Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-001: Activities Allowed or Unallowed Research and Development Cluster Award Period: July 1, 2023 – June 30, 2024 Criteria: In accordance with 2 CFR 200.430(g), as it relates to time and effort reporting, 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; be incorporated into the official records of the recipient or subrecipient; and support the distribution of the employee’s salary or wages among specific activities or cost objectives. Condition: Time and effort reporting for full time employees of the College whose labor costs were charged to certain research and development grants did not occur consistently during the fiscal year under audit. Cause: For a portion of the year under audit, there was a lack of full staffing in certain positions within the College’s Office of Grants and Sponsored Research (OGSR), which prevented the required level of detail and consistently around time and effort reporting. Effect: Due to short staffing within the OGSR department, time and effort reporting was not conducted on a timely and consistent basis for all individuals working on research and development grants during the period and the College was therefore not meeting the requirements established in the OMB Uniform Guidance. Questioned Costs: None. Context: The College uses effort reporting to meet its requirements under 2CFR 200.403. Effort reporting is a process to verify that labor charged as direct costs to sponsored awards is accurate, timely, and reflects the actual level or work performed. The College’s Effort Verification Operating Policy, states “For salaried employees and faculty who work on sponsored projects, TCNJ’s verification of effort (and payroll changes) is documented through the periodic preparation and review of Effort Verification Forms (EVFs).” As part of our testing procedures, we selected 40 salary transactions directly charged to awards (comprised of both salaried employees and faculty), of which 10 had no effort verification form certified for any of the transactions during the fiscal year under audit. Repeat Finding: No. Recommendation: Management should follow the applicable guidance as well as the College’s Effort Verification Operating Policy to complete accurate and consistent time and effort reporting on sponsored research grants. Views of Responsible Officials and Planned Corrective Action: For the fiscal year ending June 30, 2024, the College had 7 employees with a combined total of 10 payroll instances with no effort verification form certified for any of the transactions during the fiscal year. The effort was certified after the fiscal year, as part of the year-end process rather than semi-annually which has been the practice in past years following guidance in Effort Verification Operating Policy. The College recognizes the importance of ensuring that labor costs charged to federal awards are based on accurate and timely records and certifications, as required under 2 CFR 200.430(g). Once the staffing was realigned and vacant positions filled, the time and effort certification for the fiscal year labor costs were completed during the months between August 2024 and November 2024. The College is committed to improving its internal controls over time and effort reporting for research and development grants to ensure compliance and has already taken corrective actions to assist. Cause: As noted in the condition above, staffing issues related to vacancies and adequate training resources within the Office of Grants and Sponsored Research (OGSR) during the fiscal year led to inconsistent and untimely preparation of Effort Verification Forms (EVFs). This impacted the department's ability to meet the original time and effort required completion date. Corrective Actions: 1. Reorganized Post-Award Administration tasks to Finance and Business Services (FBS): In response to the identified challenges, the College has transferred a majority of the grant post-award financial and reporting administration responsibilities to the Department of Finance and Business Services (FBS). This transfer allows for a more centralized and streamlined approach to managing time and effort reporting and financial post-award functions. 2. Staffing Gaps Filled: To support the transfer of responsibilities, two new staff members have been hired within FBS to manage the post-award financial and reporting administration, including time and effort reporting tasks. 3. Improved Monitoring and Oversight: The College has implemented a monitoring and oversight process for time and effort reporting to ensure that all required documentation is completed and certified according to required guidelines. Specifically, the College has designated a responsible party within FBS to conduct regular audits of time and effort reports to confirm compliance with both internal policies and federal regulations. 4. Strengthened Training and Communication: FBS staff and relevant personnel will receive enhanced training on the College’s Effort Verification Operating Policy, emphasizing the importance of timely documentation and certification of EVFs. This will help prevent lapses in reporting and ensure that staff are fully aware of their responsibilities under 2 CFR 200.430(g). 5. Action Plan for Corrective Timing: The College has implemented a more proactive scheduling and tracking system to avoid any delays in the preparation and certification of EVFs going forward. Individual Responsible for Corrective Action: Karen Miller, Controller Jeanette Vega, Director of Grant Financial Administration Anticipated Completion Date for Corrective Action: Partially complete in September 2024, with remaining items by June 30, 2025
