Finding Text
Program Information
Federal Agency: U.S. Department of Education, Department of Health and Human Services
Federal Agency: Student Financial Assistance Cluster, Research and Development Cluster
Federal Programs: 84.033 Federal Work-Study Program, 93.243 Drug Abuse and Addiction Research Programs, and 93.855 Allergy and Infectious Diseases Research
Pass-through entity(ies): None
Federal Award Year: July 1, 2022 – June 30, 2023
Criteria or Requirement
Title 2, U.S. Code of Federal Regulations Part 200 (2 CRF 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award, (Subpart E, Section 200.403), requires that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed.
Per chapter 2, Volume 6, of the 2022-2023 Federal Student Aid Handbook, institutions must maintain adequate timesheets or records of hours worked for Federal Work Study (FWS) students. Students working for your school must have their timesheets certified by either their supervisor or an official at the school. Students working in off-campus jobs must have their timesheets certified by an official at the off-campus site
Title 200 part 2 CFR 200.303 states that the Institution, as a federal grant recipient, must “establish and maintain effective internal controls over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition found, including facts that support the deficiency identified in the finding and information to provide proper perspective for judging the prevalence and consequences of the finding
For 3 of 80 payroll transactions selected for testing, the engagement team identified that the timesheet did not contain evidence of approval by the supervisor/manager.
Cause and Possible Asserted Effect
The University did not have sufficient controls over approval of time worked. As a result, expenditures may be charged to federal grants for time that was not worked.
Identification of questioned costs and how they were computed
None
Sample statistically valid
The sample was not intended to be, and was not, a statistically valid sample.
Repeat Finding from prior year
The audit finding is not a repeat finding.
Recommendation
We recommend that the University strengthen its controls over timekeeping approvals of all employee timesheets, in order to ensure that payroll expenditures charged to the program are allowable.
Views on responsible officials
Pacific University acknowledges the importance of an effective control environment. The University’s policies do currently require approval of all timesheets; therefore, management will re-emphasize the
importance of this approval control, including review of supervisor compliance with this approval requirement, and follow-up with supervisors who may not be meeting requirements. Additionally, management will begin offering mandatory annual training for all supervisors overseeing Federal Work Study students.