Assistance Listings number
and name: 84.002 Adult Education—Basic Grants to States
Award numbers and years: 24FABASC-412421-01A, July 1, 2023 through June 30, 2024;
24FIELCC-412421-01A, July 1, 2023 through June 30, 2024;
24FIETCO-412421-01A, July 1, 2023 through June 30, 2024;
24FPRLEC-412421-01A, July 1, 2023 through June 30, 2024;
24FIECTC-412421-01A, July 1, 2023 through June 30, 2024
Compliance requirements: Activities Allowed or Unallowed and Allowable Costs / Cost Principles
Questioned costs: $52,754
Assistance Listings number
and name: 84.031 Higher Education—Institutional Aid
Award numbers and years: P031S160090, October 1, 2016 through September 30, 2023;
P031S190167, October 1, 2019 through September 30, 2024;
P031S200096, October 1, 2020 through September 30, 2025;
P031S200281, October 1, 2020 through September 30, 2025;
P031C210057, October 1, 2021 through September 30, 2026;
P031C210077, October 1, 2021 through September 30, 2026;
P031S220015, October 1, 2022 through September 30, 2027;
P031S220179, October 1, 2022 through September 30, 2027;
P031A230147, October 1, 2023 through September 30, 2028;
P031S230158, October 1, 2023 through September 30, 2028
Compliance requirements: Activities allowed or unallowed
Questioned costs: $20,411
Federal agency: U.S. Department of Education
Total questioned costs: $73,165
Condition—Contrary to federal regulations, State law, and District policies, the District did not always retain documentation supporting the Adult Education—Basic Grants to States and Higher Education—Institutional Aid programs’ payroll costs or approve employee time sheets after the work was performed for these programs. Specifically, the District could not provide documentation to support employees’ pay rates and authorization to perform work for these programs, such as offer letters, contracts, and personnel action forms, or did not approve employee time sheets after the work was performed for 22 of 54 payroll transactions we tested totaling $73,165. See finding 2024-01 in our Report on Internal Controls and Compliance for a similar finding related to the District not reviewing or approving employee timesheets.1 Also, see Table 1 on the next page for further information.
Table 1
Summary of the $73,165 of payroll costs the District did not properly support or approve
Fiscal year 2024
84.002 Adult Education—Basic Grants to States 84.031 Higher Education—Institutional Aid Total for both programs
Total employees tested 35 19 54
Total employees with unsupported pay rates and lack of authorization to perform work for the programs 7 1 8
Total unsupported payroll costs $52,366 $9,636 $62,002
Total employee time sheets lacking approval after the work was performed2 2 12 14
Total unapproved payroll costs $388 $10,775 $11,163
Total number of employees with unsupported or unapproved payroll costs 9 13 22
Total salaries not supported $52,754 $20,411 $73,165
Effect—The District’s failure to retain documentation supporting payroll costs and approve time sheets increased the risk that the $52,754 for the Adult Education—Basic Grants to States and $20,411 for the Higher Education—Institutional Aid programs may not have been spent in accordance with their award terms and conditions. Consequently, the District may be required to return these monies to the federal agency in accordance with federal requirements.3 Further, see Table 2 for information on the overall payroll costs per program during fiscal year 2024 that are at an increased risk of not being spent in accordance with the award terms and conditions. Finally, the District is at risk that this finding applies to other federal programs it administers.
Table 2
Calculation of percent of payroll costs to total program expenditures
Fiscal year 2024
84.002 Adult Education—Basic Grants to States 84.031 Higher Education—Institutional Aid
Total number of employees 279 214
Total payroll costs $3,613,133 $1,984,462
Total program costs $5,026,228 $6,696,263
% of payroll costs to total program costs 72% 30%
Cause—The District’s management reported that it did not retain documentation to support employees’ pay rates and authorization to perform work for the federal programs for employees hired prior to 2018 as they were archived and support was no longer available, and some offers for temporary employees were made verbally over the phone and never documented. The District’s policies and procedures lack requirements to document all employment offers, including temporary employment offers. Additionally, as discussed in finding 2024-01 in our Report on Internal Controls and Compliance, some supervisors did not follow District policies and procedures requiring employees’ time sheets to be reviewed and approved either before processing payroll or within 3 business days after receiving a payroll email notification that the employee’s time sheet needed approval.1 Finally, District management did not sufficiently monitor whether each college’s Human Resources Department was enforcing these policies and procedures or verifying that supervisors reviewed and approved employees’ time sheets, as required.
Criteria—Federal regulation requires the District to maintain records for salaries and wages charged to federal awards that accurately reflect the work performed to ensure they are accurate, allowable, and properly allocated (2 CFR §200.430[g][1][i]). Also, federal regulation, similar to State law and the District’s record retention policies, requires the District to retain all public records, including those contained in personnel files, related to a federal program for a period of 3 years from the date the program’s final report was submitted to the federal awarding agency or pass-through grantor (2 CFR §200.334).4,5 Further, the District’s written procedures require each employee’s time sheet to be reviewed and approved by the employee’s supervisor either before processing payroll or within 3 business days from receiving a payroll email notification that the employee’s time sheet needs approval. Additionally, each college’s Human Resources Department is responsible for verifying that supervisors review and approve time sheets timely.6 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303).
Recommendations—The District should:
1. Retain documentation for all payroll costs, such as employment agreements or acceptance letters, to demonstrate employees’ salaries and wages are authorized to be charged to federal programs and spent in accordance with the programs’ award terms and conditions.
2. Review the fiscal year 2024 payroll costs for the Adult Education—Basic Grants to States and Higher Education—Institutional Aid programs to ensure they were properly supported and spent in accordance with the award terms and conditions and coordinate with the U.S. Department of Education, as necessary, to adjust future federal reimbursement requests or repay any unallowable costs the District charged to the programs.
3. Enforce and train employees on District written procedures and requirements to:
a. Retain all public records, including those contained in personnel files, related to a federal program for a period of 3 years from the date the program’s final report was submitted to the federal awarding agency or pass-through grantor.
b. Ensure supervisors review and approve employees’ time sheets, either before payroll is processed or within 3 business days from receiving the payroll email notification that a time sheet needs approval, to verify employees accurately reported their time worked. This review should be performed after the employee performed the work to ensure the payroll costs charged to the programs accurately reflect the work performed and are accurate, allowable, and properly allocated.
4. Update District written procedures to require documentation of all employment offers, including offers for temporary employees.
The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
1 Arizona Auditor General. (2024). Report on Internal Control and Compliance, June 30, 2024. Phoenix, AZ. https://www.azauditor.gov/sites/default/files/2025-02/MaricopaCountyCommunityCollegeDistrictJune30_2024ReportOnInternalControlAndCompliance.pdf
2 The 14 employee time sheets lacking approval after the work was performed includes 5 time sheets totaling $6,917 for the Higher Education—Institutional Aid program that were never approved by a supervisor and 2 time sheets totaling $388 for the Adult Education—Basic Grants to States program and 7 time sheets totaling $3,858 for the Higher Education—Institutional Aid program that were approved by a supervisor between 1 and 7 days prior to the work being performed by the employee.
3 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the District, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521).
4 Maricopa County Community College District (MCCCD). (2023). Staff Policy Manual.
5 Arizona State Library, Archives and Public Records. (2023) General Retention Schedule Created for All Public Bodies. Retrieved 3/12/25 from https://apps.azlibrary.gov/files/docs/all_general_schedules_searchable.pdf
6 Maricopa County Community College District (MCCCD). Version 1.1 (2019). Monitoring Time Approvals: Monitoring Procedures.