Finding Text
2023-003 Twenty-First Century Community Learning Centers – Assistance Listing No. 84.287
Material Weakness in Internal Control Over Compliance and Noncompliance – A. Activities Allowed or
Unallowed and B. Allowable Costs/Cost Principles
Criteria: 2 CFR 200.430(i) indicates costs must be based on records that accurately reflect the work performed to
be considered allowable. These records must be supported by a system of internal control which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated.
Condition and Context: We selected a sample of 25 instances of time allocated to the grant. We noted 20
instances where time allocated to the grant which lacked formal review of the time allocated. We noted 1
instance of time allocated which lacked adequate documentation resulting in questioned costs of $689. We
identified likely questioned costs of $20,367 based on applying an error rate of 4.71% from our sample. Our
sample was not statistically valid.
Cause and Effect: Policies and procedures were inconsistently applied to personnel costs, resulting in questioned
costs.
Recommendation: We recommend that the Organization establish a formal documentation process to ensure
personnel costs are adequately documented, reviewed, and allocated to the federal award.
Views of Responsible Officials and Planned Corrective Action: We agree with the recommendation and plan to
have corrective action implemented by December 31, 2024. An updated timesheet policy with the correct wording
will be created by the Finance Board Subcommitee at the October meeting, presented to the full Board of
Directors at the November Board meeting and voted on at the December 2024 Board meeting.