Finding Text
Finding 2022-002 ? Allowable Costs and Allowable Activates ? Absence of Records in support of Personal Costs charged to federal programs (Material Weakness) U.S. Department of Education Elementary and Secondary School Emergency Relief Fund (Federal Assistance Listing #84.425) Federal: Federal Award Year: 2021-2022 Criteria: Per 2 CFR ?200.430, Compensation - personal services, (i) 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. Among other requirements, these records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? 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; and, ? 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. Condition: For this program, there was no evidence that actual employee time was tracked, reviewed and approved, or that the actual time incurred was used as a basis for allocating personnel charges to the federal grant. Cause: Current policies and procedures of the Charter School do not require documented timekeeping by employees who worked on the grant program, and therefore, there as no documentation that such time had been appropriately reviewed and approved, prior to being charged to the grant. Effect: Personnel costs charged to federal awards without appropriate documentation may be subject to disallowance. Questioned Costs: $14,160 Context: For our direct labor allowable costs sample, The Charter School?s management indicated that all 40 expenditure selections, totaling $14,160, were charged to the grant based on visual check ins by the operating manager onsite of the employees who conducted the related afterschool activities associated with the grant. This finding appears to be a systemic problem and that the total population which could be subject to similar questioned costs is $171,140. There was no further documentation available for our review and inspection, such as time sheets with employee or supervisor signatures, which would provide support that employees were present at the time frames paid for their services. Identified as a Repeat Finding: No. Recommendation: We recommend that the Charter School implement polices and training to staff in order to gain an understanding of the uniform guidance compliance requirements. Views of Responsible Officials: See management?s response and corrective action plan.