Finding Text
Finding 2023-009: Time Accounting (50000)
Program Identification:
Federal Agency: U.S. Department of Education
Pass‐through Entity: California Department of Education Program Names: Title I, Part A Grants:
Title I, Part A, Basic Grants Local-Income and Neglected (AL No. 84.010) ESEA, School Improvement
Grant Funding for LEAs (AL No. 84.010)
Program Names: Education Stabilization Funds:
Elementary and Secondary School Emergency Relief II Fund (AL No. 84.425) Elementary and Secondary
School Emergency Relief III Fund (AL No. 84.425) Expand Learning Opportunities Grant ESSER II State
Reserve (AL No. 84.425)
Criteria: 2 CFR, section 200.430 states, in part: (i) 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. These records must: (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; 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.
2 CFR, section 200.303 states, in part: The non-Federal entity must: (a) 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.
CSAM Procedure 905 states, in part: Periodic (Semiannual) Certification Employees who work solely
on a single federal award or cost objective need only complete a periodic certification. The
periodic certification must:
• Be prepared at least semiannually.
• Be signed by the employee or the supervisory official having firsthand knowledge of the work
performed by the employee.
• State the employee worked solely on that single federal program or cost objective during the
period covered by the certification.
Where multiple employees work on the same cost objective, a blanket certification may be used as
the documentation for all employees who worked on the cost objective.
Personnel Activity Report
Except as provided in “Substitute Systems for Time Accounting” … employees who work on multiple
activities or cost objectives of which at least one is federal must complete a
personnel activity report (PAR) or equivalent documentation.
A PAR may be as detailed as a document that identifies the employee’s activity daily by hours, or
it may be as simple as a report of the total hours or percentage of hours spent in each categorical
program or cost objective. The level of detail can generally be determined by the diversity and
variation of the employee’s work activities. The safest approach is to provide more documentation
rather than less.
Condition: The District lacks procedures and controls to ensure that employees being funded from
federal funds complete their personal activity reports monthly as well as ensuring semi-annual time
certifications are completed in
a timely manner.
Context: Our total sample consisted of 44 employees, and for all 44 employees it took the District
months to provide time accounting documentation. In some instances, the District had to
go back and prepare the time accounting documentation, because some of the employees sampled
were no longer employed by the District.
Questioned Costs: No questioned costs.
Cause: District lacks adequate controls to ensure that time certification documentation is prepared
and maintained to support all employees who are paid with federal funds.
Effect: Lack of proper controls to ensure that time certification documentation is prepared may
result in the District having to go back and recreate documentation for individuals who are no
longer employed by the District. In addition, lack of time documentation may result in a questioned
cost.
Recommendation: We recommend that the District comply with 2 CFR, section 200.303, and CSAM
Procedure 905, which require that employee time certification forms be maintained for employees who
charge time to federal program.
Views of Responsible Officials: The State and Federal Programs Department at the recommendation of
FPM began Time and Effort Procedures training on December 6, 2023, with the Office Managers and
Administrative Secretaries to emphasize the critical importance of accurate time certification
records for federal fund expenditures.
In addition, the State and Federal Programs (SFP) Department and Budget Department are
collaborating on identifying the Employees charged to Title I. Currently the Employee list for July
2023- December 2023 have been provided to SFP by the Budget Department. SFP has sent the Time and
Effort forms to the Departments: Leads, Office Managers with a deadline for collection in January.
The district commits to collecting semi-annual time and effort documentation
within 10 business days of when the effort window closes.