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2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. Criteria: 2 CFR ?200.430(i)(1)(vii) Standards for Documentation of Personnel Expenses (1) Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.