Finding 34012 (2022-003)

Significant Deficiency Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2022
Accepted
2023-09-10

AI Summary

  • Core Issue: There are significant deficiencies in internal controls over compliance with federal funding requirements, particularly regarding payroll documentation and allocation.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a) and 2 CFR 200.430(i) is necessary to ensure that federal awards are used for allowable costs and properly documented.
  • Recommended Follow-Up: Management should establish improved procedures and controls to ensure compliance with federal requirements and prevent repeat findings.

Finding Text

2022-003 Department of Education and Passed through State of South Dakota Department of Education Federal Financial Assistance Listing #84.425C, 2021G-798, 03/13/2020 ? 09/30/2022 COVID-19 Education Stabilization Fund - Governor?s Emergency Education Relief (GEER) Fund Federal Financial Assistance Listing #84.287C, 21-80064-22, 21-80064-23, 7/1/2021 ? 6/30/2022, 7/1/2022 ? 6/30/2023 Twenty-First Century Community Learning Centers Program Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Criteria: The Organization is required to have procedures in place to ensure that federal awards are expended only for allowable costs in accordance with Subpart E ? Cost Principles of the Uniform Guidance. Allowable costs are supported by appropriate documentation and correctly charged as to account, amount, and period. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.430(i) establishes the standards for documentation of personnel expenses including charges to Federal awards for salaries and wages. Charges must be based on records that accurately reflect the work performed with the records meeting the following standards: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. b) Be incorporated into the official records of the non-Federal entity. c) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities. d) Encompass both federally 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. e) Comply with the established accounting policies and practices of the non-Federal entity. f) Support the distribution of the employee?s salary or wages among specific activities or cost objectives. g) Budget estimates alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes. Condition: The amount of payroll taxes allocated to the GEER program exceeded the amount of payroll taxes actually paid for two of two employees tested. Additionally, one instance in which an employee?s overtime hours was not charged to the Twenty First Century Program. Lastly, one instance in which one employee?s biweekly wages were not charged to the Twenty First Century Program. Cause: Tracking of grant-related payroll is a manual process which increases the likelihood of error. Effect: Payroll and related costs were not properly reported by an insignificant amount. Questioned Costs: None reported Context: For the GEER program, a non-statistical sample of 6 employees were selected for testing of approximately 17 total employees whose time was charged to the federal award. The 6 employees selected for testing accounted for $53,784 of the $146,073 payroll costs charged to the federal award in the fiscal year. For the Twenty First Century Community Learning Centers Program, a non-statistical sample of 60 expenditures were selected for testing, including 56 payroll transactions and 4 nonpayroll transactions. The 56 payroll transactions accounted for $35,585 of $213,359 total payroll costs charged to the federal award. Repeat Finding from Prior Year: Yes, prior year finding 2021-003 Recommendation: We recommend management implement procedures and control processes to comply with the federal requirements noted above. Views of Responsible Officials: Management is in agreement.

Corrective Action Plan

Finding 2022-003 Federal Agency Name: Department of Education and Passed through State of South Dakota Department of Education Program Names: COVID-19 Education Stabilization Fund- Governor?s Emergency Education Relief (GEER) Fund and Twenty-First Century Community Learning Centers Program FFAL # 84.425C and 84.287C Finding Summary: The amount of payroll taxes allocated to the GEER program exceeded the amount of payroll taxes actually paid for two of two employees tested. Additionally, one instance in which an employee?s overtime hours was not charged to the Twenty First Century Program. Lastly, one instance in which one employee?s biweekly wages were not charged to the Twenty First Century Program. Responsible Individuals: Scott Hupke CFO Corrective Action Plan: We have added an additional person in the review of the manual process for accuracy and to eliminate the errors. We will also continue to explore ways to automate the process from our payroll provider to the accounting software. Anticipated Completion Date: October 2022 for the manual process review and ongoing for the ways to automate the process.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 34013 2022-003
    Significant Deficiency Repeat
  • 34014 2022-004
    Significant Deficiency Repeat
  • 610454 2022-003
    Significant Deficiency Repeat
  • 610455 2022-003
    Significant Deficiency Repeat
  • 610456 2022-004
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $352,927
84.287 Twenty-First Century Community Learning Centers $256,159
10.555 National School Lunch Program $199,739
93.575 Child Care and Development Block Grant $171,480
16.726 Juvenile Mentoring Program $35,598
93.235 Affordable Care Act (aca) Abstinence Education Program $2,868