Section 2 - Federal and State Award Findings and Questioned Costs Significant Deficiency 2024-001 Payroll costs were allocated to incorrect programs Prevention and Treatment of Substance Abuse, CFDA #93.959, Pass-Through Grant #HHS000539700192 Criteria: In accordance with Uniform Guidance (2 CFR § 200.430g), payroll costs must be charged accurately to federal awards and should be supported by records that appropriately reflect the work performed. Condition: Payroll costs reported for the associated programs under pass-through grant #HHS000539700192 totaling approximately $30,242 were erroneously charged to the incorrect program. Cause: The issue was caused by coding errors in the accounting system during payroll processing. The responsible personnel mistakenly allocated the employees' hours to incorrect program codes for certain employees and pay periods without adequate review and reconciliation to the source timesheets. Effect: Payroll costs for the individual programs under CFDA #93.959, Pass-Through Grant #HHS000539700192 were overstated in total by approximately $30,242. Questioned Costs: Approximately $30,242 Context: The finding was isolated to payroll costs and for only certain employees and pay periods, and no findings were identified related to other non-personnel direct or indirect costs or other compliance requirements. Repeat Finding: No Recommendation: We recommend that the Organization strengthen internal controls over payroll cost allocations, including adding an additional layer of review over payroll and ensuring the payroll data in the accounting system is properly reconciled to the employees' timesheets each pay period. Additionally, as possible, we recommend configuring validation controls in the accounting system to help prevent employees from being charged to incorrect program codes. Views of Responsible Officials and Planned Corrections Actions: Management agrees with the audit finding and a response is included in the corrective action plan.
Health Center Program Cluster AL No. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. H80CS00438, H8FCS40427, H8GCS47600 Healthy Start Initiative AL No. 93.926 Us. Department of Health and Human Services Award No. H49MC00156 Criteria: Under 2 CFR 200.430, payroll expenses must be based on records that accurately reflect the work performed and supported by a system of internal control that provides reasonable assurance that charges are accurate, allowable, and properly allocated. Condition: During the testing performed, it was noted that the Organization transferred payroll costs between programs, however, no time and effort certification or equivalent documentation was updated to reflect the changes. Additionally, the transfer of payroll costs between grants was not properly reflected within the accounting system records by grant. These transfers between grants were completed after the end of the fiscal year. Cause: During the year the Organization had new grants, but the payroll system was not updated to reflect the changes. Effect: Allocation of payroll costs to the federal award program may be inaccurate or not properly documented. Questioned costs: n/a Context: The Organization did not maintain supporting documentation for payroll costs that were reallocated to a new grant. These costs were reallocated from the Health Center Program and from the Healthy Start Initiative funding to the new award. Repeat Finding: No Recommendation: The Organization should review and update the policies and procedures regarding payroll costs. Additionally, the Organization should provide training to staff on grant tracking and documentation. Views of Responsible Officials: Management agrees with this finding. Staff will be trained to ensure future changes in payroll costs are updated timely within the system and documentation maintained.
Health Center Program Cluster AL No. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. H80CS00438, H8FCS40427, H8GCS47600 Healthy Start Initiative AL No. 93.926 Us. Department of Health and Human Services Award No. H49MC00156 Criteria: Under 2 CFR 200.430, payroll expenses must be based on records that accurately reflect the work performed and supported by a system of internal control that provides reasonable assurance that charges are accurate, allowable, and properly allocated. Condition: During the testing performed, it was noted that the Organization transferred payroll costs between programs, however, no time and effort certification or equivalent documentation was updated to reflect the changes. Additionally, the transfer of payroll costs between grants was not properly reflected within the accounting system records by grant. These transfers between grants were completed after the end of the fiscal year. Cause: During the year the Organization had new grants, but the payroll system was not updated to reflect the changes. Effect: Allocation of payroll costs to the federal award program may be inaccurate or not properly documented. Questioned costs: n/a Context: The Organization did not maintain supporting documentation for payroll costs that were reallocated to a new grant. These costs were reallocated from the Health Center Program and from the Healthy Start Initiative funding to the new award. Repeat Finding: No Recommendation: The Organization should review and update the policies and procedures regarding payroll costs. Additionally, the Organization should provide training to staff on grant tracking and documentation. Views of Responsible Officials: Management agrees with this finding. Staff will be trained to ensure future changes in payroll costs are updated timely within the system and documentation maintained.
Health Center Program Cluster AL No. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. H80CS00438, H8FCS40427, H8GCS47600 Healthy Start Initiative AL No. 93.926 Us. Department of Health and Human Services Award No. H49MC00156 Criteria: Under 2 CFR 200.430, payroll expenses must be based on records that accurately reflect the work performed and supported by a system of internal control that provides reasonable assurance that charges are accurate, allowable, and properly allocated. Condition: During the testing performed, it was noted that the Organization transferred payroll costs between programs, however, no time and effort certification or equivalent documentation was updated to reflect the changes. Additionally, the transfer of payroll costs between grants was not properly reflected within the accounting system records by grant. These transfers between grants were completed after the end of the fiscal year. Cause: During the year the Organization had new grants, but the payroll system was not updated to reflect the changes. Effect: Allocation of payroll costs to the federal award program may be inaccurate or not properly documented. Questioned costs: n/a Context: The Organization did not maintain supporting documentation for payroll costs that were reallocated to a new grant. These costs were reallocated from the Health Center Program and from the Healthy Start Initiative funding to the new award. Repeat Finding: No Recommendation: The Organization should review and update the policies and procedures regarding payroll costs. Additionally, the Organization should provide training to staff on grant tracking and documentation. Views of Responsible Officials: Management agrees with this finding. Staff will be trained to ensure future changes in payroll costs are updated timely within the system and documentation maintained.
Health Center Program Cluster AL No. 93.224 and 93.527 U.S. Department of Health and Human Services Award No. H80CS00438, H8FCS40427, H8GCS47600 Healthy Start Initiative AL No. 93.926 Us. Department of Health and Human Services Award No. H49MC00156 Criteria: Under 2 CFR 200.430, payroll expenses must be based on records that accurately reflect the work performed and supported by a system of internal control that provides reasonable assurance that charges are accurate, allowable, and properly allocated. Condition: During the testing performed, it was noted that the Organization transferred payroll costs between programs, however, no time and effort certification or equivalent documentation was updated to reflect the changes. Additionally, the transfer of payroll costs between grants was not properly reflected within the accounting system records by grant. These transfers between grants were completed after the end of the fiscal year. Cause: During the year the Organization had new grants, but the payroll system was not updated to reflect the changes. Effect: Allocation of payroll costs to the federal award program may be inaccurate or not properly documented. Questioned costs: n/a Context: The Organization did not maintain supporting documentation for payroll costs that were reallocated to a new grant. These costs were reallocated from the Health Center Program and from the Healthy Start Initiative funding to the new award. Repeat Finding: No Recommendation: The Organization should review and update the policies and procedures regarding payroll costs. Additionally, the Organization should provide training to staff on grant tracking and documentation. Views of Responsible Officials: Management agrees with this finding. Staff will be trained to ensure future changes in payroll costs are updated timely within the system and documentation maintained.
Finding Number 2024-001: Represents a significant deficiency in internal control over compliance with Western Maine Community Action, Inc.’s major federal programs. Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control Over Compliance Description: Payroll Expenditures – Approval of Time Sheets Major Programs: AL#10.557 - WIC Special Supplemental Nutrition Program for Women, Infants and Children – Award numbers: CD3-22-4658B and CD3-24-4658A; AL#81.042 – Weatherization – 80224, 80225, 81323, and 84023; AL#93.569 – Community Services Block Grant – Award numbers: CFS-23-7009 and CFS-24-7009 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of a sample of 80 payroll transactions there were 3 where the timesheet was not properly approved by the supervisor prior to payroll being processed. Criteria: 2 CFR 200.430(i) states that “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated”. Cause: The Organization does not have the proper review process in place to ensure that the timesheets are reviewed by supervisors prior to payroll being processed. Effect: Without proper review and approval of the hours allocated to the grants on the employee timesheets, it is possible that grants could be over or undercharged. Recommendation: We recommend the Organization implement systems and procedures to ensure timesheets are approved by supervisors prior to payroll being processed, to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the findings and has committed to a corrective action plan.
Finding Number 2024-001: Represents a significant deficiency in internal control over compliance with Western Maine Community Action, Inc.’s major federal programs. Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control Over Compliance Description: Payroll Expenditures – Approval of Time Sheets Major Programs: AL#10.557 - WIC Special Supplemental Nutrition Program for Women, Infants and Children – Award numbers: CD3-22-4658B and CD3-24-4658A; AL#81.042 – Weatherization – 80224, 80225, 81323, and 84023; AL#93.569 – Community Services Block Grant – Award numbers: CFS-23-7009 and CFS-24-7009 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of a sample of 80 payroll transactions there were 3 where the timesheet was not properly approved by the supervisor prior to payroll being processed. Criteria: 2 CFR 200.430(i) states that “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated”. Cause: The Organization does not have the proper review process in place to ensure that the timesheets are reviewed by supervisors prior to payroll being processed. Effect: Without proper review and approval of the hours allocated to the grants on the employee timesheets, it is possible that grants could be over or undercharged. Recommendation: We recommend the Organization implement systems and procedures to ensure timesheets are approved by supervisors prior to payroll being processed, to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the findings and has committed to a corrective action plan.
