Finding Text
Part-Time Employee Certification (Significant Deficiency) Criteria: Under the requirements 45 CFR 1635.4(e(1) Timekeeping, any person who works part-time for the recipient and part-time for an organization that engages in restricted activities shall certify in writing that the employee has not engaged in restricted activity during any time for which the employee was compesated by the recipient or has not used recipient resources to carry out restricted activities. Conditions/Context: It was noted that the recipient had multiple part-time employees and none of them had completed the requried certifications. Cause: The omission of the forms appears to be caused by the insufficient internal knowledge of the certification process for part-time employees with dual employment in organizations engaged in restricted activities and an absence of a formal system to identify and monitor such employees for quarterly certification compliance. Effect: Without the signed certifications it is possible that a part-time employee may inadvertently commit potential violations of LSC restrictions, risking improper use of funds. Recommendation: We recommend the Organization review its processes related to part-time employment documentation and include the signed LSC recommended form as part of their employment process. Views of Responsible Officials: The recipient agrees with the audit findings and is implementing procedures to prevent non-compliance in the future.