FAC Explorer

Finding 496635 (2023-011)

Material Weakness
Requirement
AH
Questioned Costs
-
Year
2023
Accepted
2024-09-12
Audit: 319431
Organization: City of Boston (MA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: BPS lacks proper documentation and approval for payroll charges, risking inaccuracies in grant allocations.
  • Impacted Requirements: Compliance with 2 CFR 200.430 on payroll costs and 2 CFR 200.303 on internal controls is not met.
  • Recommended Follow-Up: BPS should reinforce policies to ensure timely sign-off and retention of payroll documentation.

Finding Text

Finding number: 2023 011 Federal agency: U.S. Department of Education Pass through agency: Commonwealth Department of Elementary and Secondary Education Program: Special Education (IDEA) Cluster ALN #: 84.027; 84.173 Award number: 240 532934 2022 0035; 240 714716 2023 0035 Award year: August 23, 2021 to September 30, 2024 Finding: Internal Control over Payroll Costs and Period of Performance Prior Year Finding: No Type of Finding: Material Weakness Criteria Allowable Costs – Payroll In accordance with 2 CFR 200.430(i)(1), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities; (iv) 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; (v) Comply with the established accounting policies and practices of the non Federal entity; and (vi) 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. Period of Performance A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). A period of performance may contain one or more budget periods. LEAs and SEAs must obligate funds during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. This maximum period includes a 15 month period of initial availability plus a 12 month period for carryover. Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must 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. Condition During our testing of allowable costs and period of performance associated with payroll charges, we noted that the City of Boston Public Schools (BPS) documents time and attendance of employees on daily timesheets signed by the employee, and that these timesheets are approved by the Department Head/Supervisor on a Department Time Summary Report (DTSR). However, for 39 of our sample of 40 payroll transactions charged to the program, we noted that the DTSR was either not located or not approved by the Department Head/Supervisor. Cause This appears to be due to the insufficient retention and documentation over the review and approval of payroll charges. Effect Insufficient review of payroll documentation increases the risk of inaccurate payroll costs being allocated to a grant award. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that BPS re enforce its policies and procedures to ensure their review of payroll changes via signoff on the Department Time Summary is appropriately documented and records are retained. View of Responsible Officials from the Auditee BPS has updated DTSR training and guidance for timekeepers to ensure that any similar technical issues are addressed quickly and manually adjusted if needed. Training was given in August 2024.