Finding 2024-002 (ACFR Finding 2024-002) – Significant Deficiency Internal Control over Compliance Finding – Allowable Costs Education Stabilization Fund ALN: 84.425U FAIN: S425U210027 Grantor Agency: U.S. Department of Education Pass-Through Agency: State Department of Education Criteria: According to 2 CFR 200.403(a) and (g), for costs to be allowable under a federal awards, they must be necessary, reasonable, and adequately documented. Additionally, 2 CFR 200.430(a) requires that payroll costs charged to federal grants be based on records that accurately reflect the work performed and be properly authorized. Statement of Condition: The District charged payroll expenditures to the Educational Stabilization Fund (ESF) grant for employees who were not approved to be paid from the grant. Additionally, certain employees were paid at rates that were not authorized by the Board. Furthermore, journal entries related to payroll expenses were not supported by adequate documentation. As a result, we identified $51,682 in questioned costs. Context: During our testing of ESF, we tested the payroll expenditures charged to the grant. Our testing included reviewing and reconciling the individual employees to board approvals to be charged to the grant, reviewing the approved pay rates for the grant for hourly or stipend employees, and reconciling the underlying data on payroll-related journal entries and time sheets. Cause and effect: The District did not have adequate internal controls to ensure that only authorized employees and approved pay rates were used for payroll costs charged to the ESF grant. Additionally, there was a lack of review and oversight over payroll-related journal entries to ensure they were properly supported. Without proper controls over payroll charges and documentation, the District risks noncompliance with federal grant requirements, which could result in disallowed costs and potential repayment of federal funds. In this case, $51,682 in payroll expenditures are considered questioned costs, subject to further review by the granting agency. Questioned Costs: $51,682 Recommendation: We recommend that the District strengthen internal controls over payroll processing related to grants to ensure that only authorized employees and approved pay rates are charged to the ESF grant, implement a review process to verify that all payroll-related journal entries are adequately supported before posting, conduct a review of payroll charges to federal grants to identify and correct any additional instances of unapproved costs, provide training to finance and grant management staff on federal grant requirements for payroll expenditures, and coordinate with grantor agency to determine appropriate corrective action regarding the identified questioned costs. Views of Responsible Officials: District management concurs with the finding and has developed a corrective action plan in response to the recommendations above and has begun to take action to address the finding.
Finding 2024-002 (ACFR Finding 2024-002) – Significant Deficiency Internal Control over Compliance Finding – Allowable Costs Education Stabilization Fund ALN: 84.425U FAIN: S425U210027 Grantor Agency: U.S. Department of Education Pass-Through Agency: State Department of Education Criteria: According to 2 CFR 200.403(a) and (g), for costs to be allowable under a federal awards, they must be necessary, reasonable, and adequately documented. Additionally, 2 CFR 200.430(a) requires that payroll costs charged to federal grants be based on records that accurately reflect the work performed and be properly authorized. Statement of Condition: The District charged payroll expenditures to the Educational Stabilization Fund (ESF) grant for employees who were not approved to be paid from the grant. Additionally, certain employees were paid at rates that were not authorized by the Board. Furthermore, journal entries related to payroll expenses were not supported by adequate documentation. As a result, we identified $51,682 in questioned costs. Context: During our testing of ESF, we tested the payroll expenditures charged to the grant. Our testing included reviewing and reconciling the individual employees to board approvals to be charged to the grant, reviewing the approved pay rates for the grant for hourly or stipend employees, and reconciling the underlying data on payroll-related journal entries and time sheets. Cause and effect: The District did not have adequate internal controls to ensure that only authorized employees and approved pay rates were used for payroll costs charged to the ESF grant. Additionally, there was a lack of review and oversight over payroll-related journal entries to ensure they were properly supported. Without proper controls over payroll charges and documentation, the District risks noncompliance with federal grant requirements, which could result in disallowed costs and potential repayment of federal funds. In this case, $51,682 in payroll expenditures are considered questioned costs, subject to further review by the granting agency. Questioned Costs: $51,682 Recommendation: We recommend that the District strengthen internal controls over payroll processing related to grants to ensure that only authorized employees and approved pay rates are charged to the ESF grant, implement a review process to verify that all payroll-related journal entries are adequately supported before posting, conduct a review of payroll charges to federal grants to identify and correct any additional instances of unapproved costs, provide training to finance and grant management staff on federal grant requirements for payroll expenditures, and coordinate with grantor agency to determine appropriate corrective action regarding the identified questioned costs. Views of Responsible Officials: District management concurs with the finding and has developed a corrective action plan in response to the recommendations above and has begun to take action to address the finding.
