Finding 44434 (2022-001)

Significant Deficiency Repeat Finding
Requirement
A
Questioned Costs
-
Year
2022
Accepted
2022-10-30
Audit: 44413
Organization: Goshen Central School District (NY)

AI Summary

  • Core Issue: The School District lacks adequate internal controls for timely employee certifications of time worked on federal grants, leading to potential compliance risks.
  • Impacted Requirements: Compliance with 2 CFR, Part 200.430(i)(1) regarding accurate time reporting and allocation of federal funds.
  • Recommended Follow-Up: Implement stronger internal controls to ensure timely completion of monthly or semiannual certifications for employees working on federal awards.

Finding Text

A. Finding on Internal Control over Compliance Finding Reference: 2022-001 Federal Agency: U.S. Department of Education Federal Program: IDEA ? Part B, Section 611 (84.027) IDEA ? Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a) Significant Deficiencies in Internal Control Over Compliance b) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(1) of the Office of Management and Budget?s Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, among other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity; d) Encompass both federally assisted and all other activities compensated by the non-Federal entity; e) Support the distribution of the employee?s salary or wages amount 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: Several of the District employees whose time was being charged to the grants but who were working less than 100% of the time in the federal award program, were required to complete monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely. Cause: The School District did not have adequate review procedures in place to ensure that the monthly certifications were being completed by each employee working in the federal award programs timely. Effect: Without adequate internal controls over the employee?s time being charged to the grant and the certification requirement, the School District cannot ensure that federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Identification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2021-001. Questioned Costs: The employees? certifications in questions were reviewed and after reviewing the allocation of each employees? time it was determined that the time being charged to the grant was appropriate, therefore, there were no questioned costs. Recommendation: We recommend that the District have proper internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if less than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Management Response: The District agrees with the finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan on the following page.

Corrective Action Plan

FINDINGS - FEDERAL AWARD PROGRAM AUDITS U.S. DEPARTMENT OF EDUCATION Finding: 2022-001: IDEA - Part B, Section 611 (84.027) & IDEA - Part B, Section 619 (84.173) Recommendation; We recommend that the District have proper internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if less than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Corrective Action Plan: The District will implement a system of internal controls to ensure that all certifications are completed in accordance with the percentage of time worked (ie. Monthly or semiannually) and that they are completed timely. Additionally, the District will ensure that time being charged to the grant agrees to actual time spent working in the grant for each employee. Anticipate,/ Completion Date: Currently in process with a final expected date of October 31,2022.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 44435 2022-001
    Significant Deficiency Repeat
  • 620876 2022-001
    Significant Deficiency Repeat
  • 620877 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education_grants to States $677,542
84.010 Title I Grants to Local Educational Agencies $315,356
10.553 School Breakfast Program $190,467
10.555 National School Lunch Program $120,691
84.425 Education Stabilization Fund $102,598
84.367 Improving Teacher Quality State Grants $59,626
84.173 Special Education_preschool Grants $18,084
84.365 English Language Acquisition State Grants $17,176
84.424 Student Support and Academic Enrichment Program $2,000