Finding Text
2 CFR 200.430(a) states that compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits addressed in § 200.431. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the recipient or subrecipient consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with the recipient's or subrecipient's laws, rules, or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (g) of this section, when applicable. In addition, District Policy #6116 - Time and Effort Reporting states, in part, that Section 200.430 of the Code of Federal Regulations requires certification of effort to document salary expenses charged directly or indirectly against Federally-sponsored projects. This process is intended to verify that compensation for employment services, including salaries and wages, is allocable and properly expended, and that any variances from the budget are reconciled. Compensation for employment services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries. Compensation for personal services may also include fringe benefits, which are addressed in 2 C.F.R. 200.431 Compensation-fringe benefits. Costs of compensation are allowable to the extent that they satisfy the specific requirements of these regulations, and that the total compensation for individual employees: A. is reasonable for the services rendered, conforms to the District’s established written policy, and is consistently applied to both Federal and non-Federal activities; and B. follows an appointment made in accordance with the District’s written policies and meets the requirements of Federal statute, where applicable. Semi-annual certifications and time-and-effort documentation are used to support salary amounts charged to a federal program. Semi-annual certifications are allowed when an employee’s compensation is funded by only one federal grant. The School District did not complete semi-annual certifications or time-and-effort documentation for 3 employees tested that were charged to the Special Education Cluster AL #84.027/84.173 federal program for the period of July 2024 through June 2025. Failure to complete time and effort certifications after the time worked could lead to questioned costs being issued in future audits as well as possible reductions in future federal funding. The School District should establish and implement procedures to verify that all employees charging salaries and benefits to federal grants and completing semi-annual certifications, sign/certify the time spent on the grant subsequent to the time period worked.