Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
FINDING 2022-002 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): 21-1600, 22-1600 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 2020-001. 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. The Food Service Director, Food Service Manager, and Food Service Assistant had other job responsibilities, and, therefore, were paid from multiple cost objectives. The amount of their compensation paid from the Child Nutrition Cluster (program) was based on a pre-determined percentage. No personnel activity reports or other time and effort documentation was presented to support the amounts charged to the program. The total amount paid from the School Lunch fund, for these positions, during the audit period was $48,502, which was 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 17 SOUTH DEARBORN COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Cause Management had not developed an effective system of internal controls that would have ensured compliance or that adequate supporting documentation be retained related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls, and to provide adequate supporting documentation, enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $48,502 were identified, as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls and retain adequate supporting documentation related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): 21-1600, 22-1600 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 2020-001. 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. The Food Service Director, Food Service Manager, and Food Service Assistant had other job responsibilities, and, therefore, were paid from multiple cost objectives. The amount of their compensation paid from the Child Nutrition Cluster (program) was based on a pre-determined percentage. No personnel activity reports or other time and effort documentation was presented to support the amounts charged to the program. The total amount paid from the School Lunch fund, for these positions, during the audit period was $48,502, which was 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 17 SOUTH DEARBORN COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Cause Management had not developed an effective system of internal controls that would have ensured compliance or that adequate supporting documentation be retained related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls, and to provide adequate supporting documentation, enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $48,502 were identified, as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls and retain adequate supporting documentation related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): 21-1600, 22-1600 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 2020-001. 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. The Food Service Director, Food Service Manager, and Food Service Assistant had other job responsibilities, and, therefore, were paid from multiple cost objectives. The amount of their compensation paid from the Child Nutrition Cluster (program) was based on a pre-determined percentage. No personnel activity reports or other time and effort documentation was presented to support the amounts charged to the program. The total amount paid from the School Lunch fund, for these positions, during the audit period was $48,502, which was 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 17 SOUTH DEARBORN COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Cause Management had not developed an effective system of internal controls that would have ensured compliance or that adequate supporting documentation be retained related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls, and to provide adequate supporting documentation, enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $48,502 were identified, as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls and retain adequate supporting documentation related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): 21-1600, 22-1600 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 2020-001. 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. The Food Service Director, Food Service Manager, and Food Service Assistant had other job responsibilities, and, therefore, were paid from multiple cost objectives. The amount of their compensation paid from the Child Nutrition Cluster (program) was based on a pre-determined percentage. No personnel activity reports or other time and effort documentation was presented to support the amounts charged to the program. The total amount paid from the School Lunch fund, for these positions, during the audit period was $48,502, which was 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 17 SOUTH DEARBORN COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Cause Management had not developed an effective system of internal controls that would have ensured compliance or that adequate supporting documentation be retained related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls, and to provide adequate supporting documentation, enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $48,502 were identified, as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls and retain adequate supporting documentation related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): 21-1600, 22-1600 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 2020-001. 