Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
Research and Development Cluster, Various Assistance Listing Numbers, Various Agencies, Award Year 2022 Criteria or Specific Requirement ? Special Tests and Provisions ? Key Personnel ? 2 CFR ? 200.430(i) Condition ? The University is required to implement a system of internal controls that provide reasonable assurance of compliance with key personnel requirements specified in grant applications and proposals. Questioned Costs ? None Context ? The University?s time and effort review process includes review of monthly labor certification reports. These reports were not consistently reviewed in a timely manner during FY 2022. Effect ? Employee time charged to grants was not certified timely during the year. Cause ? The University?s internal controls did not include follow-up to ensure that key personnel were reviewing and approving personnel costs in a timely manner. Identification as a Repeat Finding, if applicable ? N/A Recommendation ? The University should ensure internal controls related to documenting effort and certification are aligned with Uniform Guidance standards. Views of Responsible Officials and Planned Corrective Actions ? Management concurs with the finding and proper controls are being implemented during FY2023. Management will implement a labor certification monitoring and escalation process. A reminder will be distributed to all principal investigators reminding them of the University?s policy and their responsibilities in the review and confirmation of their personnel expenditures.
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.