Finding Text
Finding 2024-007: Time Accounting (50000)
Repeat Finding? This is a partial repeat of Finding 2023-009.
Program Identification:
Federal Agency: U.S. Department of Education
Pass‐through Entity: California Department of Education
Program Names: Title I, Part A Grants:
Title I, Part A, Basic Grants Local-Income and Neglected (AL No. 84.010)
Criteria: 2 CFR, section 200.430 states, in part: (i) Standards for Documentation of Personnel Expenses
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work
performed. These records must: (vii) 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 which are allocated using
different allocation bases; or an unallowable activity and a direct or indirect cost activity. 2 CFR, section 200.303
states, in part: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal
award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance
with Federal statutes, regulations, and the terms and conditions of the Federal award.
CSAM Procedure 905 states, in part: Periodic (Semiannual) Certification Employees who work solely on a single
federal award or cost objective need only complete a periodic certification. The periodic certification must:
Be prepared at least semiannually.
Be signed by the employee or the supervisory official having firsthand knowledge of the work performed by
the employee.
State the employee worked solely on that single federal program or cost objective during the period covered
by the certification.
Where multiple employees work on the same cost objective, a blanket certification may be used as the documentation
for all employees who worked on the cost objective.
Personnel Activity Report
Except as provided in “Substitute Systems for Time Accounting” … employees who work on multiple activities or
cost objectives of which at least one is federal must complete a personnel activity report (PAR) or equivalent
documentation.
A PAR may be as detailed as a document that identifies the employee’s activity daily by hours, or it may be as simple
as a report of the total hours or percentage of hours spent in each categorical program or cost objective. The level of
detail can generally be determined by the diversity and variation of the employee’s work activities. The safest approach
is to provide more documentation rather than less.
Condition: Five employees that had complete PARs for time accounting had the following deficiencies:
Salaries and benefits were charged 100% to Title I, Part A for these individuals, each month’s salary was
not reconciled to reflect the percentage on their PARs.
PARs were only provided for 4 months of the fiscal year, the remaining PAR reports requested were not
provided.
Context: Exceptions were identified for all five employees who were subject to PAR reporting.
Questioned Costs: Auditor is estimating that Title I, Part A, was overcharged by $30,205 because the District did not
modify each month’s charges to the actual percentage worked on the program. This overcharge was based on
averaging the percentage for the four months of PARs we were provided.
Cause: District lacks adequate controls to ensure that time certification documentation is prepared and maintained to
support all employees who are paid with federal funds.
Effect: Estimated cost questioned of $30,205 for the 2023-24 fiscal year.
Recommendation: We recommend that the District comply with 2 CFR, section 200.303, and CSAM Procedure 905,
which require that employee time certification forms be maintained for employees who charge time to federal program.
Views of Responsible Officials: The District acknowledges this finding and is committed to strengthening internal
controls to ensure compliance with federal time accounting requirements. The State and Federal Programs Department
has received training on Time and Effort procedures, and additional training is being provided to school sites to
reinforce accurate time certification and documentation for federal fund expenditures.
To address the deficiencies, the District will shift from an annual to a monthly reconciliation process, ensuring that
employee salaries charged to Title I accurately reflect actual work performed. The State and Federal Programs
Department will collaborate with the Budget Department to systematically track employees funded through Title I
and verify that all required PARs are completed and maintained.
These corrective actions will enhance oversight, reduce the risk of discrepancies, and improve compliance with federal
regulations. The District is committed to ongoing monitoring and training to prevent recurrence and ensure the
integrity of financial reporting.