Finding Text
2024-002 The District did not have adequate internal controls and did not
comply with time-and-effort requirements.
Assistance Listing Number and Title: 21.027 COVID 19 – Coronavirus
State and Local Fiscal Recovery
Funds
Federal Agency Name: U.S. Department of the Treasury
Federal Award/Contract Number: N/A
Pass-through Entity Name: Snohomish County
Pass-through Award/Contract Number: BH-23-AR-08-050 &
EL-22-AR-22-050
Known Questioned Cost Amount: $0
Prior Year Audit Finding: N/A
Background
During the 2023-2024 school year, the District spent $740,931 in federal funds
from the Coronavirus State and Local Fiscal Recovery Funds program to provide
student support advocates, social emotional learning support and early learning
services. The objective of the program is to respond to the COVID-19 pandemic’s
negative effects on public health and the economy, provide premium pay to
essential workers during the pandemic, provide government services to the extent
COVID-19 caused a reduction in revenues collected and make necessary
investments in water, sewer or broadband infrastructure.
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
established 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 Office of Superintendent of Public Instruction (OSPI), the
cognizant agency for school districts. 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 require.
We consider this deficiency in internal controls to be a material weakness that led
to material noncompliance.
Cause of Condition
District staff responsible for collecting time-and-effort documentation relied on
staff assignments and budget allocations established for the fiscal year to identify
employees requiring time-and-effort documentation. During the year, the District
had staffing changes and decided to charge payroll costs for three employees to the
federal program. Staff responsible for obtaining time-and-effort forms did not
identify these staff assignment changes when performing their review and did not
collect the time-and-effort documentation as required.
Effect of Condition
The District did not obtain time-and-effort documentation for three employees
whose salaries and benefits costs totaling $81,201 it charged to the program.
Without adequate time-and-effort documentation, the District cannot demonstrate
compliance with OSPI’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 supported these payroll costs by providing alternative
documentation to show the employees worked on 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’s Response
The district understands the importance of internal controls regarding time and
effort reporting using federal funds. The district has implemented stronger internal
controls in order to reconcile and comply with federal and OSPI time and effort
requirements.
Auditor’s Remarks
We thank the District for its cooperation throughout the audit and the steps it is
taking to address these concerns. We will review the status of the District’s
corrective action during our next regular 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.