Finding 1152615 (2024-001)

Material Weakness
Requirement
B
Questioned Costs
$1
Year
2024
Accepted
2025-09-11

AI Summary

  • Core Issue: The District lacked adequate internal controls and did not meet time-and-effort documentation requirements for federal funds, leading to a material weakness.
  • Impacted Requirements: Compliance with federal regulations and OSPI guidelines for documenting payroll costs, specifically for 19 employees totaling $1,415,509.
  • Recommended Follow-Up: Implement robust internal controls for timely collection of signed time-and-effort documentation and ensure ongoing monitoring and training for staff.

Finding Text

The District did not have adequate internal controls and did not comply with time-and-effort requirements. Assistance Listing Number and Title: 84.027, Special Education Grant to States 84.173, Special Education Preschool Grants Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 84.027A-GT-0852; 84.173A-GT-0852; 84.173 – GT-1196 Known Questioned Cost Amount: $1,415,509 Prior Year Audit Finding: N/A Background During fiscal year 2024, the District spent $1,842,531 in federal funds from the Special Education program cluster. This program ensures students with disabilities receive free and appropriate public education with specially designed instruction that addresses their unique needs. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs it charges to the program with adequate time-and-effort documentation, as required by federal regulations and the awarding agency. Depending on the number and types of activities employees perform, time-and-effort documentation can be a semiannual certification or a monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after employees complete the work. If the District initially allocates payroll expenditures to federal programs based on a budgeted or estimated time or amounts, then it must compare and adjust estimated payroll time-and-effort records to actual time at least quarterly, if the difference is 10% or more. At year-end, payroll records must match time-and-effort documentation to ensure the District only charges federal programs for work directly supporting them. Description of Condition The District’s internal controls were ineffective for ensuring it supported all salaries and benefits it charged to the program with appropriate time-and-effort documentation, as federal regulations and the Office of Superintendent of Public Instruction (OSPI) require. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition The District experienced turnover in key positions responsible for monitoring the program. As a result, the current staff were unable to demonstrate former employees dedicated the necessary time and resources to reconciling time charged to the program and ensuring it was supported with time-and-effort documentation. Effect of Condition and Questioned Costs The District did not obtain time-and-effort documentation for 19 employees whose payroll and benefit costs totaling $1,415,509 it charged to the program. Without adequate time-and-effort documentation, the District cannot demonstrate compliance with the awarding agency’s documentation requirements to support costs charged to federal programs. Further, the District cannot assure federal grantors that payroll costs it charged to the program were accurate and valid. Federal regulations require the State Auditor’s Office to report known questioned costs that are greater than $25,000 for each type of compliance requirement. We question costs when we find the District does not have adequate documentation to support expenditures. Recommendation We recommend the District implement and follow internal controls to ensure it complies with federal and OSPI requirements for obtaining signed time-and-effort documentation timely. District’s Response The District acknowledges the finding and has implemented new procedures to ensure strong internal controls over time-and-effort documentation. This issue primarily occurred during a period of staff turnover. The District has since hired experienced personnel who are now overseeing federal program compliance. We have implemented a compliant time-and-effort tracking system consistent with OSPI and federal requirements. Documentation—whether semiannual certifications or monthly reports, as applicable—is collected, reviewed, and retained in accordance with the type of funding allocation. All documentation is reviewed by both the Business Office and program administrators to ensure accuracy. Monthly monitoring and required training for relevant staff are now embedded into our internal processes. The district is committed to ensuring accuracy and accountability in all federally funded programs. Auditor’s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to resolve this finding. We will review the corrective action taken during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction Addendum to Bulletin 048-17, Guidelines for Charging Employee Compensation to Federal Grants establishes requirements for documenting time-and-effort, including fixed schedule systems

Categories

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Other Findings in this Audit

  • 576168 2024-002
    Material Weakness
  • 576169 2024-002
    Material Weakness
  • 576170 2024-002
    Material Weakness
  • 576171 2024-002
    Material Weakness
  • 576172 2024-001
    Material Weakness
  • 576173 2024-001
    Material Weakness
  • 576174 2024-001
    Material Weakness
  • 576175 2024-003
    Significant Deficiency
  • 576176 2024-003
    Significant Deficiency
  • 576177 2024-003
    Significant Deficiency
  • 576178 2024-003
    Significant Deficiency
  • 576179 2024-003
    Significant Deficiency
  • 576180 2024-003
    Significant Deficiency
  • 576181 2024-003
    Significant Deficiency
  • 1152610 2024-002
    Material Weakness
  • 1152611 2024-002
    Material Weakness
  • 1152612 2024-002
    Material Weakness
  • 1152613 2024-002
    Material Weakness
  • 1152614 2024-001
    Material Weakness
  • 1152616 2024-001
    Material Weakness
  • 1152617 2024-003
    Significant Deficiency
  • 1152618 2024-003
    Significant Deficiency
  • 1152619 2024-003
    Significant Deficiency
  • 1152620 2024-003
    Significant Deficiency
  • 1152621 2024-003
    Significant Deficiency
  • 1152622 2024-003
    Significant Deficiency
  • 1152623 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education Grants to States $1.77M
10.553 School Breakfast Program $883,479
10.555 National School Lunch Program $258,119
84.425 Covid 19 - Education Stabilization Fund $191,184
84.011 Migrant Education State Grant Program $187,319
84.365 English Language Acquisition State Grants $151,711
10.582 Fresh Fruit and Vegetable Program $148,865
84.424 Student Support and Academic Enrichment Program $79,663
12.556 Competitive Grants: Promoting K-12 Student Achievement at Military-Connected Schools $65,666
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $50,000
84.048 Career and Technical Education -- Basic Grants to States $46,229
84.010 Title I Grants to Local Educational Agencies $26,335
10.559 Summer Food Service Program for Children $20,700
84.173 Special Education Preschool Grants $10,000
15.237 Rangeland Resource Management $48