Finding Number 2024-001: Represents a significant deficiency in internal control over compliance with Western Maine Community Action, Inc.’s major federal programs. Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control Over Compliance Description: Payroll Expenditures – Approval of Time Sheets Major Programs: AL#10.557 - WIC Special Supplemental Nutrition Program for Women, Infants and Children – Award numbers: CD3-22-4658B and CD3-24-4658A; AL#81.042 – Weatherization – 80224, 80225, 81323, and 84023; AL#93.569 – Community Services Block Grant – Award numbers: CFS-23-7009 and CFS-24-7009 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of a sample of 80 payroll transactions there were 3 where the timesheet was not properly approved by the supervisor prior to payroll being processed. Criteria: 2 CFR 200.430(i) states that “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated”. Cause: The Organization does not have the proper review process in place to ensure that the timesheets are reviewed by supervisors prior to payroll being processed. Effect: Without proper review and approval of the hours allocated to the grants on the employee timesheets, it is possible that grants could be over or undercharged. Recommendation: We recommend the Organization implement systems and procedures to ensure timesheets are approved by supervisors prior to payroll being processed, to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the findings and has committed to a corrective action plan.
Finding Number 2024-001: Represents a significant deficiency in internal control over compliance with Western Maine Community Action, Inc.’s major federal programs. Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control Over Compliance Description: Payroll Expenditures – Approval of Time Sheets Major Programs: AL#10.557 - WIC Special Supplemental Nutrition Program for Women, Infants and Children – Award numbers: CD3-22-4658B and CD3-24-4658A; AL#81.042 – Weatherization – 80224, 80225, 81323, and 84023; AL#93.569 – Community Services Block Grant – Award numbers: CFS-23-7009 and CFS-24-7009 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of a sample of 80 payroll transactions there were 3 where the timesheet was not properly approved by the supervisor prior to payroll being processed. Criteria: 2 CFR 200.430(i) states that “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated”. Cause: The Organization does not have the proper review process in place to ensure that the timesheets are reviewed by supervisors prior to payroll being processed. Effect: Without proper review and approval of the hours allocated to the grants on the employee timesheets, it is possible that grants could be over or undercharged. Recommendation: We recommend the Organization implement systems and procedures to ensure timesheets are approved by supervisors prior to payroll being processed, to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the findings and has committed to a corrective action plan.
Finding Number 2024-001: Represents a significant deficiency in internal control over compliance with Western Maine Community Action, Inc.’s major federal programs. Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control Over Compliance Description: Payroll Expenditures – Approval of Time Sheets Major Programs: AL#10.557 - WIC Special Supplemental Nutrition Program for Women, Infants and Children – Award numbers: CD3-22-4658B and CD3-24-4658A; AL#81.042 – Weatherization – 80224, 80225, 81323, and 84023; AL#93.569 – Community Services Block Grant – Award numbers: CFS-23-7009 and CFS-24-7009 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of a sample of 80 payroll transactions there were 3 where the timesheet was not properly approved by the supervisor prior to payroll being processed. Criteria: 2 CFR 200.430(i) states that “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated”. Cause: The Organization does not have the proper review process in place to ensure that the timesheets are reviewed by supervisors prior to payroll being processed. Effect: Without proper review and approval of the hours allocated to the grants on the employee timesheets, it is possible that grants could be over or undercharged. Recommendation: We recommend the Organization implement systems and procedures to ensure timesheets are approved by supervisors prior to payroll being processed, to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the findings and has committed to a corrective action plan.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel Type of Finding: Material Weakness in Internal Control Over Compliance New or Repeat Finding: New Federal Program: Special Education Cluster (ALNs 84.027, 84.173) Federal Agency: U.S. Department of Education Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406, 225350020849025000, 225360020849025360), Region 10 Education Service Center (236600497110001) Compliance Requirement: B - Allowable Costs / Costs Principles Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective, charges for their salaries must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. One allowable method is through completion of semi-annual certifications signed by the employee or a supervisory official with firsthand knowledge. These certifications provide assurance that salary costs charged to the federal program reflects the total activity for which the employee is compensated by the District, not exceeding 100% of compensated activities. Condition: The district did not maintain required semi-annual certifications for employees who worked solely on the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee worked 100% on the program for the period covered, were missing for all employees. Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed, and retained in accordance with federal requirements. Staff turnover and limited awareness of the documentation rules contributed to the oversight. Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported personnel costs were charged to the program, even if employees were appropriately assigned. Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures that employees worked solely on the program. The personnel records of the employees sampled contained approval of the employee to be hired into the appropriate job duties to be funded by special education cluster grant funds. Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees selected in our sample for testing. Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual certifications are prepared, signed, and retained for all employees working solely on federal programs. The district should provide training to finance and program staff to ensure continued compliance with federal documentation requirements. Views of Responsible Officials: District officials agree with the finding. The District has implemented new procedures in fiscal year 2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel Type of Finding: Material Weakness in Internal Control Over Compliance New or Repeat Finding: New Federal Program: Special Education Cluster (ALNs 84.027, 84.173) Federal Agency: U.S. Department of Education Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406, 225350020849025000, 225360020849025360), Region 10 Education Service Center (236600497110001) Compliance Requirement: B - Allowable Costs / Costs Principles Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective, charges for their salaries must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. One allowable method is through completion of semi-annual certifications signed by the employee or a supervisory official with firsthand knowledge. These certifications provide assurance that salary costs charged to the federal program reflects the total activity for which the employee is compensated by the District, not exceeding 100% of compensated activities. Condition: The district did not maintain required semi-annual certifications for employees who worked solely on the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee worked 100% on the program for the period covered, were missing for all employees. Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed, and retained in accordance with federal requirements. Staff turnover and limited awareness of the documentation rules contributed to the oversight. Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported personnel costs were charged to the program, even if employees were appropriately assigned. Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures that employees worked solely on the program. The personnel records of the employees sampled contained approval of the employee to be hired into the appropriate job duties to be funded by special education cluster grant funds. Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees selected in our sample for testing. Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual certifications are prepared, signed, and retained for all employees working solely on federal programs. The district should provide training to finance and program staff to ensure continued compliance with federal documentation requirements. Views of Responsible Officials: District officials agree with the finding. The District has implemented new procedures in fiscal year 2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel Type of Finding: Material Weakness in Internal Control Over Compliance New or Repeat Finding: New Federal Program: Special Education Cluster (ALNs 84.027, 84.173) Federal Agency: U.S. Department of Education Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406, 225350020849025000, 225360020849025360), Region 10 Education Service Center (236600497110001) Compliance Requirement: B - Allowable Costs / Costs Principles Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective, charges for their salaries must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. One allowable method is through completion of semi-annual certifications signed by the employee or a supervisory official with firsthand knowledge. These certifications provide assurance that salary costs charged to the federal program reflects the total activity for which the employee is compensated by the District, not exceeding 100% of compensated activities. Condition: The district did not maintain required semi-annual certifications for employees who worked solely on the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee worked 100% on the program for the period covered, were missing for all employees. Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed, and retained in accordance with federal requirements. Staff turnover and limited awareness of the documentation rules contributed to the oversight. Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported personnel costs were charged to the program, even if employees were appropriately assigned. Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures that employees worked solely on the program. The personnel records of the employees sampled contained approval of the employee to be hired into the appropriate job duties to be funded by special education cluster grant funds. Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees selected in our sample for testing. Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual certifications are prepared, signed, and retained for all employees working solely on federal programs. The district should provide training to finance and program staff to ensure continued compliance with federal documentation requirements. Views of Responsible Officials: District officials agree with the finding. The District has implemented new procedures in fiscal year 2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel Type of Finding: Material Weakness in Internal Control Over Compliance New or Repeat Finding: New Federal Program: Special Education Cluster (ALNs 84.027, 84.173) Federal Agency: U.S. Department of Education Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406, 225350020849025000, 225360020849025360), Region 10 Education Service Center (236600497110001) Compliance Requirement: B - Allowable Costs / Costs Principles Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective, charges for their salaries must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. One allowable method is through completion of semi-annual certifications signed by the employee or a supervisory official with firsthand knowledge. These certifications provide assurance that salary costs charged to the federal program reflects the total activity for which the employee is compensated by the District, not exceeding 100% of compensated activities. Condition: The district did not maintain required semi-annual certifications for employees who worked solely on the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee worked 100% on the program for the period covered, were missing for all employees. Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed, and retained in accordance with federal requirements. Staff turnover and limited awareness of the documentation rules contributed to the oversight. Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported personnel costs were charged to the program, even if employees were appropriately assigned. Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures that employees worked solely on the program. The personnel records of the employees sampled contained approval of the employee to be hired into the appropriate job duties to be funded by special education cluster grant funds. Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees selected in our sample for testing. Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual certifications are prepared, signed, and retained for all employees working solely on federal programs. The district should provide training to finance and program staff to ensure continued compliance with federal documentation requirements. Views of Responsible Officials: District officials agree with the finding. The District has implemented new procedures in fiscal year 2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel Type of Finding: Material Weakness in Internal Control Over Compliance New or Repeat Finding: New Federal Program: Special Education Cluster (ALNs 84.027, 84.173) Federal Agency: U.S. Department of Education Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406, 225350020849025000, 225360020849025360), Region 10 Education Service Center (236600497110001) Compliance Requirement: B - Allowable Costs / Costs Principles Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective, charges for their salaries must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. One allowable method is through completion of semi-annual certifications signed by the employee or a supervisory official with firsthand knowledge. These certifications provide assurance that salary costs charged to the federal program reflects the total activity for which the employee is compensated by the District, not exceeding 100% of compensated activities. Condition: The district did not maintain required semi-annual certifications for employees who worked solely on the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee worked 100% on the program for the period covered, were missing for all employees. Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed, and retained in accordance with federal requirements. Staff turnover and limited awareness of the documentation rules contributed to the oversight. Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported personnel costs were charged to the program, even if employees were appropriately assigned. Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures that employees worked solely on the program. The personnel records of the employees sampled contained approval of the employee to be hired into the appropriate job duties to be funded by special education cluster grant funds. Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees selected in our sample for testing. Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual certifications are prepared, signed, and retained for all employees working solely on federal programs. The district should provide training to finance and program staff to ensure continued compliance with federal documentation requirements. Views of Responsible Officials: District officials agree with the finding. The District has implemented new procedures in fiscal year 2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel Type of Finding: Material Weakness in Internal Control Over Compliance New or Repeat Finding: New Federal Program: Special Education Cluster (ALNs 84.027, 84.173) Federal Agency: U.S. Department of Education Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406, 225350020849025000, 225360020849025360), Region 10 Education Service Center (236600497110001) Compliance Requirement: B - Allowable Costs / Costs Principles Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective, charges for their salaries must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. One allowable method is through completion of semi-annual certifications signed by the employee or a supervisory official with firsthand knowledge. These certifications provide assurance that salary costs charged to the federal program reflects the total activity for which the employee is compensated by the District, not exceeding 100% of compensated activities. Condition: The district did not maintain required semi-annual certifications for employees who worked solely on the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee worked 100% on the program for the period covered, were missing for all employees. Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed, and retained in accordance with federal requirements. Staff turnover and limited awareness of the documentation rules contributed to the oversight. Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported personnel costs were charged to the program, even if employees were appropriately assigned. Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures that employees worked solely on the program. The personnel records of the employees sampled contained approval of the employee to be hired into the appropriate job duties to be funded by special education cluster grant funds. Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees selected in our sample for testing. Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual certifications are prepared, signed, and retained for all employees working solely on federal programs. The district should provide training to finance and program staff to ensure continued compliance with federal documentation requirements. Views of Responsible Officials: District officials agree with the finding. The District has implemented new procedures in fiscal year 2025 to ensure semi-annual certifications are completed appropriately.
A. Finding on Internal Control over Compliance Finding Reference: 2024-001 Federal Agency: U.S. Dept of Education Federal program: IDEA - Part B, Section 611 (84.027) IDEA- Part B, Section 619 (84.173), Title I, Part A (84.010) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a.) Significant Deficiencies in Internal Control Over Compliance b.) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(l) of the Office of Management and Budget's Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, amoung other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity; d) Encompass both federally assisted and all other actvities compensated by the non-Federal entity; e) Support for the distribution of the employee's salary or wages amount specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: District employees whose time was being charged to the grants, who were working both 100% and less than 100% of the time in the federal award program, were required to complete semi-annual or monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely and not completed by all employees whose time was charged to the gratns. In one instance, an employee's time was charged to the grant that did not work in the gratn. Cause: The School District did not have adequate internal controls in place to ensure that the semi annual or monthly certifications were being completed by each employee working in the federal award programs timely. Effect: Without adequate internal contyrols over the employee's time being charged to the grant and the certification requirement, the School District cannot ensure that the federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Indentification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2023-001. Questioned Costs: The employee's certifications in questions were reviewed and after reviewing the allocation of each employee's time it was determined that the time being charged to the gratn was appropriate. Additionally, for the one employee charged to the grant in error, we reviewed documentation for an employee who workied in the grant but shose time was not charged to the grant and determined that there were no questioned costs. Recommendation: We recommend that the District have propert internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program and completed timely. . Monthly certifications should be completed if less than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Internal controls should also be in place to ensure that only those employees who are working in the grant are being charged to the grant. Management Response: The District agrees with the audit finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan.
A. Finding on Internal Control over Compliance Finding Reference: 2024-001 Federal Agency: U.S. Dept of Education Federal program: IDEA - Part B, Section 611 (84.027) IDEA- Part B, Section 619 (84.173), Title I, Part A (84.010) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a.) Significant Deficiencies in Internal Control Over Compliance b.) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(l) of the Office of Management and Budget's Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, amoung other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity; d) Encompass both federally assisted and all other actvities compensated by the non-Federal entity; e) Support for the distribution of the employee's salary or wages amount specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: District employees whose time was being charged to the grants, who were working both 100% and less than 100% of the time in the federal award program, were required to complete semi-annual or monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely and not completed by all employees whose time was charged to the gratns. In one instance, an employee's time was charged to the grant that did not work in the gratn. Cause: The School District did not have adequate internal controls in place to ensure that the semi annual or monthly certifications were being completed by each employee working in the federal award programs timely. Effect: Without adequate internal contyrols over the employee's time being charged to the grant and the certification requirement, the School District cannot ensure that the federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Indentification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2023-001. Questioned Costs: The employee's certifications in questions were reviewed and after reviewing the allocation of each employee's time it was determined that the time being charged to the gratn was appropriate. Additionally, for the one employee charged to the grant in error, we reviewed documentation for an employee who workied in the grant but shose time was not charged to the grant and determined that there were no questioned costs. Recommendation: We recommend that the District have propert internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program and completed timely. . Monthly certifications should be completed if less than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Internal controls should also be in place to ensure that only those employees who are working in the grant are being charged to the grant. Management Response: The District agrees with the audit finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan.
A. Finding on Internal Control over Compliance Finding Reference: 2024-001 Federal Agency: U.S. Dept of Education Federal program: IDEA - Part B, Section 611 (84.027) IDEA- Part B, Section 619 (84.173), Title I, Part A (84.010) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a.) Significant Deficiencies in Internal Control Over Compliance b.) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(l) of the Office of Management and Budget's Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, amoung other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity; d) Encompass both federally assisted and all other actvities compensated by the non-Federal entity; e) Support for the distribution of the employee's salary or wages amount specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: District employees whose time was being charged to the grants, who were working both 100% and less than 100% of the time in the federal award program, were required to complete semi-annual or monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely and not completed by all employees whose time was charged to the gratns. In one instance, an employee's time was charged to the grant that did not work in the gratn. Cause: The School District did not have adequate internal controls in place to ensure that the semi annual or monthly certifications were being completed by each employee working in the federal award programs timely. Effect: Without adequate internal contyrols over the employee's time being charged to the grant and the certification requirement, the School District cannot ensure that the federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Indentification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2023-001. Questioned Costs: The employee's certifications in questions were reviewed and after reviewing the allocation of each employee's time it was determined that the time being charged to the gratn was appropriate. Additionally, for the one employee charged to the grant in error, we reviewed documentation for an employee who workied in the grant but shose time was not charged to the grant and determined that there were no questioned costs. Recommendation: We recommend that the District have propert internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program and completed timely. . Monthly certifications should be completed if less than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Internal controls should also be in place to ensure that only those employees who are working in the grant are being charged to the grant. Management Response: The District agrees with the audit finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan.
Material Weakness in Internal Controls over Compliance (Allowable Costs/Cost Principles), and Noncompliance with Laws and Regulations. Program Impacted: 84.010 – Title I, Part A. Criteria: 2 CFR 200.430(i) requires that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements identified in this section, these records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and (v) comply with the established accounting policies and practices of the District. Condition: The District did not maintain adequate controls over time and effort reporting to substantiate salaries and wages charged to the Title I, Part A grant. Cause: The District’s oversight of salaries and wages charged to the Title I, Part A grant was insufficient. Effect: The District was unable to support the accuracy of salaries and wages charged to the Title I, Part A grant. Questioned Costs: The District adjusted unsupported charges from the grant via the final request for reimbursement for the fiscal year expenditures. No questioned costs after adjustments. Context: The District utilized Personnel Activity Reports (PARs) for split-funded personnel as the control over salaries and wages charged to the Title I, Part A grant. The PARs identify the employee and total hours spent on grant-funded activities, supporting the rate at which they are to be charged during the specified period. During our review of salaries and wages charged to the grant during the audit period, we noted instances of one individual being charged at rates in excess of those specified on the associated PAR. Recommendation: We recommend that the District adhere to documented time and effort reporting procedures and maintain effective internal controls that ensure salaries and wages are allocated based on records that accurately reflect the work performed. View of Responsible Officials: The District agrees with the finding and will adhere to documented time and effort reporting procedures to ensure that salaries and wages allocated to federal awards are accurate and adequately supported.
