FINDING # 2022-003 (REPEAT FINDING OF 2021-003) U.S. Department of Education ? Passed-through the NYS Education Department Special Education Grants to States (IDEA, Part B); CFDA No. 84.027; Project #0032-22-0778; Grant Period ? Fiscal Year Ended June 30, 2022 Special Education Preschool Grants (IDEA Preschool); CFDA No. 84.173; Project #0033-22-0778; Grant Period ? Fiscal Year Ended June 30, 2022 Significant Deficiency Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: According to Uniform Guidance Section 200.430 Compensation - Personal Services, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must comply with the established written accounting policies and practices of the District, and support the distribution of salaries and wages among specific activities or cost objectives while reasonably reflecting the total activity for which the employee is compensated. Condition: Although the District ultimately obtained Payroll Certification Forms from the employees funded through these federal funds, they did not comply with their written procedures regarding the timeliness of obtaining signed Payroll Certification Forms from employees whose salaries were funded through federal funds. Cause: The District did not take timely action to obtain Payroll Certification Forms from employees whose salaries were funded through federal funds. Effect: The salaries for employees who worked on the grant were not properly supported to be in compliance with the District?s written procedures and the Uniform Guidance. Questioned Costs: None. Recommendation: We recommend the District comply with their written policies and procedures to be in compliance with the Uniform Guidance. District?s Response: The District?s response is included in their corrective plan. FINDING #2021-003 According to Uniform Guidance Section 200.430 Compensation ? Personal Services, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must comply with the established written accounting policies and practices of the District, and support the distribution of salaries and wages among specific activities or cost objectives while reasonably reflecting the total activity for which the employee is compensated. The District did not obtain Payroll Certification Forms from the employees funded through these federal funds and thus, they did not comply with their written procedures regarding obtaining signed Payroll Certification Forms from employees whose salaries were funded through federal funds. We recommended the District comply with their written policies and procedures to be in compliance with the Uniform Guidance. STATUS: Not Implemented DISTRICT?S RESPONSE East Ramapo Central School District Office of Funded Programs (OFP) has reviewed and revised their standards for the documentation of Personnel Expenses to ensure payroll certification forms are prepared in a timely and accurate manner. These procedures adhere to the Uniform Guidance Section 200.430. The OFP Accountant, Renee Vaughan, will establish an internal database to record all employees whose salaries are fully or partially supported with Federal funds. Initial records will be based on Budget estimates derived during the FS-10 process. Upon Approval of a Federal Grant, the OFP Accountant will generate from the internal database, (1) a report with a list of employees whose salaries are fully or partially supported with Federal funds and (2) Personnel Activity Report (PAR) forms for each employee. The OFP Accountant will also produce an informational sheet to accompany the PAR forms. This informational sheet will include a statement about the purpose of the PAR, monthly return-by dates, procedures for changes, etc. The same action will be taken when an employee starts or changes position within the Grant period. The OFP Assistant, Donna Tanner, will distribute these materials to the appropriate employees at the beginning of the grant year. When responses are received, the OFP Assistant will review the form for completion. Completed forms will be marked as such on the report list and returned to the OFP Accountant. Incomplete forms will be returned to the employee for completion. The OFP Assistant will continually follow-up with employees regarding forms not returned by the return-by dates established in the information sheet. Non-responsive PAR requests will be brought to the attention of the Superintendent and the Office of Personnel. The OFP will keep physical and or digital record of each signed PAR. The OFP Accountant will track the completion of forms in the internal database, as well as record any changes in the internal database. Any changes to allocations will prompt the creation and distribution of a new PAR form. At the end of each quarter, OFP Accountant will provide a detailed PAR report to the OFP Executive Director, Dr. Daniel Shanahan. This procedure was initiated in November 2022 and continues to be in effect presently.