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. The Food Service Director, Food Service Manager, and Food Service Assistant had other job responsibilities, and, therefore, were paid from multiple cost objectives. The amount of their compensation paid from the Child Nutrition Cluster (program) was based on a pre-determined percentage. No personnel activity reports or other time and effort documentation was presented to support the amounts charged to the program. The total amount paid from the School Lunch fund, for these positions, during the audit period was $48,502, which was 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 17 SOUTH DEARBORN COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Cause Management had not developed an effective system of internal controls that would have ensured compliance or that adequate supporting documentation be retained related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls, and to provide adequate supporting documentation, enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $48,502 were identified, as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls and retain adequate supporting documentation related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): 21-1600, 22-1600 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 2020-001. 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. The Food Service Director, Food Service Manager, and Food Service Assistant had other job responsibilities, and, therefore, were paid from multiple cost objectives. The amount of their compensation paid from the Child Nutrition Cluster (program) was based on a pre-determined percentage. No personnel activity reports or other time and effort documentation was presented to support the amounts charged to the program. The total amount paid from the School Lunch fund, for these positions, during the audit period was $48,502, which was 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 17 SOUTH DEARBORN COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Cause Management had not developed an effective system of internal controls that would have ensured compliance or that adequate supporting documentation be retained related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls, and to provide adequate supporting documentation, enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $48,502 were identified, as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls and retain adequate supporting documentation related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, National School Lunch Program, COVID-19 - National School Lunch Program Assistance Listings Numbers: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): 21-1600, 22-1600 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 2020-001. 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. The Food Service Director, Food Service Manager, and Food Service Assistant had other job responsibilities, and, therefore, were paid from multiple cost objectives. The amount of their compensation paid from the Child Nutrition Cluster (program) was based on a pre-determined percentage. No personnel activity reports or other time and effort documentation was presented to support the amounts charged to the program. The total amount paid from the School Lunch fund, for these positions, during the audit period was $48,502, which was 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 17 SOUTH DEARBORN COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Cause Management had not developed an effective system of internal controls that would have ensured compliance or that adequate supporting documentation be retained related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls, and to provide adequate supporting documentation, enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $48,502 were identified, as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls and retain adequate supporting documentation related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2022-007 - FINDING - Insufficient Controls over Payroll Charged to a Research Grant Federal Agency: National Institute of Health Assistance Listing Number: 93.397 Program Names and Award Numbers: Cancer Centers Support Grants (The Chicago Cancer Health Equity Collaborative a/k/a ChicagoCHEC), U54CA202995 Program Expenditures: $1,083,258 Questioned Costs: None Northeastern Illinois University (University) did not pay an employee for the time worked on a grant for a 3-month period when the employee worked those hours. During the testing of 60 expenditures selected from various research and development grants, we noted one (2%) expenditure tested for allowability was for retroactive pay to an employee originally only paid half of the hours worked on a grant for a 3-month period. The employee?s reported work hours were adjusted between periods to match available funding under the assumption that additional funding would be secured in a timely manner. The sample was not intended to be, and was not, a statistically valid sample. Uniform Guidance (2 CFR 200.430(i)) states charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. In accordance with Department of Labor regulations implementing the Fair Labor Standards Act (FLSA) (29 CFR part 516), charges for the salaries and wages of nonexempt employees must also be supported by records indicating the total number of hours worked each day. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards establish and maintain effective internal control designed to reasonably ensure compliance with Federal laws, statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure that all allowability policies are followed. University officials stated there was a significant delay by the funding agency in approving the usage of unspent grant funds from a prior period due to a delay in accepting the final financial status report for the previous grant period resulting in the University creating the payroll situation above. University?s response to delays in securing funding to pay employee resulted in costs being paid and charged to the grant in the wrong time periods. (Finding Code No. 2022-007). RECOMMENDATION - We recommend the University ensure procedures for payroll charges for employees are always for the actual hours worked within a given pay period according to the applicable regulations. UNIVERSITY RESPONSE - The University agrees with the recommendation.
