Federal Agency: U.S. Department of EducationPass Thru Entity: Oklahoma State Department of EducationFederal Program: COVID-19 Governor's Emergency Education Relief GEER-ESSER II Set Aside; COVID-19 Education Stabilization Funds- Elementary and Secondary School Emergency Relief (ESSER I & ESSER II) Fund and COVID-19 Education Stabilization Funds-American Rescue Plan (ARP) ESSER IIIAssistance Listing: COVID-19 84.425C; 84.425D & 84.425U (OCAS Projects 721; 722; 788; 793; 794; 795)Condition: Expenditures charged to program did not follow the allowable costs principles of direct costs related to time and effort.Criteria: 2 CFR 200.430(i)(1)(vii) standards for documentation of personnel expenses 1) charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. (vii) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on a federal aware and non-federal award.Context: 3 out of 37 expenditures did not comply with Uniform Guidance standards of allowable cost/cost principles.Cause: District was not aware of need to complete time and effort for this program.Effect: Noncompliance with Uniform Guidance.Recommendation: We recommend that expenditures charged to federal programs follow allowable cost principles within Uniform Guidance. We also recommend that employee cost charged to federal programs be supported with appropriate time and effort documentation.Views of Responsible Officialsand Planned CorrectiveAction: District was unaware of requirement for the COVID-19 Funds, and has implemented the time and effort procedures as they have with the other federal programs.
Federal Agency: U.S. Department of EducationPass Thru Entity: Oklahoma State Department of EducationFederal Program: COVID-19 Governor's Emergency Education Relief GEER-ESSER II Set Aside; COVID-19 Education Stabilization Funds- Elementary and Secondary School Emergency Relief (ESSER I & ESSER II) Fund and COVID-19 Education Stabilization Funds-American Rescue Plan (ARP) ESSER IIIAssistance Listing: COVID-19 84.425C; 84.425D & 84.425U (OCAS Projects 721; 722; 788; 793; 794; 795)Condition: Expenditures charged to program did not follow the allowable costs principles of direct costs related to time and effort.Criteria: 2 CFR 200.430(i)(1)(vii) standards for documentation of personnel expenses 1) charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. (vii) support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on a federal aware and non-federal award.Context: 3 out of 37 expenditures did not comply with Uniform Guidance standards of allowable cost/cost principles.Cause: District was not aware of need to complete time and effort for this program.Effect: Noncompliance with Uniform Guidance.Recommendation: We recommend that expenditures charged to federal programs follow allowable cost principles within Uniform Guidance. We also recommend that employee cost charged to federal programs be supported with appropriate time and effort documentation.Views of Responsible Officialsand Planned CorrectiveAction: District was unaware of requirement for the COVID-19 Funds, and has implemented the time and effort procedures as they have with the other federal programs.
Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Federal Agencies: Department of Justice; Department of the TreasuryProgram Titles: Crime Victim Assistance; Coronavirus State and Local Fiscal Recovery FundAssistance Listing Numbers: 16.575; 21.027Award Numbers: 22-31219-018, 22-31310-140, 22-31219-019, F19-31219-553, 8152, DA-239Award Periods: VariousCriteriaCharges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles.Condition/Context for EvaluationDuring our audit we identified that a total of 19 of 142 transactions (79 non-payroll transactions and 63 for payrolltransactions) tested for allowable costs and activities did not meet the requirements of Title 2 U.S. Code of FederalRegulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal AwardsSubpart E - Cost Principles. Below is a disaggregation of the exceptions identified:- Thirteen of the non-payroll transactions tested did not have documentation available to support the allocationof the expense to the program in accordance with 2 CFR 200.405.- Three of the non-payroll transactions tested did not meet the reasonable and necessary criteria of 2 CFR200.403.- Two of the payroll transactions tested was charged to the federal award based upon allocations determinedbefore services were performed with no process to identify significant changes in the corresponding workactivity in accordance with 2 CFR 200.430(i).- Two of the transactions tested did not have adequate documentation to support the item of cost in accordancewith the criteria at 200.403(g).- One of the transactions tested the cost incurred represented a reimbursement for costs in excess of theallowable amount per the Organization?s policies and procedures and did not meet the criteria of 2 CFR 200.403.Our sample was not a statistical sample.Effect or Potential EffectThe Organization charged costs to the federal awards that were unallowable. Questioned CostsActual questioned costs identified during the audit totaled the amounts below by award:Assistance Pass-Through KnownListing Pass-Through Award QuestionedNumber Funder Number Costs21.027 State of Oregon Department of Administrative Services 8152 $ 1921027 King County Regional Homelessness Authority DA-239 $ 3,808CauseInternal controls were not operating effectively to ensure only allowable costs were charged to the federal awards.Repeat FindingNot applicable.RecommendationWe recommend that the Organization provide additional training to employees to ensure that controls operate effectivelyso that only allowable costs are authorized to be charged to federal awards and that record retention controls arestrengthened to ensure documentation and policies are retained to support the distribution of charges between projects.Views of Responsible Officials of AuditeeManagement agrees with the finding and has provided the accompanying corrective action plan.
Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Federal Agencies: Department of Justice; Department of the TreasuryProgram Titles: Crime Victim Assistance; Coronavirus State and Local Fiscal Recovery FundAssistance Listing Numbers: 16.575; 21.027Award Numbers: 22-31219-018, 22-31310-140, 22-31219-019, F19-31219-553, 8152, DA-239Award Periods: VariousCriteriaCharges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles.Condition/Context for EvaluationDuring our audit we identified that a total of 19 of 142 transactions (79 non-payroll transactions and 63 for payrolltransactions) tested for allowable costs and activities did not meet the requirements of Title 2 U.S. Code of FederalRegulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal AwardsSubpart E - Cost Principles. Below is a disaggregation of the exceptions identified:- Thirteen of the non-payroll transactions tested did not have documentation available to support the allocationof the expense to the program in accordance with 2 CFR 200.405.- Three of the non-payroll transactions tested did not meet the reasonable and necessary criteria of 2 CFR200.403.- Two of the payroll transactions tested was charged to the federal award based upon allocations determinedbefore services were performed with no process to identify significant changes in the corresponding workactivity in accordance with 2 CFR 200.430(i).- Two of the transactions tested did not have adequate documentation to support the item of cost in accordancewith the criteria at 200.403(g).- One of the transactions tested the cost incurred represented a reimbursement for costs in excess of theallowable amount per the Organization?s policies and procedures and did not meet the criteria of 2 CFR 200.403.Our sample was not a statistical sample.Effect or Potential EffectThe Organization charged costs to the federal awards that were unallowable. Questioned CostsActual questioned costs identified during the audit totaled the amounts below by award:Assistance Pass-Through KnownListing Pass-Through Award QuestionedNumber Funder Number Costs21.027 State of Oregon Department of Administrative Services 8152 $ 1921027 King County Regional Homelessness Authority DA-239 $ 3,808CauseInternal controls were not operating effectively to ensure only allowable costs were charged to the federal awards.Repeat FindingNot applicable.RecommendationWe recommend that the Organization provide additional training to employees to ensure that controls operate effectivelyso that only allowable costs are authorized to be charged to federal awards and that record retention controls arestrengthened to ensure documentation and policies are retained to support the distribution of charges between projects.Views of Responsible Officials of AuditeeManagement agrees with the finding and has provided the accompanying corrective action plan.
Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Federal Agencies: Department of Justice; Department of the TreasuryProgram Titles: Crime Victim Assistance; Coronavirus State and Local Fiscal Recovery FundAssistance Listing Numbers: 16.575; 21.027Award Numbers: 22-31219-018, 22-31310-140, 22-31219-019, F19-31219-553, 8152, DA-239Award Periods: VariousCriteriaCharges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles.Condition/Context for EvaluationDuring our audit we identified that a total of 19 of 142 transactions (79 non-payroll transactions and 63 for payrolltransactions) tested for allowable costs and activities did not meet the requirements of Title 2 U.S. Code of FederalRegulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal AwardsSubpart E - Cost Principles. Below is a disaggregation of the exceptions identified:- Thirteen of the non-payroll transactions tested did not have documentation available to support the allocationof the expense to the program in accordance with 2 CFR 200.405.- Three of the non-payroll transactions tested did not meet the reasonable and necessary criteria of 2 CFR200.403.- Two of the payroll transactions tested was charged to the federal award based upon allocations determinedbefore services were performed with no process to identify significant changes in the corresponding workactivity in accordance with 2 CFR 200.430(i).- Two of the transactions tested did not have adequate documentation to support the item of cost in accordancewith the criteria at 200.403(g).- One of the transactions tested the cost incurred represented a reimbursement for costs in excess of theallowable amount per the Organization?s policies and procedures and did not meet the criteria of 2 CFR 200.403.Our sample was not a statistical sample.Effect or Potential EffectThe Organization charged costs to the federal awards that were unallowable. Questioned CostsActual questioned costs identified during the audit totaled the amounts below by award:Assistance Pass-Through KnownListing Pass-Through Award QuestionedNumber Funder Number Costs21.027 State of Oregon Department of Administrative Services 8152 $ 1921027 King County Regional Homelessness Authority DA-239 $ 3,808CauseInternal controls were not operating effectively to ensure only allowable costs were charged to the federal awards.Repeat FindingNot applicable.RecommendationWe recommend that the Organization provide additional training to employees to ensure that controls operate effectivelyso that only allowable costs are authorized to be charged to federal awards and that record retention controls arestrengthened to ensure documentation and policies are retained to support the distribution of charges between projects.Views of Responsible Officials of AuditeeManagement agrees with the finding and has provided the accompanying corrective action plan.
Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Federal Agencies: Department of Justice; Department of the TreasuryProgram Titles: Crime Victim Assistance; Coronavirus State and Local Fiscal Recovery FundAssistance Listing Numbers: 16.575; 21.027Award Numbers: 22-31219-018, 22-31310-140, 22-31219-019, F19-31219-553, 8152, DA-239Award Periods: VariousCriteriaCharges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles.Condition/Context for EvaluationDuring our audit we identified that a total of 19 of 142 transactions (79 non-payroll transactions and 63 for payrolltransactions) tested for allowable costs and activities did not meet the requirements of Title 2 U.S. Code of FederalRegulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal AwardsSubpart E - Cost Principles. Below is a disaggregation of the exceptions identified:- Thirteen of the non-payroll transactions tested did not have documentation available to support the allocationof the expense to the program in accordance with 2 CFR 200.405.- Three of the non-payroll transactions tested did not meet the reasonable and necessary criteria of 2 CFR200.403.- Two of the payroll transactions tested was charged to the federal award based upon allocations determinedbefore services were performed with no process to identify significant changes in the corresponding workactivity in accordance with 2 CFR 200.430(i).- Two of the transactions tested did not have adequate documentation to support the item of cost in accordancewith the criteria at 200.403(g).- One of the transactions tested the cost incurred represented a reimbursement for costs in excess of theallowable amount per the Organization?s policies and procedures and did not meet the criteria of 2 CFR 200.403.Our sample was not a statistical sample.Effect or Potential EffectThe Organization charged costs to the federal awards that were unallowable. Questioned CostsActual questioned costs identified during the audit totaled the amounts below by award:Assistance Pass-Through KnownListing Pass-Through Award QuestionedNumber Funder Number Costs21.027 State of Oregon Department of Administrative Services 8152 $ 1921027 King County Regional Homelessness Authority DA-239 $ 3,808CauseInternal controls were not operating effectively to ensure only allowable costs were charged to the federal awards.Repeat FindingNot applicable.RecommendationWe recommend that the Organization provide additional training to employees to ensure that controls operate effectivelyso that only allowable costs are authorized to be charged to federal awards and that record retention controls arestrengthened to ensure documentation and policies are retained to support the distribution of charges between projects.Views of Responsible Officials of AuditeeManagement agrees with the finding and has provided the accompanying corrective action plan.
Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Federal Agencies: Department of Justice; Department of the TreasuryProgram Titles: Crime Victim Assistance; Coronavirus State and Local Fiscal Recovery FundAssistance Listing Numbers: 16.575; 21.027Award Numbers: 22-31219-018, 22-31310-140, 22-31219-019, F19-31219-553, 8152, DA-239Award Periods: VariousCriteriaCharges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles.Condition/Context for EvaluationDuring our audit we identified that a total of 19 of 142 transactions (79 non-payroll transactions and 63 for payrolltransactions) tested for allowable costs and activities did not meet the requirements of Title 2 U.S. Code of FederalRegulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal AwardsSubpart E - Cost Principles. Below is a disaggregation of the exceptions identified:- Thirteen of the non-payroll transactions tested did not have documentation available to support the allocationof the expense to the program in accordance with 2 CFR 200.405.- Three of the non-payroll transactions tested did not meet the reasonable and necessary criteria of 2 CFR200.403.- Two of the payroll transactions tested was charged to the federal award based upon allocations determinedbefore services were performed with no process to identify significant changes in the corresponding workactivity in accordance with 2 CFR 200.430(i).- Two of the transactions tested did not have adequate documentation to support the item of cost in accordancewith the criteria at 200.403(g).- One of the transactions tested the cost incurred represented a reimbursement for costs in excess of theallowable amount per the Organization?s policies and procedures and did not meet the criteria of 2 CFR 200.403.Our sample was not a statistical sample.Effect or Potential EffectThe Organization charged costs to the federal awards that were unallowable. Questioned CostsActual questioned costs identified during the audit totaled the amounts below by award:Assistance Pass-Through KnownListing Pass-Through Award QuestionedNumber Funder Number Costs21.027 State of Oregon Department of Administrative Services 8152 $ 1921027 King County Regional Homelessness Authority DA-239 $ 3,808CauseInternal controls were not operating effectively to ensure only allowable costs were charged to the federal awards.Repeat FindingNot applicable.RecommendationWe recommend that the Organization provide additional training to employees to ensure that controls operate effectivelyso that only allowable costs are authorized to be charged to federal awards and that record retention controls arestrengthened to ensure documentation and policies are retained to support the distribution of charges between projects.Views of Responsible Officials of AuditeeManagement agrees with the finding and has provided the accompanying corrective action plan.
Finding 2022-003Material weakness in internal controls over compliance for allowable activities and costs and material non-compliance inthe Coronavirus State and Local Fiscal Recovery Fund program.Federal Agencies: Department of Justice; Department of the TreasuryProgram Titles: Crime Victim Assistance; Coronavirus State and Local Fiscal Recovery FundAssistance Listing Numbers: 16.575; 21.027Award Numbers: 22-31219-018, 22-31310-140, 22-31219-019, F19-31219-553, 8152, DA-239Award Periods: VariousCriteriaCharges to federal awards must meet the requirements of Title 2 U.S. Code of Federal Regulations Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E - Cost Principles.Condition/Context for EvaluationDuring our audit we identified that a total of 19 of 142 transactions (79 non-payroll transactions and 63 for payrolltransactions) tested for allowable costs and activities did not meet the requirements of Title 2 U.S. Code of FederalRegulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal AwardsSubpart E - Cost Principles. Below is a disaggregation of the exceptions identified:- Thirteen of the non-payroll transactions tested did not have documentation available to support the allocationof the expense to the program in accordance with 2 CFR 200.405.- Three of the non-payroll transactions tested did not meet the reasonable and necessary criteria of 2 CFR200.403.- Two of the payroll transactions tested was charged to the federal award based upon allocations determinedbefore services were performed with no process to identify significant changes in the corresponding workactivity in accordance with 2 CFR 200.430(i).- Two of the transactions tested did not have adequate documentation to support the item of cost in accordancewith the criteria at 200.403(g).- One of the transactions tested the cost incurred represented a reimbursement for costs in excess of theallowable amount per the Organization?s policies and procedures and did not meet the criteria of 2 CFR 200.403.Our sample was not a statistical sample.Effect or Potential EffectThe Organization charged costs to the federal awards that were unallowable. Questioned CostsActual questioned costs identified during the audit totaled the amounts below by award:Assistance Pass-Through KnownListing Pass-Through Award QuestionedNumber Funder Number Costs21.027 State of Oregon Department of Administrative Services 8152 $ 1921027 King County Regional Homelessness Authority DA-239 $ 3,808CauseInternal controls were not operating effectively to ensure only allowable costs were charged to the federal awards.Repeat FindingNot applicable.RecommendationWe recommend that the Organization provide additional training to employees to ensure that controls operate effectivelyso that only allowable costs are authorized to be charged to federal awards and that record retention controls arestrengthened to ensure documentation and policies are retained to support the distribution of charges between projects.Views of Responsible Officials of AuditeeManagement agrees with the finding and has provided the accompanying corrective action plan.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
Criteria or specific requirement: Per guidance: 2 CFR 200.430, (i) Standards for Documentation of Personnel Expenses, (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.Condition: We noted the College?s Time and Effort is originally based upon an estimate at the beginning of the year. While the employee does later certify the estimate is correct (or submits any adjustments), this certification is only completed once a year and it is not reviewed or approved by anyone other than the employee. There was no control in place to detect if the employee?s certification was incorrect.Questioned costs: None.Context: We tested 40 employees and noted for all tested, while the employee certified their time and effort, this certification occurred once a calendar year from one to four months after the calendar year end. In addition, there was no review control to ensure certification was accurate, allowable, and properly allocated.Cause: The College was not aware there should be a distinct internal control over time and effort reporting.Effect: The College?s system of time and effort reporting does not have internal controls to provide reasonable assurance that payroll charges are based upon actual time incurred. As such, it could inadvertently be allocating personnel expenses inaccurately and improperly to federal awards.Repeat finding: No.Recommendation: We recommend that the College increase the time and effort certification process to be more timely and implement a review process over the time and effort certification process.View of responsible official: The College agrees with the finding.
FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003Subject: Child Nutrition Cluster - Allowable Costs/Cost PrinciplesFederal Agency: Department of AgricultureFederal Programs: School Breakfast Program, COVID-19 - School Breakfast Program, NationalSchool Lunch Program, COVID-19 - National School Lunch ProgramAssistance Listings Numbers: 10.553, 10.555Federal Award Numbers and Years (or Other Identifying Numbers): FY2021, FY2022Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.The School Corporation had not developed nor implemented internal controls over transactionspaid from the Child Nutrition Cluster funds to ensure that the payment was an allowable cost for the benefitof the food service program.Additionally, the School Corporation paid food service employees that worked more than 5.25 hoursa day on a biweekly basis with payments that continued into the summer. In order to do this, an employee'spay was annualized based on the expected number of days worked and then divided by 26. Each employeewas required to complete a timesheet every two weeks, which was approved by their supervisor, to supportthe time worked during the school year. Four of the fourteen paychecks selected for testing had errors.Two of the paychecks did not have the required timesheets, and two of the paychecks did not havetimesheets that reflected time worked to adequately support the amount paid to the employee.The lack of internal controls was a systemic issue for all disbursements throughout the audit period.The noncompliance was isolated to payroll disbursements for the school year ended June 30, 2021.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.403 states in part:"Except where otherwise authorized by statute, costs must meet the following general criteriain order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federalaward as to types or amount of cost items. . . .(g) Be adequately documented. . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Modified OpinionCondition and ContextAn effective internal control system was not in place at the School Corporation in order to ensurecompliance with requirements related to the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.The School Corporation did not have adequate internal controls in place to ensure that the reimbursementrequests included salaries for all contracted employees and adequate supporting documentationor personnel activity reports, such as time and effort logs or Semi-Annual Certifications. The SchoolCorporation paid salaries for all contracted employees without adequate supporting documentation orpersonnel activity reports, such as time and effort logs or Semi-Annual Certifications. The total amountpaid to contracted employees was $51,644. This amount was considered questioned costs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.CriteriaCFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could have resulted in the loss of federal funds to the School Corporation.Questioned CostsQuestioned costs of $51,644 were identified, as described in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Modified OpinionCondition and ContextAn effective internal control system was not in place at the School Corporation in order to ensurecompliance with requirements related to the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.The School Corporation did not have adequate internal controls in place to ensure that the reimbursementrequests included salaries for all contracted employees and adequate supporting documentationor personnel activity reports, such as time and effort logs or Semi-Annual Certifications. The SchoolCorporation paid salaries for all contracted employees without adequate supporting documentation orpersonnel activity reports, such as time and effort logs or Semi-Annual Certifications. The total amountpaid to contracted employees was $51,644. This amount was considered questioned costs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.CriteriaCFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could have resulted in the loss of federal funds to the School Corporation.Questioned CostsQuestioned costs of $51,644 were identified, as described in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Material Weakness, Modified OpinionCondition and ContextAn effective internal control system was not in place at the School Corporation in order to ensurecompliance with requirements related to the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.The School Corporation did not have adequate internal controls in place to ensure that the reimbursementrequests included salaries for all contracted employees and adequate supporting documentationor personnel activity reports, such as time and effort logs or Semi-Annual Certifications. The SchoolCorporation paid salaries for all contracted employees without adequate supporting documentation orpersonnel activity reports, such as time and effort logs or Semi-Annual Certifications. The total amountpaid to contracted employees was $51,644. This amount was considered questioned costs.The lack of internal controls and noncompliance were systemic issues throughout the audit period.CriteriaCFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses(1) Charges to Federal awards for salaries and wages must be based on records thataccurately reflect the work performed. These records must:(i) Be supported by a system of internal control which provides reasonableassurance that the charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;(iii) Reasonably reflect the total activity for which the employee is compensated bythe non-Federal entity, not exceeding 100% of compensated activities . . .