Finding 538654 (2024-003)

Significant Deficiency
Requirement
AB
Questioned Costs
$1
Year
2024
Accepted
2025-03-27

AI Summary

  • Core Issue: Employees charged to the Title 1 program submitted Semiannual Certification Forms before the reporting period ended, violating federal regulations.
  • Impacted Requirements: Non-compliance with 2 CFR §200.430 regarding proper documentation for salaries and wages funded by federal awards.
  • Recommended Follow-Up: Provide ongoing training on federal time accounting, assign a monitoring individual, and reconcile time documentation with payroll records.

Finding Text

Criteria or Specific Requirement Federal regulation 2 CFR §200.430 states that “charges to Federal awards for salaries and wages must comply with the established accounting policies and practices of the non-Federal entity and budget estimates determined before the services are performed alone do not qualify as support for charges to Federal awards.” Entity policy states that “All employees who are paid in full or in part with federal funds, including employees whose salary is paid with state or local funds but is used to meet a required match or in-kind contribution to a federal program, shall document the amount of time they spend on grant activities (AR 3230)”. Condition In our review of employees charged to the Title 1 program we noted that two of the employees Semiannual Certification Form’s were certified before the period was over. Both Semiannual Certification Forms for the period 1/1/2024-6/14/2024 were certified on 2/23/2024. Potential Fiscal Impact $49,153 Cause The Organization’s internal control process over Federal Time Accounting was not properly designed Effect The Organization is out of compliance with 2 CFR §200.430. Context During the 2023-24 fiscal year, the Organization charged 2 employees to the Title 1 program for their salaries or extra duty performed. We reviewed time accounting documentation for both of the employees charged to the program. We identified findings in both of the employees that were reviewed. Repeat Finding No Recommendation Continue to provide training to all employees funded from federal programs and their supervisors to the requirements for federal time accounting under 2 CFR §200.430. Identify an individual responsible to monitor documentation to ensure it meets requirements. Implement a reconciliation between federal time accounting documentation and payroll records to ensure that appropriate adjustments are made to ensure payroll is charged to the correct programs. Views of Responsible Officials See Corrective Action Plan

Corrective Action Plan

Planned Corrective Action: The two employees are no longer with America’s Finest Charter School (AFCS). However, AFCS will ensure that all Title I employees responsible for reviewing the Semiannual Certification Form will certify it after the pay period. We will continue to provide training for all employees funded by federal programs and for the HR Manager regarding the requirements for federal time accounting under 2 CFR §200.430. We will also review payroll records to ensure that payroll is accurately charged to the correct programs on a semimonthly basis.

Categories

Questioned Costs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1115096 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.425D Covid-19 Esser III $1.13M
84.425U Covid-19 Esser III Learning Loss $252,735
84.010 Essa Title I Basic $197,884
84.027 Idea Basic Local Assistance $71,377
84.425 Covid-19 Esser III Summer Learning $57,900
84.365 Title III - English Learner $33,940
84.367 Title II - Supporting Effective Instruction $21,102
84.424 Title IV - Student Support & Academic Enrichment $16,095