Finding Text
2023-001 – Significant Deficiency and Nonmaterial Noncompliance – Allowable Costs and Activities Program: Title I Grants to Local Educational Agencies (ALN 84.010) – United States Department of Education – Virginia Department of Education; Federal Award Year: 2023. Criteria: Office of Management and Budget's (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subtitle A, Chapter II, Part 200, Subpart E – Cost Principles subsection 200.430 – Compensation – Personal Services subsection (i) – Standards for Documentation of Personnel Expenses subsection (1) states: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vi) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two (2) or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: For a sample of forty (40) payroll and forty (40) non-payroll transactions, grant management could not provide certifications of time incurred and charged to the grant for two (2) employees. Cause: Employees and supervisors did not adhere to School Board time certification policies and procedures. Effect: Time incurred by personnel could be incorrectly allocated to federal programs. Questioned Costs: Two (2) grant charged employees approximating $6,400, from a sample population approximating $132,000. Recommendation: Employees charging time to a grant should have approved timesheets/records prior to payroll certification and processing. Views of Responsible Officials and Planned Corrective Action: Weekly staffing reports are sent to the locations for administrators to identify employees assigned to their location. Title 1 Grant Manager is sent a monthly personnel report that identifies all employees coded to Title 1 by location. There is a semi-annual in-person staff validation process. The team includes the enrollment and planning, Talent, and Budget Departments. The grants team will schedule standing meetings (biweekly) with the grant manager, accountant, and the Director of Budget to ensure all payroll is correct as it relates to Title I Part A. This will begin immediately following the next pay period. When discrepancies are identified, the Title 1 Grant Accountant will prepare an journal entry to move the payroll charges out of the Title 1 fund to the correct fund by journal entry