Finding 1152621 (2024-003)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2024
Accepted
2025-09-11

AI Summary

  • Core Issue: The District lacked effective internal controls for time-and-effort documentation, leading to unsupported payroll costs of $47,853 charged to federal programs.
  • Impacted Requirements: Federal regulations mandate that all payroll costs must be backed by proper time-and-effort documentation to ensure compliance with funding requirements.
  • Recommended Follow-Up: The District should implement robust internal controls to secure timely signed time-and-effort documentation and ensure all journal entries are properly supported and reviewed.

Finding Text

The District did not have adequate internal controls for ensuring compliance with time-and-effort requirements. Assistance Listing Number and Title: 84.425 – COVID-19 – Educational Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: Pass-through Entity Name: Office of the Superintendent of Public Instruction (OSPI) Pass-through Award/Contract Number: 84.425D-CEP Supp ESSER; 84.425U-138288; 84.425U-142142; 84.425U-145312; 84.425U-145823; 84.425V-6109; 84.425W-459563 Known Questioned Cost Amount: $47,853 Prior Year Audit Finding: N/A Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2024, the District spent a total of $10,463,256 of its ESF awards. This included $191,184 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D), $10,099,901 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U), $114,781 in the American Rescue Plan – Emergency Assistance to Non-Public Schools (ARP EANS/EANS II) subprogram (84.425V) and $57,390 in the American Rescue Plan Elementary and Secondary School Emergency Relief – Homeless Children and Youth (ARP-HCY) subprogram (84.425W). 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. Federal regulations also establish principles and standards for determining allowable direct and indirect costs for federal awards. Additionally, federal regulations and the Office of Superintendent of Public Instruction (OSPI) require all costs charged to the program to comply with program requirements and recipients to support this compliance with proper documentation that demonstrates costs are allowable. The District is also responsible for ensuring it supports all payroll costs charged 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 the work is completed. 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 OSPI require. Our audit found the District transferred $47,853 of salary and benefit amounts to its ESSER III (84.425U) award that were originally coded to other local, state and federal programs, resulting in employees being charged to multiple federal programs without appropriate time-and-effort documentation. We consider this internal control deficiency to be a significant deficiency. Cause of Condition The District experienced turnover in the key position responsible for managing the program. As a result, the current staff were unable to find any documentation showing time-and-effort had been collected. Effect of Condition and Questioned Costs Using a statistical sample of all journal entry transactions that included both accounts payable and payroll disbursements, we found nine out of 29 transactions we tested had exceptions. Those exceptions were related to salaries and benefits totaling $47,853 that were not supported by time-and-effort documentation. Based on the projection of our sample, we identified an additional $651,791 in estimated unsupported costs. 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 and likely questioned costs that are more 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 this finding and has taken steps to address all time-andeffort documentation issues. New procedures are now in place, including formal time-and-effort tracking using the appropriate method—semiannual or monthly— based on program guidelines and funding structure. The District has also implemented a policy that requires all journal entries to include supporting documentation. Each journal entry is reviewed and approved by multiple staff, including Business Office staff and program directors, before posting. These safeguards will ensure accountability, prevent future exceptions, and maintain public trust. 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, section 403, Factors affecting allowability of costs, describes the cost principles for how direct and indirect costs should be charged to federal programs. 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 Internal Control / Segregation of Duties

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
  • 1152615 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
  • 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