Finding Text
Criteria or Specific Requirement
Federal regulation 2 CFR §200.430 states that “charges to Federal awards for salaries and wages must comply
with the established accounting policies and practices of the non-Federal entity and budget estimates
determined before the services are performed alone do not qualify as support for charges to Federal awards.”
Entity policy states that “All employees who are paid in full or in part with federal funds, including employees
whose salary is paid with state or local funds but is used to meet a required match or in-kind contribution to
a federal program, shall document the amount of time they spend on grant activities (AR 3230)”.
Condition
In our review of employees charged to the WIOA program we noted that one employee who was split funded
between WIOA and Vocational Training had a periodic time certification with fixed percentages, but did not
work a fixed schedule throughout the year.
Cause
The Entity’s internal control process over deposits was not properly designed.
Effect
The Entity is out of compliance with 2 CFR §200.430. It is reasonably possible that additional employees are
mischarged in the payroll system.
Context
During the 2023-24 fiscal year, the Entity charged 23 employees to the WIOA program in whole or in part
for their salaries or extra duty performed. We reviewed time accounting documentation for 6 of the 23
employees charged to the program. We identified findings in 1 out of 6 that were reviewed.
Repeat Finding
No
Recommendation
Continue to provide training to all employees funded from federal programs and their supervisors to the
requirements for federal time accounting under 2 CFR §200.430. Identify an individual responsible to
monitor documentation to ensure it meets requirements. Implement a reconciliation between federal time
accounting documentation and payroll records to ensure that appropriate adjustments are made to ensure
payroll is charged to the correct programs.
Views of Responsible Officials
See Corrective Action Plan