Finding Text
Criteria: Federal cost principles, as identified in 2 CFR 200.430, require salaries allocated to more than one federal award activity or cost objective to be supported by records which accurately reflect the distribution of salary or wages. Budget estimates determined before the services are performed do not qualify as support for charges to the federal awards. Personnel activity reports are required when time is allocated between federal awards and cost objectives. Periodic certifications are required when an individual’s salary is charged solely to one federal award or cost objective. Condition: During our testing of compliance with the federal program, we noted that personnel activity reports to document time and effort were not completed for individuals whose salaries were allocated to one single federal award activity and the District’s General Fund. Additionally, individuals charged solely to one federal award activity and cost objective did not complete periodic certifications. Questioned costs: None. Context: Of the District’s payroll charges related to the major programs during fiscal year 2024, we haphazardly selected 31 individual charges from the bi-weekly payroll periods. All employees charged to the grants were selected for testing at least once with the sample representing $91,454 of $547,102 in payroll related charges. During the examination of charges, we noted two instances where an individual who is charged 30% to the Special Education Cluster (IDEA and Preschool) and 70% to the District’s General Fund, did not have a monthly personnel activity report completed and one instance where an individual was charged 100% to the IDEA federal program did not have a semi-annual certification completed. Effect or potential effect: Failure to adequately document personnel activity in accordance with the requirements of the Code of Federal Regulations increases the risk that the District will request reimbursement for expenditures which were not related to employee time spent on the federal awards. Cause: For periodic certifications of time and effort, the District’s grant manager prepared the periodic certification forms for distribution to the employees. The certifications were not returned by the employees in the instances noted above. Recommendation: We recommend whenever an employee’s salary is allocated 100% to a federal award and single cost objective the District prepare, at a minimum, semi-annual certifications of time and effort. Additionally, when an employee’s salary is allocated to multiple federal awards or cost objectives the District should complete, at a minimum, monthly personnel activity reports showing the distribution of the employee’s time and effort. Any changes from the initial budgeted amounts written into the federal awards and actual time and effort as documented in the personnel activity reports must be adjusted such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Views of responsible officials: The Business Office is providing continued training to cost center managers. Throughout the summer we have had the Finance Manager training the Community Education administrative team and responsible grant managers to ensure compliance with the time and effort requirements.