Finding 2024-002 (ACFR Finding 2024-002) – Significant Deficiency Internal Control over Compliance Finding – Allowable Costs Education Stabilization Fund ALN: 84.425U FAIN: S425U210027 Grantor Agency: U.S. Department of Education Pass-Through Agency: State Department of Education Criteria: According to 2 CFR 200.403(a) and (g), for costs to be allowable under a federal awards, they must be necessary, reasonable, and adequately documented. Additionally, 2 CFR 200.430(a) requires that payroll costs charged to federal grants be based on records that accurately reflect the work performed and be properly authorized. Statement of Condition: The District charged payroll expenditures to the Educational Stabilization Fund (ESF) grant for employees who were not approved to be paid from the grant. Additionally, certain employees were paid at rates that were not authorized by the Board. Furthermore, journal entries related to payroll expenses were not supported by adequate documentation. As a result, we identified $51,682 in questioned costs. Context: During our testing of ESF, we tested the payroll expenditures charged to the grant. Our testing included reviewing and reconciling the individual employees to board approvals to be charged to the grant, reviewing the approved pay rates for the grant for hourly or stipend employees, and reconciling the underlying data on payroll-related journal entries and time sheets. Cause and effect: The District did not have adequate internal controls to ensure that only authorized employees and approved pay rates were used for payroll costs charged to the ESF grant. Additionally, there was a lack of review and oversight over payroll-related journal entries to ensure they were properly supported. Without proper controls over payroll charges and documentation, the District risks noncompliance with federal grant requirements, which could result in disallowed costs and potential repayment of federal funds. In this case, $51,682 in payroll expenditures are considered questioned costs, subject to further review by the granting agency. Questioned Costs: $51,682 Recommendation: We recommend that the District strengthen internal controls over payroll processing related to grants to ensure that only authorized employees and approved pay rates are charged to the ESF grant, implement a review process to verify that all payroll-related journal entries are adequately supported before posting, conduct a review of payroll charges to federal grants to identify and correct any additional instances of unapproved costs, provide training to finance and grant management staff on federal grant requirements for payroll expenditures, and coordinate with grantor agency to determine appropriate corrective action regarding the identified questioned costs. Views of Responsible Officials: District management concurs with the finding and has developed a corrective action plan in response to the recommendations above and has begun to take action to address the finding.
Finding 2024-002 (ACFR Finding 2024-002) – Significant Deficiency Internal Control over Compliance Finding – Allowable Costs Education Stabilization Fund ALN: 84.425U FAIN: S425U210027 Grantor Agency: U.S. Department of Education Pass-Through Agency: State Department of Education Criteria: According to 2 CFR 200.403(a) and (g), for costs to be allowable under a federal awards, they must be necessary, reasonable, and adequately documented. Additionally, 2 CFR 200.430(a) requires that payroll costs charged to federal grants be based on records that accurately reflect the work performed and be properly authorized. Statement of Condition: The District charged payroll expenditures to the Educational Stabilization Fund (ESF) grant for employees who were not approved to be paid from the grant. Additionally, certain employees were paid at rates that were not authorized by the Board. Furthermore, journal entries related to payroll expenses were not supported by adequate documentation. As a result, we identified $51,682 in questioned costs. Context: During our testing of ESF, we tested the payroll expenditures charged to the grant. Our testing included reviewing and reconciling the individual employees to board approvals to be charged to the grant, reviewing the approved pay rates for the grant for hourly or stipend employees, and reconciling the underlying data on payroll-related journal entries and time sheets. Cause and effect: The District did not have adequate internal controls to ensure that only authorized employees and approved pay rates were used for payroll costs charged to the ESF grant. Additionally, there was a lack of review and oversight over payroll-related journal entries to ensure they were properly supported. Without proper controls over payroll charges and documentation, the District risks noncompliance with federal grant requirements, which could result in disallowed costs and potential repayment of federal funds. In this case, $51,682 in payroll expenditures are considered questioned costs, subject to further review by the granting agency. Questioned Costs: $51,682 Recommendation: We recommend that the District strengthen internal controls over payroll processing related to grants to ensure that only authorized employees and approved pay rates are charged to the ESF grant, implement a review process to verify that all payroll-related journal entries are adequately supported before posting, conduct a review of payroll charges to federal grants to identify and correct any additional instances of unapproved costs, provide training to finance and grant management staff on federal grant requirements for payroll expenditures, and coordinate with grantor agency to determine appropriate corrective action regarding the identified questioned costs. Views of Responsible Officials: District management concurs with the finding and has developed a corrective action plan in response to the recommendations above and has begun to take action to address the finding.