Significant Deficiency 2024-004 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) – 93.323 Activities Allowed or Unallowed and Allowable Costs and Cost Principles Criteria or specific requirement In accordance with 2 CFR 200.430, payroll charges should be supported by proper documentation that reflects the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on a Federal award and non-Federal award. In addition, in order to ensure that employees are paid the correct amount and that no conflict of interest may occur, internal controls should be put in place to ensure that all wage rates paid have been approved by the Board. Condition Three employees were paid an additional amount using program funding in order to reflect the administrative burden associated with running the program for three years. For two of the employees, no personnel activity reports or other time records could be provided to support those costs. For the third employee, a monthly log of hours worked on grant activities was provided. However, it only showed the total hours for that month and did not break them out by date of occurrence. Additionally, no supervisor review or other control over that log occurred. Lastly, the employees’ contracts were not amended and approved by the Board to reflect these additional amounts. Context We determined, through testing of program expenditures, that $16,162 was paid in gross wages and taxes for the three employees. Cause District employees do not have a significant amount of experience with large federal programs, and they were not aware of the compliance requirements. Effect Proper records were not maintained to support program expenditures. Recommendation Employees with grant administration responsibilities should undergo training to better their understanding of the compliance requirements that accompany Federal programs. Additionally, controls should be implemented to ensure that all required records are prepared, as well as to ensure that the Board approves all wage rates. Views of responsible officials See corrective action plan.
2024-002 – Significant Deficiency in Internal Control over Major Federal Program and Noncompliance – Documentation of Employee Time and Effort. Career and Technical Education – Basic Grants to the States, ALN # 84.048 and 84.048A, Award Numbers 233480 231400, 233480 231405, 233480 231410 and 243520 24124 Federal Agency: U.S. Department of Education Criteria – Title 2 CFR 200.430 states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications for all employees paid through federal funds. Condition- The School District did not sufficiently document its employees’ actual time spent on federal programs by completing semi-annual certifications or recording their time accurately on their timesheets. Except for the administration, the employees were hired as full-time employees specifically for the Career and Technical Education grant, and although their time was accurately calculated and posted to the grant in their payroll system, the timesheets were not accurate, and the semi-annual certifications were not completed. Incorrect timesheets were noted for six of the twenty-five employees tested and missing semi-annual certification were missing for twenty-five of the twenty-five employees tested. Questioned Costs – None, the employees time was accurately calculated and recorded to the grant in the payroll system. Cause and Effect – The School District’s Career and Technical Education Program Director fell ill during the school year. The Associate Superintendent for Business and Operations stepped up to run the program in addition to her regular duties. The School District did not follow the Board Policy regarding “Time and Effort Reporting”. It appears staffing issues led to a lack of internal controls to identify and correct these errors and ensure complete compliance. Recommendation – We recommend the School District directs personnel to oversee the compliance of the Career and Technical Education grants and can verify employees are completing the “Time and Effort” reporting as required by the grant and the School Districts policy of same – annual certification for all employees paid through federal grants. View of Responsible Officials – The School District agrees with our finding and recommendation. Planned Corrective Actions – See corrective action plan, annexed.
2024-002 – Significant Deficiency in Internal Control over Major Federal Program and Noncompliance – Documentation of Employee Time and Effort. Career and Technical Education – Basic Grants to the States, ALN # 84.048 and 84.048A, Award Numbers 233480 231400, 233480 231405, 233480 231410 and 243520 24124 Federal Agency: U.S. Department of Education Criteria – Title 2 CFR 200.430 states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications for all employees paid through federal funds. Condition- The School District did not sufficiently document its employees’ actual time spent on federal programs by completing semi-annual certifications or recording their time accurately on their timesheets. Except for the administration, the employees were hired as full-time employees specifically for the Career and Technical Education grant, and although their time was accurately calculated and posted to the grant in their payroll system, the timesheets were not accurate, and the semi-annual certifications were not completed. Incorrect timesheets were noted for six of the twenty-five employees tested and missing semi-annual certification were missing for twenty-five of the twenty-five employees tested. Questioned Costs – None, the employees time was accurately calculated and recorded to the grant in the payroll system. Cause and Effect – The School District’s Career and Technical Education Program Director fell ill during the school year. The Associate Superintendent for Business and Operations stepped up to run the program in addition to her regular duties. The School District did not follow the Board Policy regarding “Time and Effort Reporting”. It appears staffing issues led to a lack of internal controls to identify and correct these errors and ensure complete compliance. Recommendation – We recommend the School District directs personnel to oversee the compliance of the Career and Technical Education grants and can verify employees are completing the “Time and Effort” reporting as required by the grant and the School Districts policy of same – annual certification for all employees paid through federal grants. View of Responsible Officials – The School District agrees with our finding and recommendation. Planned Corrective Actions – See corrective action plan, annexed.
2024-002 – Significant Deficiency in Internal Control over Major Federal Program and Noncompliance – Documentation of Employee Time and Effort. Career and Technical Education – Basic Grants to the States, ALN # 84.048 and 84.048A, Award Numbers 233480 231400, 233480 231405, 233480 231410 and 243520 24124 Federal Agency: U.S. Department of Education Criteria – Title 2 CFR 200.430 states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications for all employees paid through federal funds. Condition- The School District did not sufficiently document its employees’ actual time spent on federal programs by completing semi-annual certifications or recording their time accurately on their timesheets. Except for the administration, the employees were hired as full-time employees specifically for the Career and Technical Education grant, and although their time was accurately calculated and posted to the grant in their payroll system, the timesheets were not accurate, and the semi-annual certifications were not completed. Incorrect timesheets were noted for six of the twenty-five employees tested and missing semi-annual certification were missing for twenty-five of the twenty-five employees tested. Questioned Costs – None, the employees time was accurately calculated and recorded to the grant in the payroll system. Cause and Effect – The School District’s Career and Technical Education Program Director fell ill during the school year. The Associate Superintendent for Business and Operations stepped up to run the program in addition to her regular duties. The School District did not follow the Board Policy regarding “Time and Effort Reporting”. It appears staffing issues led to a lack of internal controls to identify and correct these errors and ensure complete compliance. Recommendation – We recommend the School District directs personnel to oversee the compliance of the Career and Technical Education grants and can verify employees are completing the “Time and Effort” reporting as required by the grant and the School Districts policy of same – annual certification for all employees paid through federal grants. View of Responsible Officials – The School District agrees with our finding and recommendation. Planned Corrective Actions – See corrective action plan, annexed.
2024-002 – Significant Deficiency in Internal Control over Major Federal Program and Noncompliance – Documentation of Employee Time and Effort. Career and Technical Education – Basic Grants to the States, ALN # 84.048 and 84.048A, Award Numbers 233480 231400, 233480 231405, 233480 231410 and 243520 24124 Federal Agency: U.S. Department of Education Criteria – Title 2 CFR 200.430 states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications for all employees paid through federal funds. Condition- The School District did not sufficiently document its employees’ actual time spent on federal programs by completing semi-annual certifications or recording their time accurately on their timesheets. Except for the administration, the employees were hired as full-time employees specifically for the Career and Technical Education grant, and although their time was accurately calculated and posted to the grant in their payroll system, the timesheets were not accurate, and the semi-annual certifications were not completed. Incorrect timesheets were noted for six of the twenty-five employees tested and missing semi-annual certification were missing for twenty-five of the twenty-five employees tested. Questioned Costs – None, the employees time was accurately calculated and recorded to the grant in the payroll system. Cause and Effect – The School District’s Career and Technical Education Program Director fell ill during the school year. The Associate Superintendent for Business and Operations stepped up to run the program in addition to her regular duties. The School District did not follow the Board Policy regarding “Time and Effort Reporting”. It appears staffing issues led to a lack of internal controls to identify and correct these errors and ensure complete compliance. Recommendation – We recommend the School District directs personnel to oversee the compliance of the Career and Technical Education grants and can verify employees are completing the “Time and Effort” reporting as required by the grant and the School Districts policy of same – annual certification for all employees paid through federal grants. View of Responsible Officials – The School District agrees with our finding and recommendation. Planned Corrective Actions – See corrective action plan, annexed.
