Finding 1169244 (2025-001)

1. Immediate Compliance Review and Documentation Grants Accounting & Grants Development and Compliance (GDC) will conduct a comprehensive review of the five HEIA grants renewed for FY2026: • Verify each employee's current compensation source (institutional vs. grant funds) • Calculate the correct grant-funded compensation based on Level of Effort percentages • Determine the period of noncompliance for each grant • Document total amount of personnel costs that should have been charged to grants • Make adjusting entries in FY2026 as needed 2. Transition Personnel to Grant-Funded Payroll (if required) Grants Accounting will work with the Program Team to: • Establish split-funding arrangements for each affected employee based on their Level of Effort • Update payroll accounting codes to properly charge personnel costs to grant accounts • Ensure proper fund availability and budget alignment 3. Review Time and Effort Reporting Procedures and Update (if necessary) Establish compliant time and effort documentation as required by 2 CFR 200.430: • For employees working solely on one grant (100% effort): Implement semi-annual certification • For employees on multiple cost objectives: Review time and effort documentation to ensure proper payroll allocation; correct as needed • Re-train all affected personnel on time and effort reporting requirements • Establish quarterly review process to ensure accurate reporting 4. Budget Realignment and Prior Approval Requests For each affected grant: • Review current budget vs. actual expenditures • Determine if budget modifications are needed to accommodate personnel costs • Submit prior approval requests to Department of Education if required (2 CFR 200.308) • Coordinate with program officers for each grant as needed 5. Policy and Procedure Updates Develop and implement enhanced procedures to prevent recurrence: • Update standard operating procedures for setting up grant-funded positions • Establish pre-award checklist requiring coordination between Grants Office and HR • Implement quarterly reconciliation between GAN key personnel and actual payroll charges • Require GDC to sign-off on all personnel appointments for grant-funded positions • Update training and grant orientation information as needed 6. Training and Communication Provide comprehensive training to: • All current Project Directors/Managers on federal grant personnel requirements • HR staff on grant-funded position management • Grants Accounting staff on proper cost allocation and monitoring • Department chairs/supervisors who oversee grant-funded personnel 7. Ongoing Monitoring and Quality Assurance Implement enhanced monitoring procedures: • Monthly reconciliation of GAN key personnel vs. actual grant charges • Quarterly review of time and effort reports for completeness and accuracy • Annual internal review of grant personnel compliance 8. Communication with Federal Agencies As appropriate: • Submit required modifications or amendments to grant agreements • Provide documentation of compliance restoration