Finding Text
84.011 MIGRANT EDUCATION PROGRAM – DEPARTMENT OF EDUCATION –COLORADO DEPARTMENT OF
EDUCATION PASS-THROUGH
2023-002 ALLOWABLE COSTS
1. Criteria: The cost principles in 2 CFR Part 200, subpart E (Cost Principles), prescribe the cost accounting
requirements associated with the administration of Federal awards by (1) States, local governments,
and Indian tribes.
2. Condition: One of the BOCES member districts did not submit reasonable documentation to support
the Time and Effort reporting required by the cost accounting requirements.
3. Context: While the BOCES is ultimately responsible for properly accounting for grant eligible costs, the
BOCES does ”flowthrough” reimbursement to its member districts for salaries and benefits that are
incurred directly by those districts. As such, the BOCES requires the member districts to retain proper
support of Time and Effort at the district level which is to be available upon request. In one instance,
while the support for the Time and Effort was submitted to the BOCES when requested, auditor review
of that documentation lead to questions about the nature of when that documentation was completed.
While the employees in question were not subject to specific timekeeping requirements as they were
not allocated employees, the actual Time and Effort certifications were not completed timely relative to
the underlying grant expenditures.
4. Cause: The specific cause could not be identified, however, the documentation provided evidence that
Time and Effort certifications were not completed timely and that both the BOCES and district internal
controls did not identify this failure.
5. Effect: While the BOCES was able to provide Time and Effort documentation for the underlying
personnel costs, the timing of those certifications is being questioned.
6. Recommendation: Due to the potential of ongoing staffing changes at the member district level, the
BOCES will want to reiterate documentation requirements annually. The BOCES may also want to start
requesting Time and Effort documentation as it is completed by the member districts to ensure that
they are complying with the documentation requirements. We would recommend that the BOCES
ensure, as part of their annual grant closeout, that they have all documentation required to support
grant expenditures maintained at the BOCES level in lieu of requesting that information on an as needed
basis.
7. Management Response: Centennial BOCES will begin monitoring and collecting monthly time and
effort for all listed employees of subgrantees. Centennial BOCES will continue to collect time and effort
documentation within Centennial BOCES staff. The BOCES will treat subgrantee employees as if they
were Centennial BOCES employees regarding collection of time and effort reports following appropriate
policies and procedures. At fiscal year-end a reconciliation of all documents required, including time and
effort documentation, will be completed.