Finding 1136295 (2024-001)

Material Weakness
Requirement
B
Questioned Costs
-
Year
2024
Accepted
2025-05-08

AI Summary

  • Core Issue: The District failed to properly implement its Time and Effort Reporting Policy, leading to unsupported salary expenditures for lunchroom employees.
  • Impacted Requirements: Compliance with 2 CFR § 200.430 and the District’s policy on compensation documentation was not met, risking questioned costs and potential misuse of funds.
  • Recommended Follow-Up: Review and align time and effort documentation practices with federal guidance, ensuring all salary notices are signed and detailed to support expenditures.

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.

Categories

Allowable Costs / Cost Principles Reporting School Nutrition Programs Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 559845 2024-001
    Material Weakness
  • 559846 2024-001
    Material Weakness
  • 559847 2024-001
    Material Weakness
  • 559848 2024-001
    Material Weakness
  • 559849 2024-001
    Material Weakness
  • 559850 2024-001
    Material Weakness
  • 559851 2024-001
    Material Weakness
  • 559852 2024-001
    Material Weakness
  • 559853 2024-001
    Material Weakness
  • 559854 2024-002
    Material Weakness Repeat
  • 559855 2024-002
    Material Weakness Repeat
  • 559856 2024-002
    Material Weakness Repeat
  • 559857 2024-002
    Material Weakness Repeat
  • 1136287 2024-001
    Material Weakness
  • 1136288 2024-001
    Material Weakness
  • 1136289 2024-001
    Material Weakness
  • 1136290 2024-001
    Material Weakness
  • 1136291 2024-001
    Material Weakness
  • 1136292 2024-001
    Material Weakness
  • 1136293 2024-001
    Material Weakness
  • 1136294 2024-001
    Material Weakness
  • 1136296 2024-002
    Material Weakness Repeat
  • 1136297 2024-002
    Material Weakness Repeat
  • 1136298 2024-002
    Material Weakness Repeat
  • 1136299 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $500,000
10.553 School Breakfast Program $214,026
84.425 Education Stabilization Fund $206,511
10.559 Summer Food Service Program for Children $204,984
84.424 Student Support and Academic Enrichment Program $122,640
84.010 Title I Grants to Local Educational Agencies $92,650
84.027 Special Education Grants to States $70,753
10.555 National School Lunch Program $62,118
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $33,967
84.173 Special Education Preschool Grants $19,333
10.556 Special Milk Program for Children $330