Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information: Research and Development Cluster (various ALN #’s) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Condition: The University’s system of internal controls did not timely identify missing grant-related earnings allocations. Cause: Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort. Effect or Potential Effect: Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year. Questioned Costs: None. Context: For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification. Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-012. Recommendation: We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting. Views of Responsible Officials: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards. Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis. Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs. Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked. Questioned Costs: None
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards. Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis. Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs. Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked. Questioned Costs: None
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards. Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis. Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs. Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked. Questioned Costs: None
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards. Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis. Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs. Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked. Questioned Costs: None
2024-006 U.S. Department of Education for the period July 1, 2023 through June 30, 2024 Assistance Listing: #84.425D and #84.425U, Elementary and Secondary School Emergency Relief Funds Criteria: Per 2 CFR 200.430(g) Standards for Documentation of Personnel Expenses, charges to Federal awards for salaries and wages should support the distribution of employee’s salary or wages among more than one Federal award, or a Federal and non-Federal award. Budgeted estimates alone do not qualify as support for charges to Federal awards. Condition: Time and effort documentation for School Department employees who are allocated amongst multiple Federal grants is based on budgeted estimates. These estimates are not adequate to ensure actual time spent on each grant is charged to the grants. Budgeted estimates are not trued up to reflect actual time worked at year end. Cause: The School Department does not have policies and procedures requiring employees charged to multiple grants, or to Federal and non-Federal activities, to track actual time spent on each grant. There are no policies and procedures to adjust budgeted estimates to actual time incurred for each grant on a periodic basis. Effect: It could not be determined if payroll costs reflected actual time worked on the grant. This could result in grants being allocated a disproportionate share of payroll costs. Recommendation: Personnel activity reports should be prepared at least monthly to document actual time worked on grants. Budgeted payroll allocations should be adjusted periodically to reflect actual time worked. Questioned Costs: None
2024-001 Compensation for Personal Services CCDF Cluster – Assistance Listing No. 93.575 – COVID-19 Funding Award Number: CTGG1 QAAA 2024*3969 A1 – Award Period: October 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition: During our testing of time and effort records we noted that although timesheets were kept for staff working on other Federal awards, they were not kept for staff who charged salaries and wages to the Federal award under this cluster. Instead, budgeted allocations were used. Criteria: According to 2 CFR Part 200.430(g)(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 recipient or subrecipient; (iii) Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities (for IHEs, this is the IBS); (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient’s or subrecipient's written policy; (v) Comply with the established accounting policies and procedures of the recipient or subrecipient (See paragraph (i)(1)(ii) of this section for treatment of incidental work for IHEs.); and (vi) 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 allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (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. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the related work activity (as defined by the recipient's or subrecipient's written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient's or subrecipient's system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated. Questioned Costs: Not determinable. Cause: The award funder (pass-through entity) categorized the Organization as a contractor at the start of the award period, however, they notified the Organization of a change in determination to subrecipient on May 6, 2024 (7 months into the 9-month grant cycle). Thus, the terms and conditions related to subrecipients were not communicated until the contract amendment was executed effective May 12, 2024. For this reason, the Organization did not require staff working on non-Federal awards (including contracts where IIK is determined to be a contractor rather than subrecipient) to keep timesheets identifying time spent working on different funding sources/cost objectives. They used budgeted allocations to charge salaries and wages to the award tested without documentation of reconciliation after-the-fact to actual time worked on different funding sources/cost objectives. Effect: Costs for salaries and wages were not fully supported by documentation in accordance with 2 CFR Part 200.430. Allowable costs could potentially be overpaid or underpaid or disallowed and required to be paid back to the Federal awarding agency (and/or pass-through entity). Recommendation: The Organization should strengthen policies and procedures to support a system of internal control which provides a reasonable assurance that the charges to Federal awards for salaries and wages are accurate, allowable, and properly allocated. This might include: 1. Updating current policy to require staff working on non-Federal awards to also keep timesheets to track and charge actual time spent working on different funding sources/cost objectives, or 2. Establishing a process to periodically review after-the-fact interim charges made to Federal awards based on budget estimates, make timely adjustments, and document their reconciliation. Views of Responsible Officials and Planned Corrective Actions: Invest in Kids management acknowledges that there have been deficiencies in processes, which were immediately corrected beginning with the May 30th payroll forward. We have restructured timesheets to be reflective of time spent working on different funding sources/cost objectives. Additionally, all staff attended the organization’s annual financial management and internal controls training in October 2024, that included updated policies and a focus on time and effort. Policy reviews have also been completed by management.