Finding Text
2024-001. Allowable Costs/Cost Principles: Compensation – Personal Services
United States Department of Education, Passed Through New York State, Department of Education:
Special Education Cluster
Special Education Grants to States: IDEA Part B ALN: 84.027
Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X
Special Education Preschool Grants: IDEA Preschool ALN: 84.173
Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X
Criteria: Salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR §200.430.
Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee's compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District prepared periodic certification equivalents, but it did not comply with Subpart E, 2 CFR §200.430.
Cause: The staff that were responsible for maintaining records that accurately reflect the work performed, as described in Subpart E, 2 CFR §200.430, to support salaries charged to federal awards, on occasion prepared PARs, which were not signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. In some situations, sufficient details regarding the duties performed by the employes did not exist.
Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the federal award.
Questioned Costs: None reported.
Context: Time records for employees charged to federal awards to be maintained by the District are supportive of amounts included in budgets approved by the State.
Identification of a Repeat Finding: This is not a repeat finding.
Recommendation: The District should monitor its procedures to ascertain that documentation to support actual salaries and wages charged to federal awards are in a format that complies with the requirements of the Uniform Guidance at Subpart E, 2 CFR §200.430.
Views of Responsible Officials of Auditee: The District agrees with the finding. Reza Kolahifar, Assistant Superintendent for Human Resources and Personnel, will oversee the monitoring of procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR §200.430.