Finding 2024-002 (ACFR Finding 2024-002) – Significant Deficiency Internal Control over Compliance Finding – Allowable Costs Education Stabilization Fund ALN: 84.425U FAIN: S425U210027 Grantor Agency: U.S. Department of Education Pass-Through Agency: State Department of Education Criteria: According to 2 CFR 200.403(a) and (g), for costs to be allowable under a federal awards, they must be necessary, reasonable, and adequately documented. Additionally, 2 CFR 200.430(a) requires that payroll costs charged to federal grants be based on records that accurately reflect the work performed and be properly authorized. Statement of Condition: The District charged payroll expenditures to the Educational Stabilization Fund (ESF) grant for employees who were not approved to be paid from the grant. Additionally, certain employees were paid at rates that were not authorized by the Board. Furthermore, journal entries related to payroll expenses were not supported by adequate documentation. As a result, we identified $51,682 in questioned costs. Context: During our testing of ESF, we tested the payroll expenditures charged to the grant. Our testing included reviewing and reconciling the individual employees to board approvals to be charged to the grant, reviewing the approved pay rates for the grant for hourly or stipend employees, and reconciling the underlying data on payroll-related journal entries and time sheets. Cause and effect: The District did not have adequate internal controls to ensure that only authorized employees and approved pay rates were used for payroll costs charged to the ESF grant. Additionally, there was a lack of review and oversight over payroll-related journal entries to ensure they were properly supported. Without proper controls over payroll charges and documentation, the District risks noncompliance with federal grant requirements, which could result in disallowed costs and potential repayment of federal funds. In this case, $51,682 in payroll expenditures are considered questioned costs, subject to further review by the granting agency. Questioned Costs: $51,682 Recommendation: We recommend that the District strengthen internal controls over payroll processing related to grants to ensure that only authorized employees and approved pay rates are charged to the ESF grant, implement a review process to verify that all payroll-related journal entries are adequately supported before posting, conduct a review of payroll charges to federal grants to identify and correct any additional instances of unapproved costs, provide training to finance and grant management staff on federal grant requirements for payroll expenditures, and coordinate with grantor agency to determine appropriate corrective action regarding the identified questioned costs. Views of Responsible Officials: District management concurs with the finding and has developed a corrective action plan in response to the recommendations above and has begun to take action to address the finding.
2024-002: Payroll Timecard Approval Federal Departments: Department of Health and Human Services Assistance Listing #: 93.612 and 93.959 Compliance and Internal Controls Significant Deficiency Category of Finding – Allowable Costs/ Cost Principles Criteria – 2 CFR § 200.430 requires that compensation for individual employees be reasonable for the services rendered, be consistently applied to both federal and non-federal activities, follows all of the Organizations written policies, and is adequately documented. Adequately documented as defined by the standard requires the charges must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition – During testing, we noticed multiple timecards for the Executive Director were not approved by the responsible individual so the required supervisors’ review of the timecard for accurate hours and allocations did not occur and was not documented. Cause – Controls in place did not operate as designed so hours charged to the grant were not properly reviewed for accuracy by responsible individuals. Effect – Salaries or wages may be overcharged or undercharged to grant if program allocation is not documented. If the granting agency ever questioned costs, IPTF may not be able to prove that all the funds requested for reimbursement from the agency were for activities allowed under the grant. Context – A nonstatistical sample of 28 payroll transactions were selected for testing. Timecard approval was performed by an unauthorized individual for 7 transactions. Recommendation – We recommend the management implement and enforce a review process to ensure all timecards are reviewed by the responsible individual or responsible individuals in a timely manner. Auditee’s comments and response – IPTF has hired and assigned an experienced individual within the organization who has the responsibility of reviewing and approving the Executive Director's timecard prior to processing. Responsible party for corrective action: Sharon Day, Executive Director Repeat finding – 2023-005
2024-002: Payroll Timecard Approval Federal Departments: Department of Health and Human Services Assistance Listing #: 93.612 and 93.959 Compliance and Internal Controls Significant Deficiency Category of Finding – Allowable Costs/ Cost Principles Criteria – 2 CFR § 200.430 requires that compensation for individual employees be reasonable for the services rendered, be consistently applied to both federal and non-federal activities, follows all of the Organizations written policies, and is adequately documented. Adequately documented as defined by the standard requires the charges must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition – During testing, we noticed multiple timecards for the Executive Director were not approved by the responsible individual so the required supervisors’ review of the timecard for accurate hours and allocations did not occur and was not documented. Cause – Controls in place did not operate as designed so hours charged to the grant were not properly reviewed for accuracy by responsible individuals. Effect – Salaries or wages may be overcharged or undercharged to grant if program allocation is not documented. If the granting agency ever questioned costs, IPTF may not be able to prove that all the funds requested for reimbursement from the agency were for activities allowed under the grant. Context – A nonstatistical sample of 28 payroll transactions were selected for testing. Timecard approval was performed by an unauthorized individual for 7 transactions. Recommendation – We recommend the management implement and enforce a review process to ensure all timecards are reviewed by the responsible individual or responsible individuals in a timely manner. Auditee’s comments and response – IPTF has hired and assigned an experienced individual within the organization who has the responsibility of reviewing and approving the Executive Director's timecard prior to processing. Responsible party for corrective action: Sharon Day, Executive Director Repeat finding – 2023-005