Finding 2022-001 Federal Award Program: Emergency Rental Assistance Program (Assistance Listing # 21.023) Pass-through Agency: Lane County Type of Finding: Significant deficiency in internal controls over compliance Compliance Requirement: Allowable costs Criteria: The Uniform Guidance (2 CFR ?200.430) states that costs of compensation are allowable to the extent they are reasonable for the services rendered and conform to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; and follow an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable. ShelterCare?s written policies rely on the use of timesheets, activity reports (which document actual hours worked by program/grant) and an excel billing worksheet to charge time to federal program grants. Condition: We noted instances in which the internal control policies were inconsistently applied to the process of recording and billing employees? time. We also noted instances in which time sheets and activity reports were missing employee and supervisor signatures indicating approval. We also noted instances in which information from the activity reports did not agree to the underlying timesheets. Cause of Condition: Internal control policies and procedures were not consistently applied to the process for timesheet review and approval, completion of activity reports and preparation of billings for the federal program grants. There was not adequate review of the billings against the underlying support (timesheets and activity reports) to catch input errors in the billings. Effect of Condition: This condition increases the risk that the incorrect amount of costs and/or unallowable costs would be charged to the federal program. Questioned Costs: No reportable questioned costs. Context: Our sample size was 40 payroll transactions and was not a statistically valid sample as it was selected haphazardly. We noted two instances in our sample in which timesheets and activity reports were missing employee and supervisor signatures indicating approval. We noted two instances in which information input into the billing did not agree to the underlying data in the activity reports and timesheets. Repeat Finding: No. Recommendation: We recommend management review the current process used to transfer data from the timesheet to the activity report to the billing worksheets and institute additional layers of review of the data to ensure data is accurately allocated and reported in the billing worksheets for which the costs charged to the grants are derived. We also recommend management consistently apply procedures to ensure activity reports are completed for all employees charging time to programs and appropriate approvals are obtained prior to billings. View of Responsible Officials: Management agrees with the finding. See Corrective Action Plan.
Significant Deficiency 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: Elementary and Secondary School Emergency Relief (ESSER) Fund Assistance Listing No. 84.425D 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?s PARs for two employees, did not accurately reflect what was charged to the grants in order to comply with Subpart I, 2 CFR ?200.430. Cause: The District budgeted costs for certain federal grants based on the required FS-10 form it submits to the State. The District then utilized the PARs to track and document the actual time and effort to support payroll costs charged to each grant. It was noted that the actual expenses charged for two employees was not supported by the PARs maintained by the District. As described in Subpart I, 2 CFR ?200.430, the District is required to document and maintain the support for salaries charged to Federal awards. Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the Federal award. Questioned Costs: None Recommendation: The District should monitor and update the appropriate documentation to support the salaries and wages charged to Federal awards in accordance with the requirements of the Uniform Guidance at Subpart I, 2 CFR ?200.430. In the event that modifications for costs charged to grants are necessary, the District should contact the New York State Department of Education (NYSED) and file the appropriate amendment, if necessary. In addition, the District should update the PARs documentation to support amounts charged to the grant. Views of Responsible Officials of Auditee: Since the grant funding periods for each of these grants are still open, the District has contacted NYSED and has been advised to submit an amended budget for these additional costs charged, as they are allowable. In addition, the District will review its internal procedure documentation for payroll costs charged to the grants to ensure that the actual costs submitted for reimbursement are supported by the PARs for each employee.
Significant Deficiency 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: Elementary and Secondary School Emergency Relief (ESSER) Fund Assistance Listing No. 84.425D 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?s PARs for two employees, did not accurately reflect what was charged to the grants in order to comply with Subpart I, 2 CFR ?200.430. Cause: The District budgeted costs for certain federal grants based on the required FS-10 form it submits to the State. The District then utilized the PARs to track and document the actual time and effort to support payroll costs charged to each grant. It was noted that the actual expenses charged for two employees was not supported by the PARs maintained by the District. As described in Subpart I, 2 CFR ?200.430, the District is required to document and maintain the support for salaries charged to Federal awards. Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the Federal award. Questioned Costs: None Recommendation: The District should monitor and update the appropriate documentation to support the salaries and wages charged to Federal awards in accordance with the requirements of the Uniform Guidance at Subpart I, 2 CFR ?200.430. In the event that modifications for costs charged to grants are necessary, the District should contact the New York State Department of Education (NYSED) and file the appropriate amendment, if necessary. In addition, the District should update the PARs documentation to support amounts charged to the grant. Views of Responsible Officials of Auditee: Since the grant funding periods for each of these grants are still open, the District has contacted NYSED and has been advised to submit an amended budget for these additional costs charged, as they are allowable. In addition, the District will review its internal procedure documentation for payroll costs charged to the grants to ensure that the actual costs submitted for reimbursement are supported by the PARs for each employee.