Federal Agency: U.S. Department of Education passed through the State of Alaska, Department of Education and Early Development (DEED) Federal Program(s): COVID-19 CRRSA ACT: ESSER II / ARP ACT: ESSER III (ESSER) and Title I-A Assistance Listing Number(s):84.425 U and D and 84.010A Award Number(s): Federal award numbers: S425U210020, S425D210020 (ESSER), S010A230002, and S010A230002 (Title I-A), Pass through entity award numbers: ER 24.YFSD.01 (ESSER), IP 24.YFSD.01, and SI 24.YFSD.01 (Title I-A). Award Year(s): 2024 Type of Finding: Significant deficiency in internal control over compliance. Criteria: Management is responsible for designing, implementing and maintaining internal controls relevant to ensuring that transactions charged to programs follow proper internal control processes (2 CFR Part 200 Subpart E § 200.400 (d)). Further, Uniform Guidance Requirements, which also apply to expenditures of ESSER funds, dictate the funding recipient is required to follow document personnel costs in accordance with 2 CFR Section 200.430 (i). The District is required to maintain time distribution records for employees funded under Federal Programs. Condition and Context: We tested a sample of fifteen (15) payroll transactions for ESSER and seven (7) payroll transactions for Title I-A. We were unable to verify the funding allocation for eleven (11) transactions for the ESSER funding and four (4) transactions for the Title I-A funding. The payroll expenditures charged to these programs were recorded using journal entries and lacked documentation of time and effort. The employee positions were not considered unallowable under the programs. Cause: Lack of internal controls over payroll expenditure allocation. Effect: The lack of supporting documentation indicating the payroll expenditure allocation allows for the potential of payroll expenditures to be incorrectly charge to unallowable funding sources. Repeat Finding: This is not a repeat finding, however, due to the number of exceptions identified, we believe this to be a systemic issue. Questioned Costs: None reported. Recommendation: We recommend that management ensures employee personnel action forms are updated to reflect the correct fund allocations for payroll costs to ensure employees time is appropriately coded. Additionally, if charged to federal grant sources that time and effort be adequately tracked and documented. Management Response: Management agrees with this finding, see Corrective Action Plan.
Federal Agency: U.S. Department of Education passed through the State of Alaska, Department of Education and Early Development (DEED) Federal Program(s): COVID-19 CRRSA ACT: ESSER II / ARP ACT: ESSER III (ESSER) and Title I-A Assistance Listing Number(s):84.425 U and D and 84.010A Award Number(s): Federal award numbers: S425U210020, S425D210020 (ESSER), S010A230002, and S010A230002 (Title I-A), Pass through entity award numbers: ER 24.YFSD.01 (ESSER), IP 24.YFSD.01, and SI 24.YFSD.01 (Title I-A). Award Year(s): 2024 Type of Finding: Significant deficiency in internal control over compliance. Criteria: Management is responsible for designing, implementing and maintaining internal controls relevant to ensuring that transactions charged to programs follow proper internal control processes (2 CFR Part 200 Subpart E § 200.400 (d)). Further, Uniform Guidance Requirements, which also apply to expenditures of ESSER funds, dictate the funding recipient is required to follow document personnel costs in accordance with 2 CFR Section 200.430 (i). The District is required to maintain time distribution records for employees funded under Federal Programs. Condition and Context: We tested a sample of fifteen (15) payroll transactions for ESSER and seven (7) payroll transactions for Title I-A. We were unable to verify the funding allocation for eleven (11) transactions for the ESSER funding and four (4) transactions for the Title I-A funding. The payroll expenditures charged to these programs were recorded using journal entries and lacked documentation of time and effort. The employee positions were not considered unallowable under the programs. Cause: Lack of internal controls over payroll expenditure allocation. Effect: The lack of supporting documentation indicating the payroll expenditure allocation allows for the potential of payroll expenditures to be incorrectly charge to unallowable funding sources. Repeat Finding: This is not a repeat finding, however, due to the number of exceptions identified, we believe this to be a systemic issue. Questioned Costs: None reported. Recommendation: We recommend that management ensures employee personnel action forms are updated to reflect the correct fund allocations for payroll costs to ensure employees time is appropriately coded. Additionally, if charged to federal grant sources that time and effort be adequately tracked and documented. Management Response: Management agrees with this finding, see Corrective Action Plan.
Federal Agency: U.S. Department of Education passed through the State of Alaska, Department of Education and Early Development (DEED) Federal Program(s): COVID-19 CRRSA ACT: ESSER II / ARP ACT: ESSER III (ESSER) and Title I-A Assistance Listing Number(s):84.425 U and D and 84.010A Award Number(s): Federal award numbers: S425U210020, S425D210020 (ESSER), S010A230002, and S010A230002 (Title I-A), Pass through entity award numbers: ER 24.YFSD.01 (ESSER), IP 24.YFSD.01, and SI 24.YFSD.01 (Title I-A). Award Year(s): 2024 Type of Finding: Significant deficiency in internal control over compliance. Criteria: Management is responsible for designing, implementing and maintaining internal controls relevant to ensuring that transactions charged to programs follow proper internal control processes (2 CFR Part 200 Subpart E § 200.400 (d)). Further, Uniform Guidance Requirements, which also apply to expenditures of ESSER funds, dictate the funding recipient is required to follow document personnel costs in accordance with 2 CFR Section 200.430 (i). The District is required to maintain time distribution records for employees funded under Federal Programs. Condition and Context: We tested a sample of fifteen (15) payroll transactions for ESSER and seven (7) payroll transactions for Title I-A. We were unable to verify the funding allocation for eleven (11) transactions for the ESSER funding and four (4) transactions for the Title I-A funding. The payroll expenditures charged to these programs were recorded using journal entries and lacked documentation of time and effort. The employee positions were not considered unallowable under the programs. Cause: Lack of internal controls over payroll expenditure allocation. Effect: The lack of supporting documentation indicating the payroll expenditure allocation allows for the potential of payroll expenditures to be incorrectly charge to unallowable funding sources. Repeat Finding: This is not a repeat finding, however, due to the number of exceptions identified, we believe this to be a systemic issue. Questioned Costs: None reported. Recommendation: We recommend that management ensures employee personnel action forms are updated to reflect the correct fund allocations for payroll costs to ensure employees time is appropriately coded. Additionally, if charged to federal grant sources that time and effort be adequately tracked and documented. Management Response: Management agrees with this finding, see Corrective Action Plan.
Federal Agency: U.S. Department of Education passed through the State of Alaska, Department of Education and Early Development (DEED) Federal Program(s): COVID-19 CRRSA ACT: ESSER II / ARP ACT: ESSER III (ESSER) and Title I-A Assistance Listing Number(s):84.425 U and D and 84.010A Award Number(s): Federal award numbers: S425U210020, S425D210020 (ESSER), S010A230002, and S010A230002 (Title I-A), Pass through entity award numbers: ER 24.YFSD.01 (ESSER), IP 24.YFSD.01, and SI 24.YFSD.01 (Title I-A). Award Year(s): 2024 Type of Finding: Significant deficiency in internal control over compliance. Criteria: Management is responsible for designing, implementing and maintaining internal controls relevant to ensuring that transactions charged to programs follow proper internal control processes (2 CFR Part 200 Subpart E § 200.400 (d)). Further, Uniform Guidance Requirements, which also apply to expenditures of ESSER funds, dictate the funding recipient is required to follow document personnel costs in accordance with 2 CFR Section 200.430 (i). The District is required to maintain time distribution records for employees funded under Federal Programs. Condition and Context: We tested a sample of fifteen (15) payroll transactions for ESSER and seven (7) payroll transactions for Title I-A. We were unable to verify the funding allocation for eleven (11) transactions for the ESSER funding and four (4) transactions for the Title I-A funding. The payroll expenditures charged to these programs were recorded using journal entries and lacked documentation of time and effort. The employee positions were not considered unallowable under the programs. Cause: Lack of internal controls over payroll expenditure allocation. Effect: The lack of supporting documentation indicating the payroll expenditure allocation allows for the potential of payroll expenditures to be incorrectly charge to unallowable funding sources. Repeat Finding: This is not a repeat finding, however, due to the number of exceptions identified, we believe this to be a systemic issue. Questioned Costs: None reported. Recommendation: We recommend that management ensures employee personnel action forms are updated to reflect the correct fund allocations for payroll costs to ensure employees time is appropriately coded. Additionally, if charged to federal grant sources that time and effort be adequately tracked and documented. Management Response: Management agrees with this finding, see Corrective Action Plan.
Federal Agency U.S. Department of Education Federal Program Name Higher Educational Institutional Aid Assistance Listing Number 84.031X Federal Award Identification Number and Year " P031X220005 - 2024, P031X200005 - 2024, P031X230006 - 2024" Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Allowable Costs and Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should 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. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not have proper documentation of Time and Effort reporting. Questioned costs: N/A Known Likely Context During our testing of 40 Payroll transactions, we identified 8 time and effort reports that were not documented properly to track hours worked on federal grant and 12 reports that did not have a documentation of review. Additionally during our testing of 5 key personnel with Level of Effort provisions in the grant award notification, we identified 1 key personnel did not have documentation to track hours for level of effort required by the Federal agency. Cause The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect The College could potentially expense incorrect amount to federal grants. Repeat Finding No Recommendation "We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. " Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Higher Educational Institutional Aid Assistance Listing Number 84.031X Federal Award Identification Number and Year " P031X220005 - 2024, P031X200005 - 2024, P031X230006 - 2024" Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Allowable Costs and Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should 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. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not have proper documentation of Time and Effort reporting. Questioned costs: N/A Known Likely Context During our testing of 40 Payroll transactions, we identified 8 time and effort reports that were not documented properly to track hours worked on federal grant and 12 reports that did not have a documentation of review. Additionally during our testing of 5 key personnel with Level of Effort provisions in the grant award notification, we identified 1 key personnel did not have documentation to track hours for level of effort required by the Federal agency. Cause The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect The College could potentially expense incorrect amount to federal grants. Repeat Finding No Recommendation "We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. " Views of Responsible Officials Management agrees with this finding.
