Finding Text
Finding 2025-008 – Allowable Costs/Cost Principles and Matching, Level of Effort, and Earmarking Information on the federal program: Federal awarding agency: United States Department of Education (ED) Federal program: School Safely National Activities, Assistance Listing No. 84.184X Award year: 2024‐2025 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 requires that a non-federal entity must (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.430 (i) states “Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflected 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; (iv) encompass both federal 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.” Condition: The University did not have effective internal controls over the timely preparation and approval of employees’ time and effort certifications. Cause: The University did not execute their internal controls for the timely preparation and approval of employees’ time and effort certifications on a timely basis. Effect or potential effect: Unallowable and/or inaccurate payroll expenditures could be charged to the federal program due to the delay in the preparation and approval of the time and effort certifications. Level of effort per grant award notification and grant proposal documents may not be met as required for the applicable employees with level of effort requirements, the program director/principal investigator and co-investigators, for the School Safely National Activities Program. Questioned costs: None. Context: It is the University’s policy to have time and effort certifications prepared and approved for grant employees on a semesterly basis. For 9 of 14 payroll expenditures selected for testing, the University’s employees prepared their time and effort certifications between 4 and 10 months after the applicable semester ended, with approvals made after that time. The grant documents provide for level of effort requirements for the program for five employees, including the program director/principal investigator with a level of effort of 25% and 4 co-investigators with level of effort of 2.5%. The University’s total School Safely National Activities program expenditures were $1,310,305 for the year ended May 31, 2025. Of this amount, $209,270 related to payroll expenditures, including fringe benefits. Identification of a repeat finding: Not applicable. Recommendation: We recommend the University execute its internal controls to provide for the preparation and approval of employees’ time and effort certifications on a timely basis after the end of each semester. Views of responsible officials: Management agrees with the finding and has developed a corrective action plan in which the University updated the time and effort reporting form and the Grants Accounting Office will ensure the forms are completed timely. The corrective action was implemented by February 6, 2026.