Finding Text
Finding 2024-001: Time and Effort Requirements (50000)
Repeat Finding? No
Assistance Listing No. 84.010 – Title I, Part A
Assistance Listing No. 84.425 – Education Stabilization Funds (ESSER)
U.S. Department of Education
Passed through California Department of Education
Criteria: To support salaries and wages for employees that work on federal programs, local educational agencies
(LEAs) are required to maintain time and effort records that accurately reflect the work performed. These time and
effort records must: (1) be supported by a system of internal control which provides reasonable assurance that the
charges are accurate, allowable, and properly allocated; (2) be incorporated into the official records of the LEA; (3)
reasonably reflect the total activity for which the employee is compensated by the LEA, not exceeding 100% of
compensated activities; (4) encompass both federally assisted and all other activities compensated by the LEA on an
integrated basis, but may include the use of subsidiary records as defined in the LEA’s written policy; (5) comply
with the established accounting policies and practices of the LEA; and (6) 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. Budget estimates or percentages determined before the services are performed alone do not qualify as
support for charges to Federal awards.
Condition: Time accounting documentation could not be located for certain employees whose salaries were charged
to federal programs. Four other employees' time accounting documentation was not signed until the date of the
audit, well after the close of the fiscal year in which they were accounted for.
Cause: The District did not have adequate oversight to ensure that sufficient time and effort procedures were
supported by documentation.
Effect: The District could be required to reclassify expenditures from Title I funds and ESSER III funds to an
unrestricted funding source.
Questioned Costs: The District did not provide documentation for $354,548.97 charged to Title I and ESSER
programs.
Context: We sampled 3 out of a total of 28 employees charged to Title I funds. Two of those 3 who were sampled
were missing time accounting documentation, and their total salaries were $167,858.84. We sampled 11 out of a
total of 101 employees charged to ESSER III funds. Three of those 11 who were sampled were missing time
accounting documentation, and their total salaries were $186,690.13.
Recommendation: The District must update its time and effort records and policies and procedures to ensure that
all salaries and wages charged to federal programs are properly supported by a system on internal controls.
Specifically, the time and effort records must accurately reflect the work performed and encompass all activities of
the employee, both federal and non-federal, and be signed in a timely manner.
Views of Responsible Officials: Managers of each employee group have been notified of the importance of
completing the time and effort requirements. Managers with the support of the admin/department secretaries are
now tasked with monitoring, reconciling and ensuring that these documents are completed and submitted on a
monthly basis.