Federal Agency U.S. Department of Education Federal Program Name Higher Educational Institutional Aid Assistance Listing Number 84.031X Federal Award Identification Number and Year " P031X220005 - 2024, P031X200005 - 2024, P031X230006 - 2024" Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/23 - 6/30/24 Compliance Requirement Affected Allowable Costs and Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure. Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should 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. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The College did not have proper documentation of Time and Effort reporting. Questioned costs: N/A Known Likely Context During our testing of 40 Payroll transactions, we identified 8 time and effort reports that were not documented properly to track hours worked on federal grant and 12 reports that did not have a documentation of review. Additionally during our testing of 5 key personnel with Level of Effort provisions in the grant award notification, we identified 1 key personnel did not have documentation to track hours for level of effort required by the Federal agency. Cause The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect The College could potentially expense incorrect amount to federal grants. Repeat Finding No Recommendation "We recommend the College review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. " Views of Responsible Officials Management agrees with this finding.
Federal Agency US Department of Education Federal Program Name Higher Education Institutional Aid Assistance Listing Number 84.031S Federal Award Identification Number and Year P031S200249 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Allowable Costs and Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material known questioned costs-therefore we will document as a SD. Additionally the client provided narrative response documents that the project directors complete, but do not quantify actual hours charged to the grant. based on expenditure of grant funds and activities in narrative responses and performance reports the grant work is being adequately completed, but the quantified hour tracking is not present. As such, based on these factors we will consider this to be a significant deficiency. Compliance Not Material Document judgment for your assessment See line 28 for more detailed response Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should 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. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements." Condition The University did not have proper documentation of Time and Effort reporting. Questioned costs: N/A Known 12,965.60 Likely 333907.5 Context During our testing of 40 Payroll transactions, we identified 38 time and effort reports that were not documented properly to track hours worked on federal grant and did not have a documentation of review. Additionally during our testing of 1 key personnel with Level of Effort provisions in the grant award notification, we identified the key personnel did not have documentation to track hours for level of effort required by the Federal agency. Cause The University did not have proper procedures in place to track time and effort for personnel on federal grants. Effect The University could potentially expense incorrect amount to federal grants. Repeat Finding No Recommendation We recommend the University review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. Views of Responsible Officials Agree
Finding Number 2024-007 Education Stabilization Fund: American Rescue Plan - Elementary and Secondary School Emergency Relief (ESSER III) Assistance Listing Number 84.425U Allowable Costs/Cost Principles – Documentation of Employee Salary and Wage Rate Immaterial Noncompliance Criteria: Per Federal regulations 2 CFR section 200.430(i)(1)(vii), the School District must maintain time and effort distribution records for an employee who works in part on the consolidated administrative cost objective and in part on a federal program whose administrative funds have not been consolidated or on activities funded from other revenue sources. Condition: At the time of our testing, the School District did not maintain salary and wage approval agreement records for employees who were funded with ESSER Federal funds. Cause: Oversight. Effect: Time and effort reports were not completed. Questioned Costs: None. Recommendation: Salary and wage approval agreements should be completed throughout the year listing the employees name, position or job title, and salary rate signed by the employee’s supervisor. Management's Response and Corrective Actions: The Director of Finance completed salary and wage approval agreement records for the ESSER funds expended for fiscal year ending June 30, 2024 during audit fieldwork. Management has assigned the Director of Finance with the task of completing the required reports in a timely manner. The Superintendent will provide oversight of this requirement. Person Responsible for Corrective Action: Danielle Banasiak, Director of Finance, and Amiee Erfourth, Superintendent Completion Date: November 15, 2024
Criteria: Title I Schoolwide Programs (SWP) should always consider the following general criteria when approving activities or expenditures supported with Title I, Part A funds: • The activity and/or expenditure meets a need identified in the comprehensive needs assessment (ESSA Section 1114(b)(6); • The activity and/or expenditure is included in the approved Single Plan for Student Achievement (SPSA) (Education Code Section 64001(g)(C)(3); • The activity and/or expenditure has been reviewed, approved, and recommended by the School Site Council to the local governing board (Education Code Section 64001(d). Condition: Expenditure of Title I funds were not consistent with the SPSA templates. Questioned Cost: None. We determined that Title I, Part A funds were spent on student related services, and support teachers, whose payroll charges allocated to the Title I, Part A program were supported by time and effort distribution records in accordance with 2 CFR 200.430(i)(1)(vii). Context: The condition was noted at Wilson Elementary and Gridley High School. Effect: The District did not comply with Federal and State requirements related to Title I Schoolwide Programs. Cause: The District did not review the proposed expenditures of Title I funds to ensure that the expenditures were consistent with the budgets in the SPSA templates. Recommendation: The District should ensure that all proposed expenditures from Title I funds are consistent with the budgets in each school’s SPSA template prior to expenditure. District Response: Annually, the Director of Curriculum and Technology in capacity of accountability coordinator shall review all school site SPSAs prior to their final adoption by the governing board of the district and facilitate communication between school site principals and the business office to ensure congruence of the planned budget documents for the District and the SPSA documents for each school site. Should discrepancies be found, the Director shall facilitate with the site principals and the business office the needed corrections to bring the documents into agreement. Director shall also conduct as-needed training with site principals about SPSA components and their appropriate completion.
FAL No. and Name: 84.425U COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSER) 84.425W COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief - Homeless Children and Youth Award Number: 21FESIII-110236-01A 22FARHOI-210236-01A 22FAHIIE-210236-01A Federal Agency: Arizona Department of Education Compliance Requirement: Allowable Costs Questioned Costs: None Criteria: In accordance with 2 CFR §200.430(i)(1)(i), the School should have a system of internal control that provides reasonable assurance that employee compensation rates are accurate and properly verified. Condition and context: Two out of twenty-five employees tested were found to have been paid at a rate lower than what was documented in their personnel file. Cause: There appears to be insufficient review and verification procedures within the payroll processing system. Effect: This deficiency increases the risk of discrepancies in employee compensation, potentially leading to both overpayments and underpayments. Recommendation: To help ensure employees receive accurate compensation, the School should implement internal control procedures that include thorough verification of payroll data against authorized pay rates before payroll is processed. Management's Corrective Action Plan is included at the end of this report.
FAL No. and Name: 84.425U COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSER) 84.425W COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief - Homeless Children and Youth Award Number: 21FESIII-110236-01A 22FARHOI-210236-01A 22FAHIIE-210236-01A Federal Agency: Arizona Department of Education Compliance Requirement: Allowable Costs Questioned Costs: None Criteria: In accordance with 2 CFR §200.430(i)(1)(i), the School should have a system of internal control that provides reasonable assurance that employee compensation rates are accurate and properly verified. Condition and context: Two out of twenty-five employees tested were found to have been paid at a rate lower than what was documented in their personnel file. Cause: There appears to be insufficient review and verification procedures within the payroll processing system. Effect: This deficiency increases the risk of discrepancies in employee compensation, potentially leading to both overpayments and underpayments. Recommendation: To help ensure employees receive accurate compensation, the School should implement internal control procedures that include thorough verification of payroll data against authorized pay rates before payroll is processed. Management's Corrective Action Plan is included at the end of this report.
Federal Award Finding 2024-001 US Department of Justice Crime Victims Assistance AL No. 16.575 Pass-Through Grantor New Hampshire Coalition Against Domestic and Sexual Violence Questioned costs – $0 Criteria – 2 CFR section 200.430 requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records should be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable and properly allocated. Condition – Our testing included sampling 40 timesheets and verifying that the time booked to the grants was properly supported by the approved time sheets. In 5 instances the actual amount charged to the grants deviated from the amount deemed chargeable to the grant per the time sheet. The actual time allocated to the grants was concluded as allowable thus there are no questioned costs. The sample was not intended to be, and was not, a statistically valid sample. Cause – The cause of the discrepancies is due to reallocating time after the timesheets are completed or the use of an incorrect timesheet. Effects or Potential Effects – The effect or potential effect is the lack of proper documentation to support that HAVEN has established a system of internal control that evidences that time charged to the grant was appropriately reviewed for accuracy and allowability. Auditor’s Recommendation – We recommend that time sheets comprehensively detail the employee’s program-related activities, which should then be accurately reflected in the grant allocations. If circumstances require re-allocation of an employee’s time the changes and the reason for the changes should be documented sufficiently to demonstrate the change was properly supported, reviewed and allowable. View of Responsible Officials – HAVEN agrees with the finding and the Office Manager will review all time sheets and document any required changes to support the payroll charged to the grants.