2022 ? 003 Allowable Activities and Costs - Payroll Disbursements Federal Agency: U.S. Department of Treasury Centers for Disease Control and Prevention U.S. Department of Health & Human Services Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Child Support Enforcement Assistance Listing Number: 21.027 93.323 93.563 Federal Award Identification Number and Year: 1505-0271 - 2021 6NU50CK000539-01-08 DHHS-CDC - 2020 Pass-Through Agency: California Department of Public Health Heluna Health California Department of Child Support Services Pass-Through Number(s): COVID-19ELC29 and COVID-19ELC87 0187.3380 21-06 Award Period: May 26, 2021 - December 31, 2026 May 18, 2020 - November 17, 2022 and January 15, 2021 - July 31, 2023 May 1, 2020 - March 31, 2022 July 1, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: According to the Assistance Listing Description for CSLFRF and ELC, Subpart D, Post Federal; Award Requirements and Subpart E, Cost Principles apply to the assistance listing. According to the LCSA Fiscal and Administrative Policy Manual Revised 2021, costs allowable for reimbursement under the Child Support IV-D award are governed by federal regulations. Title 2, ?200.403, ?200.404, and Title 45, Part 304 provide general guidelines for determining cost allowability. According to ? 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to ? 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to ? 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to ? 200.430 Compensation?personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; 2. Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, when applicable. According to ? 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: Unknown Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
2022 ? 003 Allowable Activities and Costs - Payroll Disbursements Federal Agency: U.S. Department of Treasury Centers for Disease Control and Prevention U.S. Department of Health & Human Services Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Child Support Enforcement Assistance Listing Number: 21.027 93.323 93.563 Federal Award Identification Number and Year: 1505-0271 - 2021 6NU50CK000539-01-08 DHHS-CDC - 2020 Pass-Through Agency: California Department of Public Health Heluna Health California Department of Child Support Services Pass-Through Number(s): COVID-19ELC29 and COVID-19ELC87 0187.3380 21-06 Award Period: May 26, 2021 - December 31, 2026 May 18, 2020 - November 17, 2022 and January 15, 2021 - July 31, 2023 May 1, 2020 - March 31, 2022 July 1, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: According to the Assistance Listing Description for CSLFRF and ELC, Subpart D, Post Federal; Award Requirements and Subpart E, Cost Principles apply to the assistance listing. According to the LCSA Fiscal and Administrative Policy Manual Revised 2021, costs allowable for reimbursement under the Child Support IV-D award are governed by federal regulations. Title 2, ?200.403, ?200.404, and Title 45, Part 304 provide general guidelines for determining cost allowability. According to ? 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to ? 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to ? 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to ? 200.430 Compensation?personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; 2. Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, when applicable. According to ? 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: Unknown Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
2022 ? 003 Allowable Activities and Costs - Payroll Disbursements Federal Agency: U.S. Department of Treasury Centers for Disease Control and Prevention U.S. Department of Health & Human Services Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Child Support Enforcement Assistance Listing Number: 21.027 93.323 93.563 Federal Award Identification Number and Year: 1505-0271 - 2021 6NU50CK000539-01-08 DHHS-CDC - 2020 Pass-Through Agency: California Department of Public Health Heluna Health California Department of Child Support Services Pass-Through Number(s): COVID-19ELC29 and COVID-19ELC87 0187.3380 21-06 Award Period: May 26, 2021 - December 31, 2026 May 18, 2020 - November 17, 2022 and January 15, 2021 - July 31, 2023 May 1, 2020 - March 31, 2022 July 1, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: According to the Assistance Listing Description for CSLFRF and ELC, Subpart D, Post Federal; Award Requirements and Subpart E, Cost Principles apply to the assistance listing. According to the LCSA Fiscal and Administrative Policy Manual Revised 2021, costs allowable for reimbursement under the Child Support IV-D award are governed by federal regulations. Title 2, ?200.403, ?200.404, and Title 45, Part 304 provide general guidelines for determining cost allowability. According to ? 200.302 Financial management of 2 CFR Part 200, the financial management system of each nonfederal entity must provide for written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the federal award. According to ? 