Finding Text
Significant Deficiency
Other Noncompliance
Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA)
Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund
Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER)
Repeat Finding: No
Criteria: Appendix B of 2 CFR Part 225 requires that if an employee works exclusively on a single federal award (a single cost objective), their salary charges must be supported by semi-annual certifications. These certifications must confirm the employee’s sole work on the program and be signed by the employee and approved by their supervisor. The District’s Federal Programs Procedural Handbook specifies the following:
“Employees who work solely on a single cost objective will have their time and effort confirmed twice annually through the use of a Semi-Annual Certification. The employee or supervisor with first-hand knowledge of the employee’s work will certify that the time and effort expended in the prior six-month period was in accordance with the cost objective identified on the form. Semi-Annual Certifications will include the names of all individuals paid through a specified federal grant who have worked on a single cost objective in the previous six-month period. These certifications will be distributed by the Federal Programs Director for the period of July 1 through December 31 and January 1 through June 30. The Semi-Annual Certifications will be collected and reviewed by the Federal Programs Director in a timely fashion, on or about the end of the month in which they are distributed.”
Condition: The District did not fulfill its present internal control policies and procedures contained in the District’s Federal Programs Procedural Handbook or Appendix B of 2 CFR Part 225. As a result, there were three instances where we were unable to observe all required semi-annual certifications for employees working under a single cost objective.
Context/
Perspective: This finding is a result of our statistically valid random sample of forty cash disbursements for single audit purposes and the conditions cited appear to be an isolated issue.
Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls.
Effect: Failure to prepare and review time and effort reporting forms in a timely and accurate manner may lead to improper charges to the federal award which can result in disallowed costs being applied to the program.
Question Costs: None
Recommendation: We recommend that the District implement additional internal controls to ensure that it obtains and maintains the required semi-annual certifications required by employees who work on a single cost objective and are paid through federal grants.
Views of
Responsible
Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.