FAC Explorer

Finding 37564 (2022-004)

Material Weakness
Requirement
AB
Questioned Costs
$1
Year
2022
Accepted
2023-03-29
Audit: 32371
Organization: City of Boston (MA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: The City of Boston Public Schools failed to provide adequate documentation for payroll costs, with 30% of sampled transactions lacking completed timesheets.
  • Impacted Requirements: This non-compliance violates 2 CFR 200.430(i)(1), which mandates accurate records for salaries and wages charged to federal programs.
  • Recommended Follow-Up: Implement new control procedures to ensure all payroll costs are properly documented, and utilize the updated Google Form process for time reporting.

Finding Text

Finding number: 2022 004 Federal agency: U.S. Department of Education Pass through agency: Massachusetts Department of Elementary and Secondary Education Program: COVID-19 Education Stabilization Fund ALN #: 84.425D Award number: 115 511413 2022 0035 Award year: July 30, 2021 to September 30, 2023 Finding: Internal Control and Compliance over Payroll Costs Prior Year Finding: No Type of Finding: Material Weakness Criteria In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities; (iv) 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; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) 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. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award 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 During our testing of allowable costs associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, as well as weekly time and effort reporting worksheets. The timesheets are then reviewed by each employee?s supervisor and the worksheets are reviewed by the Department Head or designee, ensuring appropriates salary and wage distribution. However, for our sample of 40 payroll transactions charged to the program, 12 transactions were not supported by a completed timesheet. Cause This appears to be due to an insufficient system for collecting, filing and maintaining supporting documentation for payroll transactions charged to Federal programs. Effect BPS is not in compliance with 2 CFR 200.430(i)(1) regarding documentation in support of salaries and wages charge to the federal program. The number of transactions that were not supported by a time sheet represent 30% of the selected population and indicate a systemic problem. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: Questioned costs of $41,281, for unsupported payroll charges, were charged to ALN # 84.425, Award No. 115 511413 2022 0035. Recommendation We recommend that BPS implement control procedures to ensure that all payroll costs charged to the federal program are supported by documentation as required by 2 CFR 200.430(i)(1). View of Responsible Officials from the Auditee The District will revert back to the previously approved Google Form process for daily sign in and sign out procedures. This form is authenticated through IT and managed in a centralized repository making it easier to recall data for auditing and validate for weekly time reporting. The District created a new office of Compliance and Risk Management. The office will audit and review the established process quarterly to ensure integrity of the process.

Corrective Action Plan

Boston Public Schools (BPS) will revert back to the previously approved Google Form process for daily sign-in and sign-out procedures. This form is authenticated through IT and managed in a centralized repository making it easier to recall data for auditing and validate for weekly time reporting. BPS created a new office of Compliance and Risk Management. The office will audit and review the established process quarterly to ensure integrity of the process. Anticipated Completion Date: June 30, 2023 Responsible Contact Person: Scott Finn, Assistant City Auditor, Grants Monitoring Unit scott.finn@boston.gov