FINDING #2024-002: FEDERAL COMPLIANCE – TIME AND EFFORT REPORTING (50000) AL Number and Title: 84.027 – IDEA Basic Local Assistance Entitlement, Part B, Sec. 611 Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Federal regulation 2 CFR §200.430 states that “charges to federal awards for salaries and wages must comply with the established accounting policies and practices of the non-federal entity and budget estimates determined before the services are performed alone do not qualify as support for charges to federal awards.” Standards for documentation of personnel expenses charged to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; • Be incorporated into the official records of the non‐Federal entity. • Reasonably reflect the total activity for which the employee is compensated by the non‐Federal entity, not exceeding 100% of compensated activities. • 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; • Comply with the established accounting policies and practices of the non‐Federal entity. • 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. • 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. Condition: Auditors selected a representative sample of 21 employees with salaries and benefits charged to the federal program noted above during the 2023-2024 fiscal year. Based on our audit procedures, we were unable to confirm that timely review and approval of employees charged to federal programs had been properly documented. As a result, we could not confirm that the criteria for personnel expenses charged to federal awards had been met. Effect: The District is not in compliance with 2 CFR §200.430. Cause: Administrative oversight. Questioned Cost: None. Although the District was not in compliance, we did not note any questionable or potentially unallowable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District implement control procedures that meet the requirements outlined above and properly document the timely review and approval of employees charged to federal programs. This can be accomplished through the timely preparation of semi-annual certifications for single-funded employees and monthly certifications for multi-funded employees. Corrective Action Plan: The Views of Responsible Officials and Corrective Action Plan are included on page 85.
FINDING #2024-002: FEDERAL COMPLIANCE – TIME AND EFFORT REPORTING (50000) AL Number and Title: 84.027 – IDEA Basic Local Assistance Entitlement, Part B, Sec. 611 Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Federal regulation 2 CFR §200.430 states that “charges to federal awards for salaries and wages must comply with the established accounting policies and practices of the non-federal entity and budget estimates determined before the services are performed alone do not qualify as support for charges to federal awards.” Standards for documentation of personnel expenses charged to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; • Be incorporated into the official records of the non‐Federal entity. • Reasonably reflect the total activity for which the employee is compensated by the non‐Federal entity, not exceeding 100% of compensated activities. • 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; • Comply with the established accounting policies and practices of the non‐Federal entity. • 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. • 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. Condition: Auditors selected a representative sample of 21 employees with salaries and benefits charged to the federal program noted above during the 2023-2024 fiscal year. Based on our audit procedures, we were unable to confirm that timely review and approval of employees charged to federal programs had been properly documented. As a result, we could not confirm that the criteria for personnel expenses charged to federal awards had been met. Effect: The District is not in compliance with 2 CFR §200.430. Cause: Administrative oversight. Questioned Cost: None. Although the District was not in compliance, we did not note any questionable or potentially unallowable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District implement control procedures that meet the requirements outlined above and properly document the timely review and approval of employees charged to federal programs. This can be accomplished through the timely preparation of semi-annual certifications for single-funded employees and monthly certifications for multi-funded employees. Corrective Action Plan: The Views of Responsible Officials and Corrective Action Plan are included on page 85.
FINDING #2024-002: FEDERAL COMPLIANCE – TIME AND EFFORT REPORTING (50000) AL Number and Title: 84.027 – IDEA Basic Local Assistance Entitlement, Part B, Sec. 611 Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Federal regulation 2 CFR §200.430 states that “charges to federal awards for salaries and wages must comply with the established accounting policies and practices of the non-federal entity and budget estimates determined before the services are performed alone do not qualify as support for charges to federal awards.” Standards for documentation of personnel expenses charged to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; • Be incorporated into the official records of the non‐Federal entity. • Reasonably reflect the total activity for which the employee is compensated by the non‐Federal entity, not exceeding 100% of compensated activities. • 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; • Comply with the established accounting policies and practices of the non‐Federal entity. • 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. • 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. Condition: Auditors selected a representative sample of 21 employees with salaries and benefits charged to the federal program noted above during the 2023-2024 fiscal year. Based on our audit procedures, we were unable to confirm that timely review and approval of employees charged to federal programs had been properly documented. As a result, we could not confirm that the criteria for personnel expenses charged to federal awards had been met. Effect: The District is not in compliance with 2 CFR §200.430. Cause: Administrative oversight. Questioned Cost: None. Although the District was not in compliance, we did not note any questionable or potentially unallowable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District implement control procedures that meet the requirements outlined above and properly document the timely review and approval of employees charged to federal programs. This can be accomplished through the timely preparation of semi-annual certifications for single-funded employees and monthly certifications for multi-funded employees. Corrective Action Plan: The Views of Responsible Officials and Corrective Action Plan are included on page 85.
FINDING #2024-002: FEDERAL COMPLIANCE – TIME AND EFFORT REPORTING (50000) AL Number and Title: 84.027 – IDEA Basic Local Assistance Entitlement, Part B, Sec. 611 Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Federal regulation 2 CFR §200.430 states that “charges to federal awards for salaries and wages must comply with the established accounting policies and practices of the non-federal entity and budget estimates determined before the services are performed alone do not qualify as support for charges to federal awards.” Standards for documentation of personnel expenses charged to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; • Be incorporated into the official records of the non‐Federal entity. • Reasonably reflect the total activity for which the employee is compensated by the non‐Federal entity, not exceeding 100% of compensated activities. • 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; • Comply with the established accounting policies and practices of the non‐Federal entity. • 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. • 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. Condition: Auditors selected a representative sample of 21 employees with salaries and benefits charged to the federal program noted above during the 2023-2024 fiscal year. Based on our audit procedures, we were unable to confirm that timely review and approval of employees charged to federal programs had been properly documented. As a result, we could not confirm that the criteria for personnel expenses charged to federal awards had been met. Effect: The District is not in compliance with 2 CFR §200.430. Cause: Administrative oversight. Questioned Cost: None. Although the District was not in compliance, we did not note any questionable or potentially unallowable costs. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District implement control procedures that meet the requirements outlined above and properly document the timely review and approval of employees charged to federal programs. This can be accomplished through the timely preparation of semi-annual certifications for single-funded employees and monthly certifications for multi-funded employees. Corrective Action Plan: The Views of Responsible Officials and Corrective Action Plan are included on page 85.
2024-002 Internal Control over Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Payroll Activities Identification of the Federal Program: Federal Agency: United States Housing & Urban Development Program Name: Community Development Block Grant - Disaster Recovery Whole Community Resilience Planning Program Assistance Listing Number: 14.228 Award Number: B-17-DM-72-0001 Passthrough Entity: Government of Puerto Rico Department of Housing Pass-Through Entity Identifying Number: FFNMUBT6WCM1 Sub-award Period: 1/30/2023-9/30/2024 Criteria - The Code of Federal Regulations 2 CFR 200.303, Internal Control, requires the non-federal entity to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the non-federal entity is managing Federal awards in compliance with Federal statutes, regulations, and other terms and conditions. Per 2 CFR Section 200.430 Compensation – Personal Services: “Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.” 2 CFR Section 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; (vi) [Reserved] (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.” Condition – During the audit, we noted that the Trust has a system of internal control in whichemployees who charge time to the Federal programs, are required to complete a timeslip and have their Timeslips reports reviewed and approved by the employees’ supervisors on a monthly basis. During our testing, we noted that five out of seven employees selected for testing charged time to the Federal program between July 1, 2023 and April 30, 2024, but the timeslips reports were not reviewed and approved by their supervisors until June 2024. There was a lack of timely approval of hours charged to the federal program by the supervisors. However, we validated that the employees who charged time to the federal awards as part of our sample selection were included in the budgets for the federal programs. Cause – The Trust did not follow its documented policies and procedures in place to ensure compliance with the requirements regarding activities allowed or unallowed and allowable costs/cost principles – payroll activities. Effect or Potential Effect - Without timely approvals that the personnel costs charged are accurate, the Trust is not able to demonstrate that key elements in a system of internal control over the recording of time exists. Questioned Costs - None. Context - This is a condition identified based upon our review of the Trust’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these findings is detailed in the condition section above. Repeat finding - This is not a repeat finding. Recommendation - We recommend that the Trust strengthen its current policies and procedures to ensure that payroll costs charged to federal awards are supported by a system of internal controls that allows for timely employee preparation, certification, and supervisory approval of time charged to the federal awards. Views of Responsible Officials – Time charged to this program had to be captured both as part of the billing process to the Federal funder, United States Housing and Urban Development (HUD) and through Timeslips system as required by internal policy. Time entries were downloaded from the Timeslips system and formatted for approvals using a time certification form template as required and approved by HUD. Billing to HUD occurs monthly. However, there were significant delays by HUD in reviewing and approving monthly invoices along with frequent changes to the requested documentation needed to substantiate costs. Although internal Timeslips reports were available for review and approval on a monthly basis, the program manager’s approvals were only documented on the time certification form as required by HUD. As a result, evidence of timely approvals on a monthly basis were not available as internal policy states. Procedures will be enforced to ensure that program managers are documenting approvals for hours charged to all federal awards according to both federal and internal policies as required on a monthly basis.