200.303 Internal controls of 2 CFR Part 200, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. According to ? 200.403 Factors affecting allowability of costs of 2 CFR Part 200, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the nonfederal entity in order to be allowable under federal awards. According to ? 200.430 Compensation?personal services of 2 CFR Part 200, costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: 1. Is reasonable for the services rendered and conforms to the established written policy of the nonfederal entity consistently applied to both federal and nonfederal activities; 2. Follows an appointment made in accordance with a nonfederal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and 3. Is determined and supported as provided in paragraph (i) of this section, when applicable. According to ? 200.431 Compensation-fringe benefits of 2 CFR Part 200, except as provided elsewhere in these principles, the costs of fringe benefits are allowable provided that the benefits are reasonable and are required by law, nonfederal entity-employee agreement, or an established policy of the nonfederal entity. Condition: The County does not have written procedures for determining the allowability of costs nor an established written policy for compensation-personal services and fringe benefits. Questioned costs: Unknown Context: During our testing, we noted the County charged various types of salaries and benefits to the grants. The County does not have written procedures for determining the allowability of costs. Specific to compensation-personal services and fringe benefits, there is not an established written policy for us to test that personnel costs charged to grants conform to, follows an appointment in accordance with, and are required by an established policy of the County. Cause: Management oversight. Effect: The auditor noted instances of noncompliance. Noncompliance results in potential unallowable costs charged to grants. Recommendation: We recommend the County establish written procedures for determining the allowability of costs to include a written policy regarding the charging of personnel costs to grants. Views of responsible officials: There is no disagreement from responsible officials.
2022-003 Department of Health and Human Services FFLA #93.087, 90CU0090, 9/30/2020 ? 9/29/2022; 90CU0095, 9/30/2018 ? 9/29/2023 Enhance Safety of Children Affected by Substance Abuse Activities Allowed and Allowable Costs Material Weakness in Internal Control over Compliance Criteria: The Center is required to have procedures in place to ensure that federal awards are expended only for allowable costs in accordance with Subpart E ? Cost Principles of the Uniform Guidance. Allowable costs are supported by appropriate documentation and correctly charged as to account, amount, and period. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.430(i) establishes the standards for documentation of personnel expenses including charges to Federal awards for salaries and wages. Charges must be based on records that accurately reflect the work performed with the records meeting the following standards: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. b) Be incorporated into the office records of the non-Federal entity. c) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities. d) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy. e) Comply with the established accounting policies and practices of the non-Federal entity. f) Support the distribution of the employee?s salary or wages among specific activities or cost objectives. g) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: In our sample of expenditures selected for testing, we noted the following items: a) ClickTime timecard, which tracks federal and nonfederal hours for employees, did not properly reflect the employees total federal and nonfederal hours being paid within the payroll register (3 instances). b) Calculation errors for expenses allocated to the grant (4 instances). Cause: Employees did not enter all nonfederal hours within the ClickTime system and the secondary review of the employee ClickTime timecards did not identify the missing hours. In addition, the secondary review of federal grant expenditure tracking spreadsheet did not identify the calculation errors. Effect: The Center?s controls did not detect or correct the errors identified, which results in a reasonable possibility that the Center could submit disallowed costs under the federal awards and would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. The program was underallocated. Context: A total non-statistical sample of 60 nonpayroll and payroll transactions were tested which accounted for $116,557 out of $870,823 of federal payroll and nonpayroll direct program expenditures. Repeat Finding from Prior Year: Yes, prior year finding 2021-003 Recommendation: We recommend management review the procedures and control processes involving timecards and the federal grant expenditure tracking spreadsheet to ensure compliance with the federal grant. Views of Responsible Officials: Management is in agreement.
