Finding Text
Significant Deficiency / Other Non-compliance
Federal Agency
U.S. Department of Education
Pass-through:
Mississippi Department of Education
Assistance Listing Numbers:
84.425 U
Program Title:
COVID-19-Elementary & Secondary School Emergency Relief Fund (ESSER) ARP III
Compliance Requirement:
Activities Allowed or Unallowed;
Allowable Costs/Cost Principles.
Repeat Finding from prior year:
No
Prior Year Finding Number:
N/A
Criteria:
2 CFR Section 200.430(g) specifies that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated and 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 allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
In addition, the district’s Federal Programs Procedural Handbook states “ Salaries and wages paid for North Tippah employees who work on a single federal cost object must be supported by periodic certifications that the employees worked solely on that activity for the period covered by the certification. These certifications must be prepared at least semi-annually, then signed and dated by the employee and supervisory administrator that has firsthand knowledge of the employee’s work.
North Tippah Employees who work on multiple cost objectives must support the distribution of their salaries or wages by completing personnel activity reports These personnel activity reports must reflect an after the fact distribution of the actual activity; must account for the total activity for which the employee is compensated; must be prepared at least monthly, coinciding with one or more pay periods; and the PAR shall have a legible handwritten signature signed and dated by employee and supervisory administrator that has firsthand knowledge of the employee’s work.
Condition:
The district failed to follow the their policies and procedures regarding time and effort documentation, as a result time and effort documentation for seven employees were not available for audit.
Context/Perspective
This finding is a result of our statistically valid random sample of forty cash disbursements for single audit purposes and the conditions cited appear to be an isolated issue.
Cause:
The cause is likely a failure to monitor and follow the District’s documented internal controls procedures.
Effect:
Failure to prepare and review time and effort reporting forms in a timely and accurate manner may lead to improper charges to the federal award which can result in disallowed costs being applied to the program.
Recommendation:
We recommend that the District implement additional internal controls to ensure that it obtains and maintains the required semi-annual certifications required by employees who work on a
single cost objective and are paid through federal grants or monthly personnel activity reports (PAR) for employees who work on more that one cost objective.
Questioned Cost:
None
Views of responsible officials of the auditee:
See Auditee’s Corrective Action Plan