2024-002: Payroll Timecard Approval Federal Departments: Department of Health and Human Services Assistance Listing #: 93.612 and 93.959 Compliance and Internal Controls Significant Deficiency Category of Finding – Allowable Costs/ Cost Principles Criteria – 2 CFR § 200.430 requires that compensation for individual employees be reasonable for the services rendered, be consistently applied to both federal and non-federal activities, follows all of the Organizations written policies, and is adequately documented. Adequately documented as defined by the standard requires the charges must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition – During testing, we noticed multiple timecards for the Executive Director were not approved by the responsible individual so the required supervisors’ review of the timecard for accurate hours and allocations did not occur and was not documented. Cause – Controls in place did not operate as designed so hours charged to the grant were not properly reviewed for accuracy by responsible individuals. Effect – Salaries or wages may be overcharged or undercharged to grant if program allocation is not documented. If the granting agency ever questioned costs, IPTF may not be able to prove that all the funds requested for reimbursement from the agency were for activities allowed under the grant. Context – A nonstatistical sample of 28 payroll transactions were selected for testing. Timecard approval was performed by an unauthorized individual for 7 transactions. Recommendation – We recommend the management implement and enforce a review process to ensure all timecards are reviewed by the responsible individual or responsible individuals in a timely manner. Auditee’s comments and response – IPTF has hired and assigned an experienced individual within the organization who has the responsibility of reviewing and approving the Executive Director's timecard prior to processing. Responsible party for corrective action: Sharon Day, Executive Director Repeat finding – 2023-005
2024-002: Payroll Timecard Approval Federal Departments: Department of Health and Human Services Assistance Listing #: 93.612 and 93.959 Compliance and Internal Controls Significant Deficiency Category of Finding – Allowable Costs/ Cost Principles Criteria – 2 CFR § 200.430 requires that compensation for individual employees be reasonable for the services rendered, be consistently applied to both federal and non-federal activities, follows all of the Organizations written policies, and is adequately documented. Adequately documented as defined by the standard requires the charges must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition – During testing, we noticed multiple timecards for the Executive Director were not approved by the responsible individual so the required supervisors’ review of the timecard for accurate hours and allocations did not occur and was not documented. Cause – Controls in place did not operate as designed so hours charged to the grant were not properly reviewed for accuracy by responsible individuals. Effect – Salaries or wages may be overcharged or undercharged to grant if program allocation is not documented. If the granting agency ever questioned costs, IPTF may not be able to prove that all the funds requested for reimbursement from the agency were for activities allowed under the grant. Context – A nonstatistical sample of 28 payroll transactions were selected for testing. Timecard approval was performed by an unauthorized individual for 7 transactions. Recommendation – We recommend the management implement and enforce a review process to ensure all timecards are reviewed by the responsible individual or responsible individuals in a timely manner. Auditee’s comments and response – IPTF has hired and assigned an experienced individual within the organization who has the responsibility of reviewing and approving the Executive Director's timecard prior to processing. Responsible party for corrective action: Sharon Day, Executive Director Repeat finding – 2023-005
Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430 states in part: (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, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the activities allowed or unallowed and allowable costs/cost principle compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: $2,130 (Known questioned costs) Context: For 5 selections, in a sample of 5 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employees’ time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support for the allocation of the time charged to the School Lunch fund. Identification as a repeat finding: No. Recommendation: We recommend management ensure semi-annual certifications are completed for all employees charged to the grant awards at 100% and time and effort logs are maintained for all employees not charged at 100% to support work performed and charged to the grant awards. We recommend management establish a documented review by management of semi-annual certifications and time and effort logs to ensure time charged to grant awards is allowable and allocable based on work performed in accordance with grant requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430 states in part: (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, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the activities allowed or unallowed and allowable costs/cost principle compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: $2,130 (Known questioned costs) Context: For 5 selections, in a sample of 5 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employees’ time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support for the allocation of the time charged to the School Lunch fund. Identification as a repeat finding: No. Recommendation: We recommend management ensure semi-annual certifications are completed for all employees charged to the grant awards at 100% and time and effort logs are maintained for all employees not charged at 100% to support work performed and charged to the grant awards. We recommend management establish a documented review by management of semi-annual certifications and time and effort logs to ensure time charged to grant awards is allowable and allocable based on work performed in accordance with grant requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430 states in part: (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, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the activities allowed or unallowed and allowable costs/cost principle compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: $2,130 (Known questioned costs) Context: For 5 selections, in a sample of 5 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employees’ time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support for the allocation of the time charged to the School Lunch fund. Identification as a repeat finding: No. Recommendation: We recommend management ensure semi-annual certifications are completed for all employees charged to the grant awards at 100% and time and effort logs are maintained for all employees not charged at 100% to support work performed and charged to the grant awards. We recommend management establish a documented review by management of semi-annual certifications and time and effort logs to ensure time charged to grant awards is allowable and allocable based on work performed in accordance with grant requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430 states in part: (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, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the activities allowed or unallowed and allowable costs/cost principle compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: $2,130 (Known questioned costs) Context: For 5 selections, in a sample of 5 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employees’ time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support for the allocation of the time charged to the School Lunch fund. Identification as a repeat finding: No. Recommendation: We recommend management ensure semi-annual certifications are completed for all employees charged to the grant awards at 100% and time and effort logs are maintained for all employees not charged at 100% to support work performed and charged to the grant awards. We recommend management establish a documented review by management of semi-annual certifications and time and effort logs to ensure time charged to grant awards is allowable and allocable based on work performed in accordance with grant requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Federal Agency: U.S. Department of Homeland Security Federal Program Name: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Federal