Findings and Questioned Costs – Major Federal Award Programs Audit Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.010 Title I Grants to Local Educational Agencies Compliance Requirement: B. Allowable Costs Criteria: Per 2 CFR 200.430(g)(1)(i), the District is required to have records that are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The District uses semi-annual certifications to determine if the salaries and/or employee benefits of its employees are allowable for the grant. These certifications are to be signed after each semi-annual period by the teacher and the Title I program director. These certifications show that the teachers’ time was spent under the Title I program, and their salaries and benefits are allowable for the Title I program. Condition: During the course of our audit, we reviewed semi-annual certifications for all Title I teachers, as required. These certifications are used to verify that the employee spent one hundred percent of their time working in the Title I program. Per requirements, these certifications should be signed at the end of the applicable period as that is when the actual time spent in the program is known. However, during our review, we noted that all the certifications were signed at the beginning of the applicable semi-annual period. Cause: There is a lack of oversight in this area. Supervisors should ensure the teachers complete the semi-annual certifications in a timely manner after the end of each semi-annual period. Also, program directors should be reviewing the signed certifications to ensure all program requirements are followed to avoid any noncompliance issues and consequences. Effect: Semi-annual certifications are listed under the Allowable Costs/Cost Principles compliance requirement. In order to apply expenditures to the Title I Program, the employees need to certify that they are spending all of their time on that program. Without this certification, it is not clear that the amounts reported as Title I expenditures are indeed eligible expenditures. Questioned Costs: No questioned costs noted. Perspective Information: This appears to be a systemic problem since all Title I semi-annual certifications for the fiscal year 2024 were reviewed and all certifications were filled out at the beginning of each semi-annual period instead of subsequent to the period. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District employ stronger oversight in this area by assigning a review to the Title Program Director or equivalent. Once the certifications are signed by a supervisor, they should be forwarded to this point person for their review and signature. The certifications should be reviewed to ensure each Title teacher is completing a semi-annual certification and that it is being signed by the supervisor. These certifications should also have a due date twice a year to ensure they are done timely and are not overlooked. These should be added to the review checklist already used for Title I reporting. Views of Responsible Officials: The District will set up automated reminders through the internal tracking system with specific deadlines to ensure that all certifications are completed and signed no later than 30 business days after the end of the applicable periods. Regular checks will be conducted by the Title 1 Coordinator to verify that all certifications are completed and signed within the required timeframes. All relevant staff members will undergo training on the new procedures, and will be assigned roles and responsibilities for monitoring and submitting the certifications. See Corrective Action Plan.
2024-003 Allowable Costs Federal agency: U.S Department of Education & Department of Health and Human Services Federal program title: Career and Technical Education - Basic Grant to States & Child Care and Development Block Grant Assistant Listing Number: 84.048 & 93.575 Federal Award Identification Number: V048A220030-2024 and 2101ILccc5-2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.430(g)(1) states charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not have proper documentation of Time and Effort reporting. Context: During our testing, we identified that time and effort reports were not documented properly to track hours worked on federal grant and did not have documentation of formal review. Questioned costs: None. Cause: The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect: The College could potentially expense incorrect amount to federal grants. Repeat Finding: No. Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Views of responsible officials: Management agrees with the finding.
2024-003 Allowable Costs Federal agency: U.S Department of Education & Department of Health and Human Services Federal program title: Career and Technical Education - Basic Grant to States & Child Care and Development Block Grant Assistant Listing Number: 84.048 & 93.575 Federal Award Identification Number: V048A220030-2024 and 2101ILccc5-2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.430(g)(1) states charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not have proper documentation of Time and Effort reporting. Context: During our testing, we identified that time and effort reports were not documented properly to track hours worked on federal grant and did not have documentation of formal review. Questioned costs: None. Cause: The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect: The College could potentially expense incorrect amount to federal grants. Repeat Finding: No. Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Views of responsible officials: Management agrees with the finding.
Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Criteria: In accordance with 2 CFR section 200.430, the local education agency is required to maintain time and effort distribution records for employees who work on federal programs. These distribution records must support the portion of time and effort dedicated to: 1) The federal program or cost objective; and 2) Other programs or cost objectives supported by federal funds or other revenue sources. Statement of Condition: The District was not in compliance with the Uniform Guidance as it was noted that management of the District was not preparing time and effort distribution records and could not produce source documentation to support the time and effort applied to payroll expense that was charged to Title I Grants to Local Education Agencies. Cause: The District’s internal controls to identify and document employees that require support for time and effort charged to Title I Grants to Local Education Agencies were not effective for the year ended June 30, 2024. Context: We selected payroll costs associated with nine employees who had wages charged to Title I Grants to Local Education Agencies. Of the nine employees selected for testing, two employees did not have time and effort documentation or other source documentation to support the payroll expense that was charged to the federal program. Effect or Potential Effect: Salary and wage costs could be applied to Title I Grants to Local Education Agencies without appropriate supporting documentation required in accordance with 2 CFR Part 200.430 and District Policy. Questioned Costs: $26,366 of known questioned costs charged to this federal program in the year under audit. Recommendations: We recommend the District review their internal controls to strengthen processes and improve procedures. We recommend the District complete all required time and effort certifications in a timely manner. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and recommendation and plans to implement a system of completing necessary time and effort documentation for all employees who work on federal programs.
Finding Type: Material Noncompliance; Material Weakness in Internal Control over Compliance Criteria: In accordance with 2 CFR section 200.430, the local education agency is required to maintain time and effort distribution records for employees who work on federal programs. These distribution records must support the portion of time and effort dedicated to: 1) The federal program or cost objective; and 2) Other programs or cost objectives supported by federal funds or other revenue sources. Statement of Condition: The District was not in compliance with the Uniform Guidance as it was noted that management of the District was not preparing time and effort distribution records and could not produce source documentation to support the time and effort applied to payroll expense that was charged to Title I Grants to Local Education Agencies. Cause: The District’s internal controls to identify and document employees that require support for time and effort charged to Title I Grants to Local Education Agencies were not effective for the year ended June 30, 2024. Context: We selected payroll costs associated with nine employees who had wages charged to Title I Grants to Local Education Agencies. Of the nine employees selected for testing, two employees did not have time and effort documentation or other source documentation to support the payroll expense that was charged to the federal program. Effect or Potential Effect: Salary and wage costs could be applied to Title I Grants to Local Education Agencies without appropriate supporting documentation required in accordance with 2 CFR Part 200.430 and District Policy. Questioned Costs: $26,366 of known questioned costs charged to this federal program in the year under audit. Recommendations: We recommend the District review their internal controls to strengthen processes and improve procedures. We recommend the District complete all required time and effort certifications in a timely manner. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding and recommendation and plans to implement a system of completing necessary time and effort documentation for all employees who work on federal programs.
Federal Agency: U.S. Department of Education Federal Program Name: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010 Federal Award Identification Numbers and Year: S010A230020 and S010A220020 Pass-Through Agency: Maryland Department of Education (MSDE) Pass-Through Number(s): 241282-01 231095-01 Award Period: 7/1/2022–9/30/2024 7/1/2023–9/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (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; (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. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the 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). Condition/Context: For one of forty timesheets selected for testing, the Board was unable to provide documentation to substantiate that the time and effort was dedicated to the federal program. The Board did not have effective controls in place for monitoring and obtaining adequate support to validate actual payroll expenses charged to the federal program. Questioned costs: $3,415 Cause: Controls were not operating effectively to ensure that time and effort reporting was performed and documented in a timely manner, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Repeat Finding: No. Recommendation: We recommend that the Board reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Board should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010 Federal Award Identification Numbers and Year: S010A230020 and S010A220020 Pass-Through Agency: Maryland Department of Education (MSDE) Pass-Through Number(s): 241282-01 231095-01 Award Period: 7/1/2022–9/30/2024 7/1/2023–9/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (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; (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. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the 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). Condition/Context: For one of forty timesheets selected for testing, the Board was unable to provide documentation to substantiate that the time and effort was dedicated to the federal program. The Board did not have effective controls in place for monitoring and obtaining adequate support to validate actual payroll expenses charged to the federal program. Questioned costs: $3,415 Cause: Controls were not operating effectively to ensure that time and effort reporting was performed and documented in a timely manner, in accordance with federal requirements. Effect: There is an increased risk of charging unallowed payroll costs to the program. Repeat Finding: No. Recommendation: We recommend that the Board reevaluate its current process, implement proper controls, and perform additional training over time and effort reporting. The Board should not seek federal reimbursement unless it can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Views of responsible officials: There is no disagreement with the audit finding.