Finding Text
2 CFR § 400.1 gives regulatory effect to the Department of Agriculture for 2 CFR § 200.430 which provides, in part, that costs of compensation are allowable to the extent that charges to federal awards for salaries and wages are based on records that accurately reflect the work performed.
Furthermore, the District’s Time and Effort Reporting Policy (#6116) provides that the total compensation for individual employees:
A. Is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and
B. Follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable.
Time and Effort reports:
A. Are supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated;
B. Are incorporated into the official records of the District;
C. Reasonably reflect the total activity for which the employee is compensated by the District, not exceeding 100% of the compensated activities;
D. Encompass both Federally assisted and other activities compensated by the District on an integrated basis;
E. Comply with the District’s established accounting policies and practices;
F. Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one (1) Federal award, a Federal award and non-Federal award, an indirect cost activity and a direct cost activity, two (2) or more indirect activities which are allocated using different allocation bases, or an unallowable activity and a direct or indirect cost activity.
Due to a lack of proper implementation of the District policy noted above, errors were noted during the testing of salary expenditures for the Child Nutrition Cluster. The semi-annual certificates representing salaries and benefits paid of $7,309 out of $30,433 or 24% for the lunchroom employees were not signed as approved by the Supervisor nor were there detailed time sheets to support that employees worked solely on a single Federal program or cost objective.
This could result in further questions regarding salaries and the allowability of costs related to grants. In addition, could result in the misuse of public funds and ultimately questioned costs.
The District should review the federal guidance associated with maintaining time and effort documentation in comparison to their policy and should fully implement said policy. This will help ensure all monies spent for the School District's Federal programs are properly support in accordance with Uniform Guidance requirements. In addition, salary notices should be specific as to position of employee and be signed by the Treasurer, Board President and employee.