Award Identification Number and Year: FEMA-4496-DR (1/20/2020) Pass-Through Agency: Massachusetts Emergency Management Agency Pass-Through Number(s): CT CDA CTFEMA4496HINGH Award Period: January 20, 2020 through May 11, 2023 Compliance Requirement: Allowable Costs / Cost Principles Type of Finding: Material weakness in internal control over compliance; Material noncompliance Criteria or specific requirement: The United States Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Such records should support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on a federal award and a non-federal award. Condition: We noted that for a sample of payroll disbursements the total amount charged to the grant was not supported by accurate documentation. Questioned costs: Questioned costs total $3,898. Context: Sixty payroll transactions were selected for testing in our statistically valid sample and the following exceptions were noted: • For 2 of 60 disbursements, the Town requested reimbursement for employee hours which were not supported in the documented time records. • For 1 of 60 disbursements, the Town requested reimbursement for employee hours for which approval documentation was not available in the documented time records. Cause: Policies and procedures were not implemented to ensure that costs charged to the program were based on adequate supporting documentation. Effect: Unallowable costs were charged to the program. Repeat Finding: No. Recommendation: We recommend the Town enhance procedures and controls to ensure that payroll costs charged to the grant are adequately documented. Views of responsible officials: Management agrees with the finding. Please refer to the Corrective Action Plan.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430. In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system. Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date. This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430. In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system. Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date. This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430. In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system. Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date. This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430. In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system. Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date. This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430. In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system. Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date. This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430. In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system. Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date. This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430. In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system. Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date. This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430. In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system. Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date. This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430. In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system. Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date. This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430 states in part: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the activities allowed or unallowed and allowable costs/cost principle compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: $6,759 (Known questioned costs) Context: For 5 selections, in a sample of 40 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employees’ time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support for the allocation of the time charged to the ESSER II and III funds. Identification as a repeat finding: No. Recommendation: We recommend management ensure semi-annual certifications are completed for all employees charged to the grant awards at 100% and time and effort logs are maintained for all employees not charged at 100% to support work performed and charged to the grant awards. We recommend management establish a documented review by management of semi-annual certifications and time and effort logs to ensure time charged to grant awards is allowable and allocable based on work performed in accordance with grant requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.430 states in part: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the activities allowed or unallowed and allowable costs/cost principle compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: $6,759 (Known questioned costs) Context: For 5 selections, in a sample of 40 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employees’ time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support for the allocation of the time charged to the ESSER II and III funds. Identification as a repeat finding: No. Recommendation: We recommend management ensure semi-annual certifications are completed for all employees charged to the grant awards at 100% and time and effort logs are maintained for all employees not charged at 100% to support work performed and charged to the grant awards. We recommend management establish a documented review by management of semi-annual certifications and time and effort logs to ensure time charged to grant awards is allowable and allocable based on work performed in accordance with grant requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Criteria: According to 2 CFR §200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Specifically, the Uniform Guidance states that: • Records must reflect an after-the-fact review of the actual activity of each employee, • The review must be documented by the employee or responsible supervisor, • The documentation must account for the total activity for which employees are compensated, and • This documentation must be signed by the employee or supervisor. Condition: During our audit, we reviewed a sample of timesheets for employees whose salaries were charged to the grant award. We found that in one instance, an employee was paid $2,165 for a period of time in which the employee no longer worked for the School District. We found in another instance that an employee’s timesheet was missing the required supervisor’s signature, indicating that no formal review or approval process was documented. This employee was paid $1,128 for time during which no work was performed for the School District. Cause: Insufficient internal controls to ensure compliance with both timekeeping policies and employee termination policies. Effects: Without proper supervisory review and signature, there is an increased risk that salaries and wages charged to the federal award may not be accurately allocated to the correct activities and that time reported may not reflect actual work performed. Additionally, deficiencies in internal control surrounding the employee termination process can result in payments to individuals who no longer work for the School District. Questioned Costs: Known questioned costs, based on the results of our audit procedures, amounted to $3,293. When projecting these known questioned costs to the total population of payroll costs charged to the grant in the amount of $7,445,417, likely questioned costs amount to $40,520. Recommendation: We recommend the School District ensure that all supervisors are trained on the importance of reviewing and signing timesheets to comply with federal requirements. We also recommend that the School District evaluate the root cause of the erroneous payment to an employee who had resigned to ensure that controls surrounding employee resignations and terminations are adequate. Auditee’s Response: We concur with the finding and recommendations.