(vii) Support the distribution of the employee's salary or wages among specificactivities or cost objectives if the employee works on more than one Federal award; aFederal award and non-Federal award; an indirect cost activity and a direct costactivity; two or more indirect activities which are allocated using different allocationbases; or an unallowable activity and a direct or indirect cost activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could have resulted in the loss of federal funds to the School Corporation.Questioned CostsQuestioned costs of $51,644 were identified, as described in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish a system of internal controlsto ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principlescompliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Significant Deficiency, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Charges to Federal awards for salaries and wages must be based on records that accurately reflectthe work performed. One employee was paid from ESSER I and ESSER II grant awards and also fromother funding sources. Adequate time records were not maintained for the employee to determine if theproper amount was charged to the federal award. The total amount charged to the federal award of $28,599was considered a questioned cost.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salariesand wages must be based on records that accurately reflect the work performed. Theserecords must:(i) Be supported by a system of internal control which provides reasonable assurance thatthe charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;INDIANA STATE BOARD OF ACCOUNTS16SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)(iii) Reasonably reflect the total activity for which the employee is compensated by thenon-Federal entity, not exceeding 100% of compensated activities (for IHE, this perthe IHE's definition of IBS); . . .(vii) Support the distribution of the employee's salary or wages among specific activitiesor cost objectives if the employee works on more than one Federal award; a Federalaward and non-Federal award; an indirect cost activity and a direct cost activity; twoor more indirect activities which allocated using different allocation bases; or anunallowable activity and a direct or indirect costs activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsQuestioned costs of $28,599 were identified as detailed in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Significant Deficiency, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Charges to Federal awards for salaries and wages must be based on records that accurately reflectthe work performed. One employee was paid from ESSER I and ESSER II grant awards and also fromother funding sources. Adequate time records were not maintained for the employee to determine if theproper amount was charged to the federal award. The total amount charged to the federal award of $28,599was considered a questioned cost.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salariesand wages must be based on records that accurately reflect the work performed. Theserecords must:(i) Be supported by a system of internal control which provides reasonable assurance thatthe charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;INDIANA STATE BOARD OF ACCOUNTS16SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)(iii) Reasonably reflect the total activity for which the employee is compensated by thenon-Federal entity, not exceeding 100% of compensated activities (for IHE, this perthe IHE's definition of IBS); . . .(vii) Support the distribution of the employee's salary or wages among specific activitiesor cost objectives if the employee works on more than one Federal award; a Federalaward and non-Federal award; an indirect cost activity and a direct cost activity; twoor more indirect activities which allocated using different allocation bases; or anunallowable activity and a direct or indirect costs activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsQuestioned costs of $28,599 were identified as detailed in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost PrinciplesFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: Allowable Costs/Cost PrinciplesAudit Findings: Significant Deficiency, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Charges to Federal awards for salaries and wages must be based on records that accurately reflectthe work performed. One employee was paid from ESSER I and ESSER II grant awards and also fromother funding sources. Adequate time records were not maintained for the employee to determine if theproper amount was charged to the federal award. The total amount charged to the federal award of $28,599was considered a questioned cost.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.430(i) states in part:"Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salariesand wages must be based on records that accurately reflect the work performed. Theserecords must:(i) Be supported by a system of internal control which provides reasonable assurance thatthe charges are accurate, allowable, and properly allocated;(ii) Be incorporated into the official records of the non-Federal entity;INDIANA STATE BOARD OF ACCOUNTS16SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)(iii) Reasonably reflect the total activity for which the employee is compensated by thenon-Federal entity, not exceeding 100% of compensated activities (for IHE, this perthe IHE's definition of IBS); . . .