Finding Text
Federal Agency: U.S. Department of Education
Federal Program: Education Stabilization Fund
ALN(s): 84.425U
Pass-through Agency: Michigan Department of Education
Grant Number(s): 213713 Project 2122; 213723 Project 2122
Criteria: Title 2 CFR 200.430 states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. It is the School District’s procedure to utilize semi-annual certifications or personnel activity reports (PARs) for its records to accurately reflect the work performed.
Condition: For interim purposes the School District utilized budgets to allocate employee time between programs. During the audit of the Elementary and Secondary School Emergency Relief (ESSER III) federal grant the School District did not sufficiently document its employees’ actual time spent between federal and/or state programs by completing semi-annual certifications and/or PARs for all employees charged to ESSER III.
Cause: The School District has suffered from mass turnover in key positions within the past year including Human Resources, Payroll, and Business Manager positions. The timing of the loss of these key positions and the subsequent delay in finding qualified replacements for these key positions left the School District short-staffed for a good portion of the year while state and federal funding hit unprecedented levels due to the response to the COVID-19 pandemic. With the added funding there was additional reporting which led to even more work having to be spread and managed to an already handicapped staff.
Effect: The School District did not follow Board Policy 6116 “Time and Effort Reporting”. Additionally, the accuracy of its interim budgets for ESSER III was not able to be adjusted against after-the fact charges based on comparison with the semi-annual certifications and PARs; accordingly, actual time allocations may vary from budgeted allocations.
Perspective: Only employees charged to the Education Stabilization Fund did not have appropriate documentation. All employees selected related to Title I had appropriate documentation to validate employee time to federal and state programs.
Recommendation: The School District should follow its policy to appropriately document (through the use of semi-annual certifications or PARs) and adjust budget allocations to actual based on after-the-fact charges to all federal and/or state programs.