Finding Text
Finding 2023-001: Time and Effort Requirements (50000)
Assistance Listing No. 84.425 – Education Stabilization Funds (ESSER)
U.S. Department of Treasury
Passed through California Department of Education
Criteria: To support salaries and wages for employees that work on federal programs, local educational agencies (LEAs) are required to maintain time and effort records that accurately reflect the work performed. These time and effort records must: (1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (2) be incorporated into the official records of the LEA; (3) reasonably reflect the total activity for which the employee is compensated by the LEA, not exceeding 100% of compensated activities; (4) encompass both federally assisted and all other activities compensated by the LEA on an integrated basis, but may include the use of subsidiary records as defined in the LEA’s written policy; (5) comply with the established accounting policies and practices of the LEA; and (6) 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; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Budget estimates or percentages determined before the services are performed alone do not qualify as support for charges to Federal awards.
Condition: The LEA failed to provide all the time and effort documentation that the California Department of Education (CDE) requested to support salaries and benefits charged to the Federal Stimulus funds.
Cause: The LEA did not have sufficient time and effort procedures to ensure that their records were supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Specifically, the LEA’s procedures did not include controls to ensure that time and effort records include cost objectives, and account for the total activity for which the employee is compensated by the LEA as required by federal regulations.
Effect: The LEA must upload into the CDE Monitoring Tool (CMT) documentation to support the $510,311.76 in salaries and benefits charged to ESSER II and ESSER III funds.
Questioned Costs: The LEA did not provide documentation for $510,311.76 charged to ESSER programs. Specifically, the LEA failed to provide sufficient documentation to support $164,012.89 in salaries charged to ESSER II - Resource 3212 as well as $301,103.34 in salaries charged to ESSER III – Resource 3213.
Context: The finding was the result of Federal Program Monitoring (FPM) procedures performed by the CDE. Auditors sampled 21 employees during the FPM audit.
Recommendation: The County has already cleared this finding with CDE. No further action is needed.
Views of Responsible Officials: The County has already cleared this finding with CDE. In addition, we have updated the new time and effort policy and offered training to agency-wide members.