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 37561 2022-001
    Material Weakness
  • 37562 2022-002
    Significant Deficiency
  • 37563 2022-003
    Material Weakness Repeat
  • 37565 2022-005
    Significant Deficiency
  • 37566 2022-006
    Significant Deficiency
  • 37567 2022-005
    Significant Deficiency
  • 37568 2022-006
    Significant Deficiency
  • 37569 2022-005
    Significant Deficiency
  • 37570 2022-006
    Significant Deficiency
  • 37571 2022-005
    Significant Deficiency
  • 37572 2022-006
    Significant Deficiency
  • 37573 2022-005
    Significant Deficiency
  • 37574 2022-006
    Significant Deficiency
  • 37575 2022-007
    Significant Deficiency
  • 614003 2022-001
    Material Weakness
  • 614004 2022-002
    Significant Deficiency
  • 614005 2022-003
    Material Weakness Repeat
  • 614006 2022-004
    Material Weakness
  • 614007 2022-005
    Significant Deficiency
  • 614008 2022-006
    Significant Deficiency
  • 614009 2022-005
    Significant Deficiency
  • 614010 2022-006
    Significant Deficiency
  • 614011 2022-005
    Significant Deficiency
  • 614012 2022-006
    Significant Deficiency
  • 614013 2022-005
    Significant Deficiency
  • 614014 2022-006
    Significant Deficiency
  • 614015 2022-005
    Significant Deficiency
  • 614016 2022-006
    Significant Deficiency
  • 614017 2022-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $141.16M
21.027 Coronavirus State and Local Fiscal Recovery Funds $90.35M
84.425 Education Stabilization Fund $52.13M
21.019 Coronavirus Relief Fund $37.76M
84.010 Title I Grants to Local Educational Agencies $32.74M
10.555 National School Lunch Program $29.43M
14.267 Continuum of Care Program $29.00M
21.023 Emergency Rental Assistance Program $23.84M
84.027 Special Education_grants to States $19.37M
14.231 Emergency Solutions Grant Program $15.08M
97.067 Homeland Security Grant Program $10.22M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $4.43M
14.218 Community Development Block Grants/entitlement Grants $3.44M
84.367 Improving Teacher Quality State Grants $3.14M
14.889 Choice Neighborhoods Implementation Grants $2.50M
32.009 Emergency Connectivity Fund Program $2.42M
84.365 English Language Acquisition State Grants $2.15M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $2.14M
66.443 Reducing Lead in Drinking Water (sdwa 1459b) $1.91M
84.424 Student Support and Academic Enrichment Program $1.53M
93.053 Nutrition Services Incentive Program $1.46M
84.048 Career and Technical Education -- Basic Grants to States $1.29M
10.559 Summer Food Service Program for Children $1.15M
14.905 Lead Hazard Reduction Demonstration Grant Program $875,418
84.287 Twenty-First Century Community Learning Centers $798,800
84.173 Special Education_preschool Grants $705,763
10.582 Fresh Fruit and Vegetable Program $589,666
84.002 Adult Education - Basic Grants to States $493,394
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $461,145
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $434,221
16.034 Coronavirus Emergency Supplemental Funding Program $387,065
20.616 National Priority Safety Programs $330,000
16.738 Edward Byrne Memorial Justice Assistance Grant Program $327,657
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $327,115
97.111 Regional Catastrophic Preparedness Grant Program (rcpgp) $230,558
16.741 Dna Backlog Reduction Program $228,189
14.241 Housing Opportunities for Persons with Aids $198,525
94.016 Senior Companion Program $180,387
14.401 Fair Housing Assistance Program_state and Local $179,360
47.076 Education and Human Resources $178,788
14.248 Community Development Block Grants_section 108 Loan Guarantees $151,694
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $139,975
97.042 Emergency Management Performance Grants $136,689
94.002 Retired and Senior Volunteer Program $134,065
84.196 Education for Homeless Children and Youth $133,025
93.052 National Family Caregiver Support, Title Iii, Part E $128,466
97.106 Securing the Cities Program $117,605
16.588 Violence Against Women Formula Grants $116,980
16.820 Postconviction Testing of Dna Evidence to Exonerate the Innocent $115,958
16.838 Comprehensive Opioid Abuse Site-Based Program $99,654
10.649 Pandemic Ebt Administrative Costs $82,855
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $77,511
97.047 Pre-Disaster Mitigation $75,000
45.149 Promotion of the Humanities_division of Preservation and Access $64,064
12.900 Language Grant Program $62,353
45.301 Museums for America $58,423
16.817 Byrne Criminal Justice Innovation Program $54,978
97.044 Assistance to Firefighters Grant $31,952
97.039 Hazard Mitigation Grant $29,550
14.261 Homeless Management Information Systems Technical Assistance $25,333
45.024 Promotion of the Arts_grants to Organizations and Individuals $22,500
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $22,337
10.331 Food Insecurity Nutrition Incentive Grants Program $18,005
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $17,540
16.015 Missing Alzheimer's Disease Patient Assistance Program $12,177
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $9,776
16.833 National Sexual Assault Kit Initiative $9,758
14.U00 Brownsfields Economic Development Initiative $7,379
20.600 State and Community Highway Safety $5,364
93.763 Alzheimer?s Disease Initiative: Specialized Supportive Services Project (adi-Sss) Thru Prevention and Public Health Funds (pphf) $2,777
84.411 Investing in Innovation (i3) Fund $1,836
20.205 Highway Planning and Construction $1,634
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $1,529