Finding 1187253 (2024-006)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2024
Accepted
2026-03-26
Audit: 394853
Organization: Town of Brookline (MA)
Auditor: CBIZ CPAS PC

AI Summary

  • Core Issue: Lack of proper documentation for time and effort related to federal grant salaries, with 28 out of 40 payroll selections missing required support.
  • Impacted Requirements: Compliance with Uniform Guidance (2 CFR § 200.430) regarding allowable costs and necessary documentation for federal grants.
  • Recommended Follow-Up: Implement strict procedures to ensure all employees maintain and retain time and effort documentation, including timesheets and certifications, to prevent unallowable costs.

Finding Text

Finding 2024-006: Improve Documentation and Controls over Allowable Costs Federal Program(s) Information Federal Agency: Department of Education Cluster/Program: Special Education Cluster Award Name: Special Education Grants to States and Special Education Preschool Grants Assistance Listing Number: 84.027/84.173 Award Year: 2024 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding - Compliance Internal Control over Compliance – Material Weakness Criteria or Specific Requirement Per Uniform Guidance (2 CFR § 200.430), charges to federal grants for salaries and wages must be based on records that accurately reflect the work performed. Time and effort documentation—such as personnel activity reports, after-the-fact certifications, or properly maintained timesheets for hourly employees—must support that the amount charged to the grant is allocable and appropriate. Condition and Context Of the 40 payroll selections tested for the Special Education Cluster, 28 lacked required time and effort documentation to support the time worked on the grant. In addition, for 21 hourly employees, timesheets were not maintained, preventing verification that only hours spent on grant functions were charged to the grants. Cause The Town did not have effective controls in place to ensure required time and effort documentation and timesheets were completed and retained for all employees whose salaries or wages were charged, in whole or in part, to federal grant programs. Effect or Potential Effect Lack of proper time and effort support and failure to maintain timesheets for hourly employees increases the risk of unallowable or unsupported costs being charged to the grants, resulting in material noncompliance and the potential for disallowed costs. Questioned costs are reported as follows: AL Number(s): Name of Federal Program or Cluster Questioned Costs 84.027/84.173 Special Education Cluster $1,251,490 Recommendation The Town should implement and enforce procedures to ensure all employees whose salaries or wages are charged to federal grants maintain and retain appropriate time and effort documentation, including timesheets for hourly staff and semi-annual certifications for salaried staff, in compliance with Uniform Guidance. Views of Responsible Official See corrective action plan included herein.

Corrective Action Plan

Audit Finding Reference: 2024-006 Improve Documentation and Controls over Allowable Costs Planned Corrective Action: The Town will implement and enforce procedures to ensure all employees whose salaries or wages are charged to federal grants maintain and retain appropriate time and effort documentation, including timesheets for hourly staff and semi-annual certifications for salaried staff, in compliance with Uniform Guidance. Management has made staff aware of the Time and Effort reporting requirements associated with Federal grants and will work with grant managers and finance department staff to ensure this requirement is implemented during Fiscal 2026; on or about March 18th.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1187242 2024-005
    Material Weakness Repeat
  • 1187243 2024-005
    Material Weakness Repeat
  • 1187244 2024-005
    Material Weakness Repeat
  • 1187245 2024-005
    Material Weakness Repeat
  • 1187246 2024-005
    Material Weakness Repeat
  • 1187247 2024-005
    Material Weakness Repeat
  • 1187248 2024-006
    Material Weakness Repeat
  • 1187249 2024-006
    Material Weakness Repeat
  • 1187250 2024-006
    Material Weakness Repeat
  • 1187251 2024-006
    Material Weakness Repeat
  • 1187252 2024-006
    Material Weakness Repeat
  • 1187254 2024-003
    Material Weakness Repeat
  • 1187255 2024-003
    Material Weakness Repeat
  • 1187256 2024-004
    Material Weakness Repeat
  • 1187257 2024-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.21M
10.555 NATIONAL SCHOOL LUNCH PROGRAM $786,838
84.425 EDUCATION STABILIZATION FUND - ESSER II $295,682
97.067 HOMELAND SECURITY GRANT PROGRAM $270,936
10.555 COVID-19 NATIONAL SCHOOL LUNCH PROGRAM $200,177
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $182,106
97.036 COVID-19 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $156,987
84.027 SPECIAL EDUCATION GRANTS TO STATES $149,793
10.553 SCHOOL BREAKFAST PROGRAM $98,513
84.027 COVID-19 SPECIAL EDUCATION GRANTS TO STATES $70,853
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $65,619
84.425 EDUCATION STABILIZATION FUND - ESSER III $60,562
20.513 ENHANCED MOBILITY OF SENIORS AND INDIVIDUALS WITH DISABILITIES $44,307
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $40,608
84.425 EDUCATION STABILIZATION FUND - SUMMER LEARNING GRANT $40,490
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $26,433
97.044 ASSISTANCE TO FIREFIGHTERS GRANT $26,008
84.425 EDUCATION STABILIZATION FUND - SEL & MENTAL HEALTH GRANT $20,800
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $20,499
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $12,383
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $11,930
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $10,683
84.425 EDUCATION STABILIZATION FUND - CHRONIC ABSENTEEISM FUNDS $9,042
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $8,945
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $7,631
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $4,702
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $2,139
93.008 MEDICAL RESERVE CORPS SMALL GRANT PROGRAM $1,333
84.173 COVID-19 SPECIAL EDUCATION PRESCHOOL GRANTS $943
20.616 NATIONAL PRIORITY SAFETY PROGRAMS $725
84.126 REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES $110