Finding Text
Findings and Questioned Costs – Major Federal Award Programs Audit
Federal Agency: U.S. Department of Education
Passthrough Entity: Missouri Department of Elementary and Secondary Education
Assistance Listing Number and Federal Program: 84.010 Title I Grants to Local Educational Agencies
Compliance Requirement: B. Allowable Costs
Criteria:
Per 2 CFR 200.430(g)(1)(i), the District is required to have records that are supported by a system of internal
control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The
District uses semi-annual certifications to determine if the salaries and/or employee benefits of its employees are allowable for the grant. These certifications are to be signed after each semi-annual period by the teacher and the Title I program director. These certifications show that the teachers’ time was spent under the Title I program, and their salaries and benefits are allowable for the Title I program.
Condition:
During the course of our audit, we reviewed semi-annual certifications for all Title I teachers, as required. These
certifications are used to verify that the employee spent one hundred percent of their time working in the Title I
program. Per requirements, these certifications should be signed at the end of the applicable period as that is when the actual time spent in the program is known. However, during our review, we noted that all the certifications were signed at the beginning of the applicable semi-annual period.
Cause:
There is a lack of oversight in this area. Supervisors should ensure the teachers complete the semi-annual
certifications in a timely manner after the end of each semi-annual period. Also, program directors should be
reviewing the signed certifications to ensure all program requirements are followed to avoid any noncompliance
issues and consequences.
Effect:
Semi-annual certifications are listed under the Allowable Costs/Cost Principles compliance requirement. In order to apply expenditures to the Title I Program, the employees need to certify that they are spending all of their time on that program. Without this certification, it is not clear that the amounts reported as Title I expenditures are indeed eligible expenditures.
Questioned Costs:
No questioned costs noted.
Perspective Information:
This appears to be a systemic problem since all Title I semi-annual certifications for the fiscal year 2024 were
reviewed and all certifications were filled out at the beginning of each semi-annual period instead of subsequent to the period.
Identification of Repeat Findings:
Not a repeat finding.
Recommendation:
We recommend that the District employ stronger oversight in this area by assigning a review to the Title Program
Director or equivalent. Once the certifications are signed by a supervisor, they should be forwarded to this point
person for their review and signature. The certifications should be reviewed to ensure each Title teacher is
completing a semi-annual certification and that it is being signed by the supervisor. These certifications should also have a due date twice a year to ensure they are done timely and are not overlooked. These should be added to the review checklist already used for Title I reporting.
Views of Responsible Officials:
The District will set up automated reminders through the internal tracking system with specific deadlines to ensure that all certifications are completed and signed no later than 30 business days after the end of the applicable periods. Regular checks will be conducted by the Title 1 Coordinator to verify that all certifications are completed and signed within the required timeframes. All relevant staff members will undergo training on the new procedures, and will be assigned roles and responsibilities for monitoring and submitting the certifications. See Corrective Action Plan.