Finding Text
Finding 2024-006 – Significant Deficiency: Allowable Costs and Activities – Control Finding
ALN 84.042 – Student Support Services, 84.044 – Talent Search and 84.047 – Upward Bound – TRIO Cluster
Federal Agency: U.S. Department of Education
Federal Award Numbers: P042A151026, P044A160377, and P047A170574
Pass-Through Entity: None
SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued)
For The Year Ended June 30, 2024
ALN 84.031 - Title III - Higher Education – Institutional Aid
Federal Agency: U.S. Department of Education
Federal Award Numbers: P031B170058 and P031E200062
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal programs.
Condition: We noted through procedures performed that payroll costs were not charged to the grant in accordance with the time and effort certification.
Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: TRIO Cluster - In a sample of 40 individual costs charged to the grant, one payroll item was found where 100% of an employee’s salary was charged to the grant, despite the time and effort certification indicating that only 64% should have been allocated. In addition, three individual costs in the sample lacked appropriate review and approval for the charges applied to the grant. This indicates that the control over compliance was not operating effectively.
Title III - In a sample of 40 individual costs charged to the grant, one payroll item was found where 100% of an employee’s salary was charged to the grant, despite the time and effort certification indicating that only 89% should have been allocated. This indicates that the control over compliance was not operating effectively.
Identification As A Repeat Finding: Not applicable
Recommendation: We recommend that management review the internal controls over allowable costs and activities to ensure the control is designed to ensure the correct amount of salaries are charged to the grant based on the approved time and effort certifications.
Views Of Responsible Officials: Payroll charges to federal programs must match certified time and effort documentation. The Director of Sponsored Programs, the Director of Title III, and the Grant Accountant will jointly review allocations before payrolls are processed. Monthly reports will be generated for review by the Grant Accountant, and discrepancies must be corrected within 30 days.
Management will implement a formal review and approval process to ensure that all allowable costs are verified for compliance with applicable regulations and approved by designated personnel prior to reimbursement or payment.