Finding Text
Finding 2024-003: Time and Effort Requirements (50000)
Repeat Finding? No
Assistance Listing No. 84.425 – Education Stabilization Funds (ESSER)
U.S. Department of Treasury
Passed through California Department of Education
Criteria: To support salaries and wages for employees that work on federal programs, local educational agencies (LEAs) are required to maintain time and effort records that accurately reflect the work performed. These time and effort records must: (1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (2) be incorporated into the official records of the LEA; (3) reasonably reflect the total activity for which the employee is compensated by the LEA, not exceeding 100% of compensated activities; (4) encompass both federally assisted and all other activities compensated by the LEA on an integrated basis, but may include the use of subsidiary records as defined in the LEA’s written policy; (5) comply with the established accounting policies and practices of the LEA; and (6) 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 or percentages determined before the services are performed alone do not qualify as support for charges to Federal awards.
Condition: Three employees out of a sample of 25 total had exceptions related to proper time accounting documentation. One employee was missing time accounting documentation for the months of August and September 2023. The employee was terminated during the year; however, there was no time accounting done for August or September while the employee was active. Two other employees' time accounting documentation was not signed until after the close of the fiscal year in which they were accounted for.
Cause: The exceptions appear to be isolated situations and not a systemic problem. The District did not have sufficient time and effort procedures to ensure that their records were supported by appropriate documentation.
Effect: The District could be required to reimburse ESSER III funds using an unrestricted funding source.
Questioned Costs: The District did not provide documentation for $22,155 charged to ESSER programs. Specifically, the District failed to provide sufficient documentation to support salaries charged to ESSER III – Resource 3213.
Context: Three employees out of a sample of 25 total had exceptions related to proper time accounting documentation.
Recommendation: The District must update its time and effort records and policies and procedures to ensure that all salaries and wages charged to federal programs are properly supported by a system on internal controls. Specifically, the time and effort records must accurately reflect the work performed and encompass all activities of the employee, both federal and non-federal, and be signed in a timely manner.
Views of Responsible Officials: The District agrees with the auditor’s recommendation as stated above.