Finding 1167556 (2025-001)

Finding 2025-001 – Allowable Costs Federal Award & Specific Award Identification U.S. Department of Education Passed through the New York State Department of Education Program Name: Migrant Education – State Grant Program Assistance Listing: 84.011 SIGNIFICANT DEFICIENCY Reporting Criteria The Office of Management and Budget (OMB) Uniform Guidance, specifically 2 CFR § 200.430(i), requires that charges for salaries and wages to federal awards be based on records that accurately reflect the work performed. For employees working on multiple activities, including federal and non-federal projects, time must be supported by Personal Activity Reports (PARs) or other equivalent documentation that accounts for 100% of the employees time. Statement of Condition During our audit, we selected a sample of personnel costs charged to the Migrant Education – State Grant Program. A review of these personnel files revealed that staff members who worked on multiple cost objectives did not have Personnel Activity Reports (PARs) or equivalent documentation. Cause The BOCES lacked adequate internal controls and documented procedures to ensure proper tracking and certification of time spent by employees working on multiple cost objectives. Effect The BOCES is in non-compliance with the Uniform Guidance. Uncertified salary expenses charged to the federal grant may be disallowed by the granting agency. Questioned Costs There were no questioned costs.Context The BOCES employees staff members who were not charged 100% to the grant did not have PARS or other certifications, that accounted for 100% of their time. There have been no previous instances of non-compliance. This is not a repeat finding. Recommendation We recommend that the BOCES establish and implement written policies and procedures for reporting time and effort in compliance with 2 CFR § 200.430. This process should include: •Requiring all employees working on multiple cost objectives to complete and certify PARs or equivalent documentation. •Ensure PARs account for 100% of the employee’s compensated time. •Mandating that PARs or other certifications be prepared and signed at least semi-annually (or monthly, depending on the employee’s schedule). •Reconciling reported time and effort to payroll records. View of Responsible Individuals The BOCES acknowledges that they did not meet the PARS requirement for the Migrant Education – State Grant Program.