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
Criteria Title 2, Code of Federal Regulations (CFR), Subtitle A, Chapter II, Part 200, Subpart D, Cost Principles for Non-Profit Organizations, Section 200.303 states “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). (b) Comply with Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statues, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.” Additionally, Section 200.430 (g) states “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The section continues to clarify the records must “Reasonably reflect the total activity for which the employee is compensated by the recipient or subrecipient, not exceeding 100 percent of compensated activities.” Condition During our testing of the Organization’s expenditures, we noted the following deficiencies in internal controls: 1. 7 of the 50 non-payroll samples selected for testing lacked evidence of approval. 2. Management had incorrectly allocated time for 10 of the 50 payroll transactions selected for testing. 3. One employee selected for payroll testing had been compensated, and expenses allocated to the GL, at a rate other than what had been approved for the individual. Cause The Agency has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Repeat Finding No. Effect Noncompliance may impact future funding from federal and state awarding agencies. Recommendation We recommend the Agency establish and maintain effective internal control over Federal Awards in order to provide reasonable assurance that the Agency is managing the Awards in compliance with Federal statutes and regulations, as well as the terms and conditions set forth in the specific Federal Award. Additionally, we recommend the Agency implement proper internal control procedures to document hours worked, by employee, by grant; and maintain documentation to support charges allocated to each Federal award.
2024-001 Lack of Documentation to Support Distribution of Wages (Significant Deficiency) Federal Agency: Department of Education Pass-through Agency: New Hampshire Department of Education Cluster/Program: COVID – 19 Education Stabilization Fund Assistance Listing Numbers: 84.425D/84.425U Passed-through Identification: #20220358 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Internal Control over Compliance – Significant Deficiency Material Noncompliance Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the District, as a recipient of Federal funds, must establish and maintain effective internal controls 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. In addition, under 2 CFR 200.430, it states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, (2) be incorporated into the official records of the non-Federal entity, (3) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, and (4) 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 or a federal award and non-Federal award. Condition: During our review of payroll charged to the ESSER III (#20220358) grant it was noted the district gave out retention bonuses to all staff working at Haverhill Cooperative School District. Although a record of bonus recipients was maintained, it was not formally approved by the Superintendent and/or the School Board. Cause: Administrative oversight. Effect: The District did not have adequate documentation to support the distribution of the employee’s wages paid using grant funds. Questioned Costs: $33,557 Repeat Finding: No Recommendation: We recommend that if the district chooses to maintain a master spreadsheet for stipends or retention bonuses, the list should be formally reviewed and approved by both the School Board and the Superintendent. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
U.S. Department of Education AL 84.010A Title I, Basic Grants to Local Education Agencies AL 84.010A Title I, Part A - Investment in Schools 2 AL 84.367A Title II: Improving Teacher Quality State Grants AL 84.424A Title IV: Student Support and Academic Enrichment Grants Type of Finding – Noncompliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Payroll) Repeat Finding: No Condition During our tests of compliance for activities allowed or allowed and allowable costs/costs principles (payroll), the School was unable to provide the personnel action form for 4 out of 25 transactions randomly selected for testing. Additionally, 2 out of 25 the payroll transactions had instances the amounts charged to the federal program did not agree to the time and effort reporting and the associated payroll registers. Criteria In accordance with 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; (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; and (vi) 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. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Cause The School did not maintain adequate internal controls over activities allowed and allowable costs/costs principles. Effect Unallowed payroll costs could be charged to federal grants. Recommendation Internal controls over financial reporting should be designed to prevent, detect or correct, errors in a timely manner. Without adequate controls, the School cannot provide reasonable assurance transactions charged to federal grants are accurate. Questioned Costs $6,385 Management’s Response The School agrees with the finding. See Schedule of Correction Action Plans. Auditor’s Conclusion: Finding remains as stated.
