Finding Text
Criteria
If a school operating a schoolwide program does not consolidate federal funds with state and
local funds in a consolidated schoolwide pool, an employee who works, in whole or in part, on
a federal program or cost objective must document time and effort as follows:
(a) For an employee who works solely on a single cost objective (e.g., a single federal
program whose funds have not been consolidated or federal programs whose funds have
been consolidated but not with State and local funds), an LEA is not required to maintain
records reflecting the distribution of the employee’s salary and wages, including among the
Federal programs included in the consolidation, if applicable.
(b) For an employee who works on multiple activities or cost objectives (e.g., in part on a
federal program whose funds have not been consolidated in a consolidated schoolwide pool
and in part on federal programs supported with funds consolidated in a schoolwide pool or
on activities that are not part of the same cost objective), an LEA must maintain time and
effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the
portion of time and effort dedicated to:
(i) The federal program or cost objective; and
(ii) Each other program or cost objective supported by consolidated federal funds or
other revenue sources.
Condition/Context
We haphazardly sampled thirteen employees who received compensation under the Title I
grant. We viewed the employee time sheet and payroll certifications and annual certifications
determining that the employee’s time and effort and payroll certifications are reviewed and
approved. We noted that eight of the employees that spent less than 100% of their time on the
grant did not indicate how much of their time was allocated to the grant. Therefore, we were
unable to verify these employees’ time and effort. We also noted two employees that had
missing payroll certifications. Therefore, we were unable to verify approval of the certification
had occurred. The sampling methodology used was not statistically valid.
Cause
Time and effort statements were not prepared in all cases and adequate oversight of the
employee’s payroll certification was not in place in order to identify mistakes approved pay.
Effect
Without demonstrable, documented controls supporting compliance with Title I compliance
standards, compliance with the requirements may not be assured.
Questioned Costs
Known and likely questioned costs were not determinable.
Recommendation
We recommend that the School District institute additional procedures to ensure that
employee’s time and effort, for those with less than 100% allocated to the grant, and payroll
certifications are documented and reviewed for accuracy.
View of Responsible Officials
The School District will institute additional procedures to ensure that time and effort
determinations are reviewed and accurate.