Criteria: According to 2 CFR §200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Specifically, the Uniform Guidance states that: • Records must reflect an after-the-fact review of the actual activity of each employee, • The review must be documented by the employee or responsible supervisor, • The documentation must account for the total activity for which employees are compensated, and • This documentation must be signed by the employee or supervisor. Condition: During our audit, we reviewed a sample of timesheets for employees whose salaries were charged to the grant award. We found that in one instance, an employee was paid $2,165 for a period of time in which the employee no longer worked for the School District. We found in another instance that an employee’s timesheet was missing the required supervisor’s signature, indicating that no formal review or approval process was documented. This employee was paid $1,128 for time during which no work was performed for the School District. Cause: Insufficient internal controls to ensure compliance with both timekeeping policies and employee termination policies. Effects: Without proper supervisory review and signature, there is an increased risk that salaries and wages charged to the federal award may not be accurately allocated to the correct activities and that time reported may not reflect actual work performed. Additionally, deficiencies in internal control surrounding the employee termination process can result in payments to individuals who no longer work for the School District. Questioned Costs: Known questioned costs, based on the results of our audit procedures, amounted to $3,293. When projecting these known questioned costs to the total population of payroll costs charged to the grant in the amount of $7,445,417, likely questioned costs amount to $40,520. Recommendation: We recommend the School District ensure that all supervisors are trained on the importance of reviewing and signing timesheets to comply with federal requirements. We also recommend that the School District evaluate the root cause of the erroneous payment to an employee who had resigned to ensure that controls surrounding employee resignations and terminations are adequate. Auditee’s Response: We concur with the finding and recommendations.
Criteria: According to 2 CFR §200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Specifically, the Uniform Guidance states that: • Records must reflect an after-the-fact review of the actual activity of each employee, • The review must be documented by the employee or responsible supervisor, • The documentation must account for the total activity for which employees are compensated, and • This documentation must be signed by the employee or supervisor. Condition: During our audit, we reviewed a sample of timesheets for employees whose salaries were charged to the grant award. We found that in one instance, an employee was paid $2,165 for a period of time in which the employee no longer worked for the School District. We found in another instance that an employee’s timesheet was missing the required supervisor’s signature, indicating that no formal review or approval process was documented. This employee was paid $1,128 for time during which no work was performed for the School District. Cause: Insufficient internal controls to ensure compliance with both timekeeping policies and employee termination policies. Effects: Without proper supervisory review and signature, there is an increased risk that salaries and wages charged to the federal award may not be accurately allocated to the correct activities and that time reported may not reflect actual work performed. Additionally, deficiencies in internal control surrounding the employee termination process can result in payments to individuals who no longer work for the School District. Questioned Costs: Known questioned costs, based on the results of our audit procedures, amounted to $3,293. When projecting these known questioned costs to the total population of payroll costs charged to the grant in the amount of $7,445,417, likely questioned costs amount to $40,520. Recommendation: We recommend the School District ensure that all supervisors are trained on the importance of reviewing and signing timesheets to comply with federal requirements. We also recommend that the School District evaluate the root cause of the erroneous payment to an employee who had resigned to ensure that controls surrounding employee resignations and terminations are adequate. Auditee’s Response: We concur with the finding and recommendations.
