Finding Text
Criteria or Specific Requirements
The Uniform Guidance states that allowable personnel costs charged to federal programs may
include reasonable amounts for activities contributing and directly related to work under an
agreement (2 CFR 200.430(i)(1)(i)). Charges to federal awards for salaries and wages must be
based on records that accurate reflect the work performed (2 CFR 200.430(g)(1)).
Condition
Material Weakness in Internal Control over Compliance – Time-and-effort reporting, or another
similar internal control activity to retroactively verify employee time spent on the program was
not reviewed and approved or not performed for the year ending June 30, 2024. During testing
over Activities Allowed or Unallowed and Allowable Cost requirements, the following
deficiencies were noted:
For the Career and Technical Education program, 14 out of 14 employees selected for
testing do not have time-and-effort record reflecting the distribution of the employee’s
salary and wages for the federal program.
For the Title III and V programs, we noted the following –
o 25 out of 30 employees selected for testing did not have time-and-effort record
reflecting the distribution of the employee’s salary and wages for the federal
program.
o 5 out of 30 employees selected for testing had time-and-effort records,
however, there were no evidence of review and approval. 2 of the 5 employees
also had incomplete time-and-effort reports (i.e. only for half of the fiscal year,
or a few months).
Questioned Costs
Career Technical Education – Basic Grants to States known questioned costs: $749,547.
Higher Education Institutional Aid programs known questioned costs: $1,431,770.
Context
The Career Technical Education program reference above had a total of $2,355,332 in
expenditures for the year ended June 30, 2024, of which $1,108,453 were associated with
salaries and benefits. There was a total population of 66 employees charged to the program in
the fiscal year ended June 30, 2024.
The Title III and V programs referenced above had a total of $2,865,454 in expenditures for the
year ended June 30, 2024, of which $2,248,191 associated with salaries and benefits. There was
a total population of 148 employees charged to the program in the fiscal year ended June 30,
2024.
Effect
Without effective internal controls in place over personnel costs, the District risks
noncompliance for program costs that could be material.
Cause
The District does not have policies and procedures in place to review personnel charges to
identify the employee costs that should and should not be charged to the federal program
referenced above.
Repeat Finding (Yes or No)
No
Recommendation
The District should monitor personnel costs charged to federal programs in accordance with the
Uniform Guidance. The District should review personnel costs on a regular basis to ensure that
costs charged are supported by allowable activities directly related to the program. Additionally,
adequate supporting documentation should be retained for personnel costs charged to the
federal programs.
Views of Responsible Officials and Corrective Action Plan
The District and campus staff will work together to develop processes to capture proper and
relevant time and effort activities. This will ensure documentation can be provided regarding
personnel expenses to identify employee costs charged to federal programs.