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 Title 1 program we noted that two of the employees
Semiannual Certification Form’s were certified before the period was over. Both Semiannual
Certification Forms for the period 1/1/2024-6/14/2024 were certified on 2/23/2024.
Potential Fiscal Impact
$49,153
Cause
The Organization’s internal control process over Federal Time Accounting was not properly designed
Effect
The Organization is out of compliance with 2 CFR §200.430.
Context
During the 2023-24 fiscal year, the Organization charged 2 employees to the Title 1 program for their
salaries or extra duty performed. We reviewed time accounting documentation for both of the employees
charged to the program. We identified findings in both of the employees 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