U.S. Department of Education AL 84.010A Title I, Basic Grants to Local Education Agencies AL 84.010A Title I, Part A - Investment in Schools 2 AL 84.367A Title II: Improving Teacher Quality State Grants AL 84.424A Title IV: Student Support and Academic Enrichment Grants Type of Finding – Noncompliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Payroll) Repeat Finding: No Condition During our tests of compliance for activities allowed or allowed and allowable costs/costs principles (payroll), the School was unable to provide the personnel action form for 4 out of 25 transactions randomly selected for testing. Additionally, 2 out of 25 the payroll transactions had instances the amounts charged to the federal program did not agree to the time and effort reporting and the associated payroll registers. Criteria In accordance with 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; (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; and (vi) 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. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Cause The School did not maintain adequate internal controls over activities allowed and allowable costs/costs principles. Effect Unallowed payroll costs could be charged to federal grants. Recommendation Internal controls over financial reporting should be designed to prevent, detect or correct, errors in a timely manner. Without adequate controls, the School cannot provide reasonable assurance transactions charged to federal grants are accurate. Questioned Costs $6,385 Management’s Response The School agrees with the finding. See Schedule of Correction Action Plans. Auditor’s Conclusion: Finding remains as stated.
U.S. Department of Education AL 84.010A Title I, Basic Grants to Local Education Agencies AL 84.010A Title I, Part A - Investment in Schools 2 AL 84.367A Title II: Improving Teacher Quality State Grants AL 84.424A Title IV: Student Support and Academic Enrichment Grants Type of Finding – Noncompliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Payroll) Repeat Finding: No Condition During our tests of compliance for activities allowed or allowed and allowable costs/costs principles (payroll), the School was unable to provide the personnel action form for 4 out of 25 transactions randomly selected for testing. Additionally, 2 out of 25 the payroll transactions had instances the amounts charged to the federal program did not agree to the time and effort reporting and the associated payroll registers. Criteria In accordance with 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; (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; and (vi) 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. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Cause The School did not maintain adequate internal controls over activities allowed and allowable costs/costs principles. Effect Unallowed payroll costs could be charged to federal grants. Recommendation Internal controls over financial reporting should be designed to prevent, detect or correct, errors in a timely manner. Without adequate controls, the School cannot provide reasonable assurance transactions charged to federal grants are accurate. Questioned Costs $6,385 Management’s Response The School agrees with the finding. See Schedule of Correction Action Plans. Auditor’s Conclusion: Finding remains as stated.
U.S. Department of Education AL 84.010A Title I, Basic Grants to Local Education Agencies AL 84.010A Title I, Part A - Investment in Schools 2 AL 84.367A Title II: Improving Teacher Quality State Grants AL 84.424A Title IV: Student Support and Academic Enrichment Grants Type of Finding – Noncompliance and Significant Deficiency over Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Payroll) Repeat Finding: No Condition During our tests of compliance for activities allowed or allowed and allowable costs/costs principles (payroll), the School was unable to provide the personnel action form for 4 out of 25 transactions randomly selected for testing. Additionally, 2 out of 25 the payroll transactions had instances the amounts charged to the federal program did not agree to the time and effort reporting and the associated payroll registers. Criteria In accordance with 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; (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; and (vi) 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. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Cause The School did not maintain adequate internal controls over activities allowed and allowable costs/costs principles. Effect Unallowed payroll costs could be charged to federal grants. Recommendation Internal controls over financial reporting should be designed to prevent, detect or correct, errors in a timely manner. Without adequate controls, the School cannot provide reasonable assurance transactions charged to federal grants are accurate. Questioned Costs $6,385 Management’s Response The School agrees with the finding. See Schedule of Correction Action Plans. Auditor’s Conclusion: Finding remains as stated.