Finding Text
FINDING #2023-007: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000)
Assistance Listing Number and Title: 84.010 ‐ ESEA (ESSA): Schoolwide Programs (SWP)
Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education
Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires
an accounting for personnel time on multi‐funded positions by the time spent on each program and to semi‐annually
certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges
to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These
records must:
• Be supported by a system of internal control which provides reasonable assurance that the charges are
accurate, allowable, and properly allocated;
• Be incorporated into the official records of the non‐Federal entity
• Reasonably reflect the total activity for which the employee is compensated by the non‐Federal entity, not
exceeding 100% of compensated activities
• 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;
• Comply with the established accounting policies and practices of the non‐Federal entity.
• 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 (i.e., estimates determined before the services are performed) alone do not qualify as
support for charges to Federal awards but may be used for interim accounting purposes.
Condition: Auditor selected employees with salaries coded to the federal programs noted above. The following
deficiencies were noted:
• ESEA (ESSA): Schoolwide Programs (SWP) (Resource 3150): 2/60 employees tested with salaries coded to
the program during the fiscal year did not have time certifications on file for the 2022-23 year.
Cause: The District has not been following its policy for proper time accounting.
Effect: The District is not in compliance.
Questioned Costs: Although the District was not in compliance, we were able to review alternative documentation
to determine that employees charged to the program were allowable.
Repeat Finding: This is a repeat finding, see prior year finding #2022-008.
Recommendation: We recommend that the District prepares time certification semi‐annually for single funded
employees and monthly for multi-funded employees.
Views of Responsible Officials: See Corrective Action Plan on following page.