(vii) Support the distribution of the employee's salary or wages among specific activitiesor cost objectives if the employee works on more than one Federal award; a Federalaward and non-Federal award; an indirect cost activity and a direct cost activity; twoor more indirect activities which allocated using different allocation bases; or anunallowable activity and a direct or indirect costs activity. . . ."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Allowable Costs/Cost Principles compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement could result in the loss of future federal funds to the School Corporation.Questioned CostsQuestioned costs of $28,599 were identified as detailed in the Condition and Context.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliancerequirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Federal Awarding Agency: U.S. Department of Health and Human Services (USDHHS)Impact: Significant Deficiency, NoncomplianceAL Number and Title: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)Federal Award Number: 6 NU50CK000509-01-06Applicable Compliance Requirement: Allowable Costs/Cost PrinciplesCondition:Seven of 25 timesheets that charged FY 22 personal services to the ELC program were not supported in compliance with federal requirements.Context:The audit tested a sample of 25 timesheets and identified seven instances of noncompliance. Four errors were personal and holiday leave charged to the grant award when the timesheets did not indicate time worked on the ELC program. Two timesheets lacked positive time keeping or biennial certifications attesting that the employees worked 100 percent of the time on ELC. One timesheet was inaccurately entered into the payroll system.Cause:According to Division of Public Health (DPH) management, staff turnover and inadequate training for temporary employees on how to complete, review, and approve timesheets contributed to the timesheet errors.Criteria:Per Title 45 CFR 75.303(a), the State must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Title 2 CFR 200.430(i)(1) states 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.Effect:The errors resulted in questioned costs totaling $9,778. Questioned costs for the population are projected to be $608,618 based on the dollar of noncompliance observed in the sample projected over the tested population. Noncompliance with federal regulations may result in the federal award agency imposing additional conditions or taking corrective action, including reduced federal funding.Questioned Costs:$9,778Recommendation:DPH?s director should provide training for completing and reviewing timesheets, and ensure personal service costs charged to the ELC program are allowable and supported by required documentation.Views of Responsible Officials:Management agrees with the finding.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.
Finding 2022-008 ? Allowable Costs/Cost PrinciplesIdentification of the federal program U.S. Department of DefenseU.S. Department of Health and Human ServicesResearch and Development ClusterAssistance Listing Nos.12.420, 93.103, 93.121, 93.279, 93.286, 93.310, 93.350, 93.361, 93,394, 93.396, 93.650, 93.837, 93.838, 93.847, 93.853, 93.855, 93.865, and 93.866See Schedule of Findings and Questioned Costs for chart/tableCriteria or specific requirement (including statutory, regulatory, or other citation) 2 CFR 200.303(a) requires that the non-Federal entity must ?(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).?2 CFR Part 200 Section 200.430 (i) states ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) be incorporated into the official records of the non-Federal entity; (iii) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) comply with the established accounting policies and practices of the non-Federal entity.?Condition St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Cause Management did not review payroll expenditures to support allowable costs/cost principles nor did it reconcile budgeted costs to actual costs incurred for certain payroll expenses.Effect or potential effect Unallowable and inaccurate payroll expenditures could be charged to the federal program.Questioned costs None.Context We issued a material weakness related to internal controls in the prior year. Based upon the implementation date for the corrective action provided by management, the finding related to this internal control had not been remediated for the full period under audit. As such, we did not test the operating effectiveness of this control and are issuing a material weakness consistent with the prior year finding.Payroll expenditures of $4.1 million represent 33% of St. Joseph?s Hospital and Medical Center?s total research and development expenditures of $12.6 million, which represent 16% of total research and development cluster expenditures of $77.5 million.Identification as a repeat finding, if applicable This is a repeat finding for St. Joseph Hospital and Medical Center ? Finding 2021-009.Recommendation We recommend management implement a process to record time charged to federal grants in accordance with 2 CFR 200.430 and implement effective internal controls to review and approve payroll expenditures charged to the grant.Views of responsibleofficials Management agrees with the finding and implemented corrective action in September 2022.