2022-005 Department of Health and Human Services FFLA #93.829, H79SM083331-02, 5/1/2021 ? 12/31/2022 Section 223 Demonstration Programs to Improve Community Mental Health Services Activities Allowed and Allowable Costs Material Weakness in Internal Control over Compliance Criteria: The Center is required to have procedures in place to ensure that federal awards are expended only for allowable costs in accordance with Subpart E ? Cost Principles of the Uniform Guidance. Allowable costs are supported by appropriate documentation and correctly charged as to account, amount, and period. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.430(i) establishes the standards for documentation of personnel expenses including charges to Federal awards for salaries and wages. Charges must be based on records that accurately reflect the work performed with the records meeting the following standards: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. b) Be incorporated into the office records of the non-Federal entity. c) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities. d) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy. e) Comply with the established accounting policies and practices of the non-Federal entity. f) Support the distribution of the employee?s salary or wages among specific activities or cost objectives. g) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: In our sample of expenditures selected for testing, we noted the following items: a) ClickTime timecard, which tracks federal and nonfederal hours for employees, did not properly reflect the employees total federal and nonfederal hours being paid within the payroll register (7 instances). b) Calculation errors for expenses allocated to the grant (2 instances). Cause: Employees did not enter all nonfederal hours within the ClickTime system and the secondary review of the employee ClickTime timecards did not identify the missing hours. In addition, the secondary review of federal grant expenditure tracking spreadsheet did not identify the calculation errors. Effect: The Center?s controls did not detect or correct the errors identified, which results in a reasonable possibility that the Center could submit disallowed costs under the federal awards and would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None reported. The program was underallocated. Context: A total non-statistical sample of 60 payroll and nonpayroll transactions were tested which accounted for $222,843 out of $2,108,556 of federal payroll and nonpayroll direct program expenditures. Repeat Finding from Prior Year: Yes, prior year finding 2021-005 Recommendation: We recommend management review the procedures and control processes involving timecards and the federal grant expenditure tracking spreadsheet to ensure compliance with the federal grant. Views of Responsible Officials: Management is in agreement.
2022 ? 002 ? Elementary and Secondary School Emergency Relief Fund Activities Allowed or Unallowed & Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Federal Program Title: Elementary and Secondary School Emergency Relief Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: S425C200018, S425D200013, S425U210013 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria: Per 2 CFR 200.430, 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, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: During our testing we noted the internal control process in place during the majority of the period was insufficient to ensure proper time and effort reviews were performed and documented, and to ensure that all expenditures were supported as allowable activities and allowable costs for the program in the audit period. Questioned costs: Known - $9,653.17, Likely - $299,904.00. Known and questioned costs exceed program materiality. Context: In a statistically valid sample, 14 of 14 selections were not supported by appropriate documentation to support the amounts charged to the grants. 14 of 14 selections did not have adequate time and effort documentation. Cause: Eastbrook Community School Corporation did not have a process implemented to track time and effort for the grant, as they believed that they were not required to. Effect: Activities or costs could be charged to a federal grant which do not meet the allowability standards, leading to noncompliance. Repeat Finding: No. Recommendation: We recommend the management ensure controls are consistently in place. Training over the organization's controls may be beneficial. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 002 ? Elementary and Secondary School Emergency Relief Fund Activities Allowed or Unallowed & Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Federal Program Title: Elementary and Secondary School Emergency Relief Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: S425C200018, S425D200013, S425U210013 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria: Per 2 CFR 200.430, 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, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: During our testing we noted the internal control process in place during the majority of the period was insufficient to ensure proper time and effort reviews were performed and documented, and to ensure that all expenditures were supported as allowable activities and allowable costs for the program in the audit period. Questioned costs: Known - $9,653.17, Likely - $299,904.00. Known and questioned costs exceed program materiality. Context: In a statistically valid sample, 14 of 14 selections were not supported by appropriate documentation to support the amounts charged to the grants. 