Finding Text
U.S. DEPARTMENT OF EDUCATION Passed through the Commonwealth of Massachusetts?Department of Elementary and Secondary Education Material Weakness 2022-002: Special Education Cluster ? SPED Grants to States, IDEA, Part B (Assistance Listing #84.027) Pass-through program number: 0240-577419-2022-0645; Fiscal year ending June 30, 2022 Criteria: Established internal controls surrounding documentation of federal award compliance requirements should ensure that all charges to Federal awards for salaries and wages are based on records that accurately reflect the work performed. Accordingly, time and effort documentation are required to be maintained which clearly documents ?after-the -fact? determinations of amounts for which individuals have worked on the federal program. These records should correspond with the internal control policies and procedures maintained by the District. Condition and Context: During our audit work associated with time and effort certifications, we noted a population of approximately (11) individuals being consistently charged to the grant program through the fiscal year. Of the four (4) individuals tested, no time & effort certifications were maintained on file for the fiscal year 2022. Salaries for the tested individuals were in accordance with expected pay schedule/contracts. Based upon our discussion with personnel, for fiscal year 2023, the District budgeting within the grant award has been changed to charge non-salary related allowable costs to the award ongoing. Cause and effect: Effective for fiscal year 2022, the District implemented a formalized grants manual. However, grants personnel incorrectly interpreted ?time & effort? requirements for personnel in accordance with the District?s established procedures. The District?s established procedures did not provide for adequate monitoring and review in accordance with the adopted policies and procedures. Perspective Information: There was a similar finding in the prior years related to allowable costs associated with the maintenance of appropriate time & effort certifications (2021-002; 2020-002). There was a finding related to enhanced formalization of grant compliance was previously reported in the previous years? audit reports as a finding.(2021-003; 2020-004). Questioned Costs: $236,230 represents the approximate charge to the program of salary of the (4) individuals for whom there were no time & effort certifications on file for the year ended June 30, 2022. As indicated, the actual amounts paid, corresponded with expected pay schedule/contracts. Total salaries and wages charged to the program for fiscal year 2022 was $637,307. Auditor?s Recommendation: The District should review currently established policies and procedures for maintenance of time and effort certifications as established within adopted grants manual. Personnel should review established policies and procedures on a routine basis to ensure the District?s compliance with all aspects of the District?s established policies and procedures as well as individual requirements pursuant to OMB. Established policies and procedures should be reviewed on an annual basis to ensure continued compliance with ever changing federal compliance and other financial reporting requirements. View of Responsible Official and Planned Corrective Action: The District expects significant improvement in the administration and monitoring of grant activity during the current fiscal year with additional review of the procedure manual and new personnel. Additionally, as indicated by the auditor, the budgeting for the 240 SPED allocation grant in fiscal year 2023 has been changed to exclude personnel costs (salaries & wages) subject to the ?time & effort? certifications. District personnel will review established grants policies and procedures manual with current federal awards.