Finding Text
SCHEDULE OF FEDERAL AWARD FINDINGS AND QUESTIONED COSTS
East Valley School District No. 361
September 1, 2023 through August 31, 2024
2024-001 The District did not have adequate internal controls and did not comply with time-and-effort requirements.
Assistance Listing Number and Title: 84.010, Title I Grants to Local Educational Agencies
Federal Grantor Name: U.S. Department of Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public Instruction (OSPI)
Pass-through Award/Contract Number: GT-01077
Known Questioned Cost Amount: $0
Prior Year Audit Finding: N/A
Background
The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting academic standards and reside in areas with high concentrations of children from low-income families. During the fiscal year 2024, the District spent $1,423,886 in federal funds from Title I.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of internal controls.
The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations and the awarding agency. Depending on the number and types of activities employees perform, time-and-effort documentation can be a semiannual certification or a monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work is completed.
Description of Condition
The District's internal controls were ineffective for ensuring it supported all salaries and benefits it charged to the program with appropriate time-and-effort documentation, as federal regulations and OSPI require.
We consider this deficiency in internal controls to be a material weakness that led to material noncompliance.
Cause of Condition
The District changed how it was funding payroll costs for five employees who work in schoolwide programs and overlooked collecting time-and-effort documentation for them when it decided to charge their costs to the Title I program.
Effect of Condition
The District did not obtain time-and-effort documentation for five employees whose payroll and benefits costs totaling $312,961 were charged to the program.
Without adequate time-and-effort documentation, the District cannot demonstrate compliance with the awarding agency's documentation requirements to support costs charged to federal programs. Further, the District cannot assure federal grantors that payroll costs it charged to the program were accurate and valid.
During the audit, the District obtained and provided the signed time-and-effort records to support the payroll costs it charged to the program; therefore, we are not questioning these costs.
Recommendation
We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for obtaining signed time-and-effort documentation timely.
District Response
The District has already updated time and effort processes to ensure mid-year additions or corrections are included on Time and effort documentation. We have also added a secondary time and effort review process to ensure all employees charged to the Federal program are included on time and effort documentation.
Auditor Remarks
We appreciate the District's commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the status of the District's corrective action during our next audit.
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, audit findings, establishes reporting requirements for audit findings,
Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
Title 2 CFR Part 200 Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs.
Office of Superintendent of Public Instruction Addendum to Bulletin 048-17 Guidelines for Charging Employee Compensation to Federal Grants establishes requirements for documenting time-and-effort, including fixed schedule systems.