Finding Text
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: New
Federal Program: Special Education Cluster (ALNs 84.027, 84.173)
Federal Agency: U.S. Department of Education
Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406,
225350020849025000, 225360020849025360), Region 10 Education Service Center
(236600497110001)
Compliance Requirement: B - Allowable Costs / Costs Principles
Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective,
charges for their salaries must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable, and properly allocated. One allowable method is
through completion of semi-annual certifications signed by the employee or a supervisory official
with firsthand knowledge. These certifications provide assurance that salary costs charged to the
federal program reflects the total activity for which the employee is compensated by the District, not
exceeding 100% of compensated activities.
Condition: The district did not maintain required semi-annual certifications for employees who worked solely on
the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee
worked 100% on the program for the period covered, were missing for all employees.
Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed,
and retained in accordance with federal requirements. Staff turnover and limited awareness of the
documentation rules contributed to the oversight.
Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary
costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported
personnel costs were charged to the program, even if employees were appropriately assigned.
Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures
that employees worked solely on the program. The personnel records of the employees sampled
contained approval of the employee to be hired into the appropriate job duties to be funded by
special education cluster grant funds.
Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees
selected in our sample for testing.
Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual
certifications are prepared, signed, and retained for all employees working solely on federal
programs. The district should provide training to finance and program staff to ensure continued
compliance with federal documentation requirements.
Views of Responsible
Officials:
District officials agree with the finding. The District has implemented new procedures in fiscal year
2025 to ensure semi-annual certifications are completed appropriately.