Finding Text
U.S. DEPARTMENT OF EDUCATION
Passed through Massachusetts Department of Elementary and Secondary Education
Special Education Cluster #84.027, 84.173
Title I #84.010
Education Stabilization Fund #84.425
2023-001: Controls for Monitoring Payroll Charged to the Grant
Compliance Requirement: Allowable Costs/Cost Principles
Type of Finding: Compliance and Internal Control Over Compliance – Other Matter
Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles.
Condition: Payroll expenditures charged to the grants are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not completed for each employee charged out of the grant for fiscal year 2023.
Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments.
Effect: The City has not complied with the federal and state time and effort reporting requirements.
Cause: Turnover in the grant manager role led to time and effort documentation not being completed for fiscal year 2023. Management should follow their written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required.
Questioned Costs: Total payroll costs charged to the grants in 2023 was as follows: (see table) Recommendation: The City should follow their written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should ensure the standardized forms are approved by the individual in charge of the grant and overseen by grant management personnel. This will ensure compliance is not impacted by employee turnover in the future.
Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin collecting the time and effort documentation for the impacted grans for the current fiscal year (FY24) and into future periods as required.