Finding Text
Finding 2023-001: U.S. Department of Education, passed through the Colorado Department of Education,
Twenty-First Century Community Leaming Centers - Assistance Listing No. 84.287.
Criteria: 2 CFR 200 (Uniform Guidance) and the Cross-Cutting Section of the U.S. Department
of Education as contained in the OMB Compliance Supplement requires the maintenance
of time and effort distribution records that support the portion of time and effort
dedicated to each program or other cost objective supported by federal funds or other
revenue sources.
Condition: Time and effort distribution contained within the accounting records did not agree to
underlying, external time-keeping support.
Effect: Reimbursement was received for costs incurred and claimed for administrative, program
and site staff salaries that was not adequately supported by time and effort records.
Questioned Costs: None. Context:
Cause:
During our compliance testing of allowable costs/cost principles, we selected 28
separate in<livi<luals pai<l <luring two separate months (4 separate pay periods) <luring the
year ended July 31, 2023, whose salaries were allocated and charged as a qualifying
grant expenditures for the periods selected. The salary expense recorded in the
accounting system and accounting records for 26 of the 28 individuals selected did not
agree to the separately examined external time-keeping/time records for the same period
for which the individuals indicated and recorded time to the grant.
As a result of management turnover near year-end, the Organization was unable to
retrieve or reconcile time and effort records directly to or from the underlying payroll
data and grant draw/reimbursement requests/claims for the payroll periods and
individuals paid and included within our selections. The accounting records capturing
the salaries expense did not agree to the time records and salary authorizations
maintained.
Recommendation: We recommend that the Organization implement additional review procedures over each
manul journal entry recorded to expense and allocate payroll during each pay period.
The data should be compared and reconciled directly from the third-party payroll and
time keeping service prior to recording the journal entry accounting for the expense
within the accounting system. This will ensure accuracy by individual and location
against the actual payroll paid and time records kept. This review should be performed
consistently throughout the fiscal year and again at year-end.
Response: The Organization understands the recommendation. We have established a second level
of review ensuring all payroll data is reconciled by a third-party accounting firm. This
firm is currently working with the Organization staff accountant to ensure all
reconciliations are timely and accurate. We will utilize the third-party accounting firm
through the end of the second quarter, at which point the responsibility will be passed
to the director of finance. This regular review will be a review of time keeping and
expense allocation and the general ledger in the accounting system prior to recording
any payroll related entries. Review will also be performed on a monthly basis and at
year-end by the Senior Director of Programs and the CEO.