14 of 14 selections did not have adequate time and effort documentation. Cause: Eastbrook Community School Corporation did not have a process implemented to track time and effort for the grant, as they believed that they were not required to. Effect: Activities or costs could be charged to a federal grant which do not meet the allowability standards, leading to noncompliance. Repeat Finding: No. Recommendation: We recommend the management ensure controls are consistently in place. Training over the organization's controls may be beneficial. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 002 ? Elementary and Secondary School Emergency Relief Fund Activities Allowed or Unallowed & Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Federal Program Title: Elementary and Secondary School Emergency Relief Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: S425C200018, S425D200013, S425U210013 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria: Per 2 CFR 200.430, 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, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: During our testing we noted the internal control process in place during the majority of the period was insufficient to ensure proper time and effort reviews were performed and documented, and to ensure that all expenditures were supported as allowable activities and allowable costs for the program in the audit period. Questioned costs: Known - $9,653.17, Likely - $299,904.00. Known and questioned costs exceed program materiality. Context: In a statistically valid sample, 14 of 14 selections were not supported by appropriate documentation to support the amounts charged to the grants. 14 of 14 selections did not have adequate time and effort documentation. Cause: Eastbrook Community School Corporation did not have a process implemented to track time and effort for the grant, as they believed that they were not required to. Effect: Activities or costs could be charged to a federal grant which do not meet the allowability standards, leading to noncompliance. Repeat Finding: No. Recommendation: We recommend the management ensure controls are consistently in place. Training over the organization's controls may be beneficial. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 002 ? Elementary and Secondary School Emergency Relief Fund Activities Allowed or Unallowed & Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Federal Program Title: Elementary and Secondary School Emergency Relief Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: S425C200018, S425D200013, S425U210013 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria: Per 2 CFR 200.430, 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, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: During our testing we noted the internal control process in place during the majority of the period was insufficient to ensure proper time and effort reviews were performed and documented, and to ensure that all expenditures were supported as allowable activities and allowable costs for the program in the audit period. Questioned costs: Known - $9,653.17, Likely - $299,904.00. Known and questioned costs exceed program materiality. Context: In a statistically valid sample, 14 of 14 selections were not supported by appropriate documentation to support the amounts charged to the grants. 14 of 14 selections did not have adequate time and effort documentation. Cause: Eastbrook Community School Corporation did not have a process implemented to track time and effort for the grant, as they believed that they were not required to. Effect: Activities or costs could be charged to a federal grant which do not meet the allowability standards, leading to noncompliance. Repeat Finding: No. Recommendation: We recommend the management ensure controls are consistently in place. Training over the organization's controls may be beneficial. View of Responsible Officials: There is no disagreement with the audit finding.
2022 ? 002 ? Elementary and Secondary School Emergency Relief Fund Activities Allowed or Unallowed & Allowable Costs/Cost Principles Federal Agency: U.S. Department of Education Federal Program Title: Elementary and Secondary School Emergency Relief Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Federal Award Identification Number and Year: FY 21 and FY 22 Pass-Through Entity: Indiana Department of Education Pass-Through Entity Number: S425C200018, S425D200013, S425U210013 Award Period: July 1, 2020 through June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance, Material Noncompliance (Modified Opinion) Criteria: Per 2 CFR 200.430, 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, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: During our testing we noted the internal control process in place during the majority of the period was insufficient to ensure proper time and effort reviews were performed and documented, and to ensure that all expenditures were supported as allowable activities and allowable costs for the program in the audit period. Questioned costs: Known - $9,653.17, Likely - $299,904.00. Known and questioned costs exceed program materiality. Context: In a statistically valid sample, 14 of 14 selections were not supported by appropriate documentation to support the amounts charged to the grants. 14 of 14 selections did not have adequate time and effort documentation. Cause: Eastbrook Community School Corporation did not have a process implemented to track time and effort for the grant, as they believed that they were not required to. Effect: Activities or costs could be charged to a federal grant which do not meet the allowability standards, leading to noncompliance. Repeat Finding: No. Recommendation: We recommend the management ensure controls are consistently in place. Training over the organization's controls may be beneficial. View of Responsible Officials: There is no disagreement with the audit finding.