Corrective Action Plan

Boston Public Schools (BPS) has updated its’ training and guidance for timekeepers. Timekeepers participated in enhanced trainings during August of 2024 in preparation of the new school year. Anticipated Completion Date: August 31, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 496626 2023-003
    Material Weakness
  • 496627 2023-004
    Significant Deficiency
  • 496628 2023-004
    Significant Deficiency
  • 496629 2023-005
    Material Weakness
  • 496630 2023-006
    Material Weakness Repeat
  • 496631 2023-007
    Material Weakness Repeat
  • 496632 2023-008
    Material Weakness
  • 496633 2023-009
    Material Weakness Repeat
  • 496634 2023-010
    Material Weakness
  • 496636 2023-012
    Significant Deficiency
  • 496637 2023-011
    Material Weakness
  • 496638 2023-012
    Significant Deficiency
  • 496639 2023-013
    Significant Deficiency
  • 496640 2023-014
    Material Weakness
  • 496641 2023-015
    Material Weakness
  • 496642 2023-016
    Material Weakness
  • 1073068 2023-003
    Material Weakness
  • 1073069 2023-004
    Significant Deficiency
  • 1073070 2023-004
    Significant Deficiency
  • 1073071 2023-005
    Material Weakness
  • 1073072 2023-006
    Material Weakness Repeat
  • 1073073 2023-007
    Material Weakness Repeat
  • 1073074 2023-008
    Material Weakness
  • 1073075 2023-009
    Material Weakness Repeat
  • 1073076 2023-010
    Material Weakness
  • 1073077 2023-011
    Material Weakness
  • 1073078 2023-012
    Significant Deficiency
  • 1073079 2023-011
    Material Weakness
  • 1073080 2023-012
    Significant Deficiency
  • 1073081 2023-013
    Significant Deficiency
  • 1073082 2023-014
    Material Weakness
  • 1073083 2023-015
    Material Weakness
  • 1073084 2023-016
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $155.28M
21.027 Coronavirus State and Local Fiscal Recovery Funds $137.12M
84.425 Education Stabilization Fund $95.96M
84.010 Title I Grants to Local Educational Agencies $36.42M
14.267 Continuum of Care Program $33.21M
10.555 National School Lunch Program $30.28M
84.027 Special Education_grants to States $18.48M
97.067 Homeland Security Grant Program $14.25M
21.023 Emergency Rental Assistance Program $13.46M
14.231 Emergency Solutions Grant Program $9.76M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $7.37M
14.218 Community Development Block Grants/entitlement Grants $2.92M
84.367 Improving Teacher Quality State Grants $2.66M
66.443 Reducing Lead in Drinking Water (sdwa 1459b) $2.33M
84.365 English Language Acquisition State Grants $1.97M
84.048 Career and Technical Education -- Basic Grants to States $1.89M
14.248 Community Development Block Grants_section 108 Loan Guarantees $1.81M
10.558 Child and Adult Care Food Program $1.72M
10.582 Fresh Fruit and Vegetable Program $1.42M
84.424 Student Support and Academic Enrichment Program $1.21M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $1.17M
84.173 Special Education_preschool Grants $984,808
84.287 Twenty-First Century Community Learning Centers $975,544
14.905 Lead Hazard Reduction Demonstration Grant Program $932,129
10.559 Summer Food Service Program for Children $847,800
93.053 Nutrition Services Incentive Program $819,095
84.002 Adult Education - Basic Grants to States $637,747
97.106 Securing the Cities Program $633,137
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $529,609
16.833 National Sexual Assault Kit Initiative $419,758
16.034 Coronavirus Emergency Supplemental Funding Program $361,892
16.741 Dna Backlog Reduction Program $304,935
97.111 Regional Catastrophic Preparedness Grant Program (rcpgp) $296,943
94.016 Senior Companion Program $282,802
97.044 Assistance to Firefighters Grant $275,718
16.738 Edward Byrne Memorial Justice Assistance Grant Program $220,692
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $216,589
14.241 Housing Opportunities for Persons with Aids $146,150
94.002 Retired and Senior Volunteer Program $128,436
97.056 Port Security Grant Program $114,220
10.579 Child Nutrition Discretionary Grants Limited Availability $112,182
16.588 Violence Against Women Formula Grants $106,201
84.196 Education for Homeless Children and Youth $101,856
97.024 Emergency Food and Shelter National Board Program $93,705
45.024 Promotion of the Arts_grants to Organizations and Individuals $75,000
16.820 Postconviction Testing of Dna Evidence to Exonerate the Innocent $70,275
10.935 Urban Agriculture and Innovative Production $68,330
16.751 Edward Byrne Memorial Competitive Grant Program $62,566
93.052 National Family Caregiver Support, Title Iii, Part E $54,824
47.076 Education and Human Resources $48,623
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $47,562
14.401 Fair Housing Assistance Program_state and Local $43,110
97.042 Emergency Management Performance Grants $42,546
10.331 Food Insecurity Nutrition Incentive Grants Program $40,575
16.838 Comprehensive Opioid Abuse Site-Based Program $38,947
14.889 Choice Neighborhoods Implementation Grants $38,598
14.261 Homeless Management Information Systems Technical Assistance $38,248
84.305 Education Research, Development and Dissemination $32,566
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $25,988
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $19,965
14.246 Community Development Block Grants/brownfields Economic Development Initiative $13,770
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $12,444
93.566 Refugee and Entrant Assistance_state Administered Programs $9,500
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $7,450
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $6,810
20.205 Highway Planning and Construction $6,244
84.411 Investing in Innovation (i3) Fund $1,192
16.710 Public Safety Partnership and Community Policing Grants $1,068
20.600 State and Community Highway Safety $283
16.817 Byrne Criminal Justice Innovation Program $-17
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $-385,211