Criteria: According to 2 CFR §200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Specifically, the Uniform Guidance states that: • Records must reflect an after-the-fact review of the actual activity of each employee, • The review must be documented by the employee or responsible supervisor, • The documentation must account for the total activity for which employees are compensated, and • This documentation must be signed by the employee or supervisor. Condition: During our audit, we reviewed a sample of timesheets for employees whose salaries were charged to the grant award. We found that in one instance, an employee was paid $2,165 for a period of time in which the employee no longer worked for the School District. We found in another instance that an employee’s timesheet was missing the required supervisor’s signature, indicating that no formal review or approval process was documented. This employee was paid $1,128 for time during which no work was performed for the School District. Cause: Insufficient internal controls to ensure compliance with both timekeeping policies and employee termination policies. Effects: Without proper supervisory review and signature, there is an increased risk that salaries and wages charged to the federal award may not be accurately allocated to the correct activities and that time reported may not reflect actual work performed. Additionally, deficiencies in internal control surrounding the employee termination process can result in payments to individuals who no longer work for the School District. Questioned Costs: Known questioned costs, based on the results of our audit procedures, amounted to $3,293. When projecting these known questioned costs to the total population of payroll costs charged to the grant in the amount of $7,445,417, likely questioned costs amount to $40,520. Recommendation: We recommend the School District ensure that all supervisors are trained on the importance of reviewing and signing timesheets to comply with federal requirements. We also recommend that the School District evaluate the root cause of the erroneous payment to an employee who had resigned to ensure that controls surrounding employee resignations and terminations are adequate. Auditee’s Response: We concur with the finding and recommendations.
2024-001 Activities Allowed or Unallowed and Allowable Costs / Cost Principles Research and Development Cluster: National Institutes of Health: Institutional Career Development Costs (ALN 93.350, grant number 5 UL1 TR001866) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance Criteria: Non-federal entities should ensure that costs are reasonable and necessary for the performance of the Research and Development effort identified in the applicable award. In accordance with the documentation standards of 2 CFR section s200.430(i), costs of compensation for personal services are allowable to the extent total compensation for individual employees: a. Is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both federal and non-federal activities; b. Follows an appointment made in accordance with a non-federal entity’s rules or written policies and meets the requirements of federal statute, where applicable; and c. Is determined and supported as provided in 2 CFR section 200.430(i), including the charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition and context: In April 2024, University management became aware that a full-time employee of the University was concurrently employed by Duke-NUS Medical School in Singapore since early 2021. The employee had not previously disclosed to the University his affiliation with, and income from, Duke-NUS Medical School, including on his financial conflict of interest in research disclosure forms that the University requires all researchers to complete and in various documents and certifications in connection with several National Institutes of Health (NIH) grants, which supported a portion of his salary. The University retained external legal counsel to conduct an investigation. After this investigation by external counsel, several actions were taken. First, the University stopped drawing NIH grant funds to support this employee’s salary. The employee’s employment ended. The University conducted a financial conflict of interest in research review as to the employee’s previously undisclosed significant financial interests for the period 2021 to 2024, and other payments from Duke-NUS Medical School, dating back to 2019 and found no evidence that the design, conduct, or reporting of the employee’s NIH-funded work at the University had been adversely affected. Lastly, the University informed NIH of the matter and offered to repay half of the employee’s salary, fringe benefits, and indirect cost recovery charges that had been charged to NIH grants during the time period from January 2021 through May 2024. The proposed repayment amounts to $299,805. The amount charged to NIH grants during fiscal year 2024 was $178,084. Cause: The employee failed to disclose to the University that he was concurrently employed by Duke-NUS Medical School including on his financial conflict of interest in research forms that he was required to complete and in documents and certifications in connection with various NIH grants that supported his salary. Effect: Because the University assumed when calculating the employee’s salary that he was a full-time employee of the University and drew from NIH grants on that basis, but in reality, he was also working at Duke-NUS Medical School, some of the employee’s salary, related fringe benefits and indirect cost charges likely were unallowable under federal grant principles. Questioned Costs: The likely questioned costs are $178,084. Known questioned costs are indeterminable. Recommendation: The University should continue to communicate to University investigators the importance of accurately completing the financial conflicts of interest in research disclosure forms pursuant to applicable, long-standing University policies. Views of Responsible Officials: The University recognizes the seriousness of this matter, involving a former employee who accepted employment and worked at Duke-NUS Medical School in Singapore, without disclosing to the University this concurrent position. Under the University’s Code of Conduct, all members of the University community should conduct themselves ethically, honestly, and with integrity in all dealings and should act with due recognition of their position of trust with respect to the University’s research sponsors. Upon discovering that the employee had a concurrent employment at Duke-NUS, the University acted responsibly in investigating the matter and taking appropriate action, including notifying NIH, offering repayment, and fully cooperating with NIH. No internal controls or protocols were compromised as a result of this matter.