Finding Text
Title 2 U. S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.430(a)(2) outlines the requirements of allowable compensation specifically that the compensation follows an appointment made in accordance with the non-Federal entity's written policies. The Monroe County Board of Education's (the ?Board?) Policies and Procedures Manual states, "All compensation must be approved by the Board, regardless of the sources of funding."; "No employee is entitled to compensation except for work performed by the employee in accordance with an approved contract or applicable terms of appointment."; and "Compensation may be withheld pending the employee's timely, accurate, and complete submission of all required records, data, and reports." When reviewing the Education Stabilization Fund, 60 expenditures were randomly selected for testing, in addition to two judgmentally selected expenditures. During the test of expenditures, the following issues were noted: ? Twenty-five payments totaling $24,087.50 were made to personnel for after school tutoring services without proper Board approval. The Board did not provide contracts or other documentation of Board approval for personnel that received compensation for providing after school tutoring. Furthermore, the Board did not approve a specified rate of pay for these services. ? Five payments were made to independent contractors for which compensation did not agree with daily rates of pay specified in the independent contractor agreements. ? An administrative stipend of $1,230 was paid to an employee for serving as the Homeless Liaison Coordinator. Review of the Board minutes indicated that the Board did not approve the payment of the administrative stipend to the employee. A retroactive contract dated November 10, 2021, for Homeless Liaison Coordinator was located in the employee's personnel file, but it was not signed by the Superintendent. Additionally, the contract stated work was to be performed outside of the employee's normal work hours and time worked must be reflected on a sign-in sheet. No documentation was provided to substantiate the hours worked for the expenditure tested. ? Two payments were made to independent contractors for nursing services. Independent contractor agreements were on file for each nurse; however, the Board did not approve the independent contractor agreements in a Board meeting. Per the agreements, the independent contractors agreed to provide adequate documentation of work performed and times worked. The Board did not provide any documentation of work performed or hours worked for one of the independent contractors. Total compensation paid to these two independent contractors for nursing services totaled $159,147.84. ? A payment of $1,265.40 was made for temporary housing of homeless students. The Board did not provide any documentation that students were identified as homeless students or eligible to receive benefits under the Homeless Children and Youth grant. Controls were not in place to ensure personnel were properly compensated, contracts were properly approved, and appropriate records to support work performed were maintained. Additionally, payments were made for unallowable activities from the federal program . As a result, the Monroe County Board of Education expended $194,009.26 for personnel compensation and contract services that were not approved and/or substantiated by appropriate records and $1,265.40 for unallowable activities from the federal program. Recommendation The Monroe County Board of Education should implement controls to ensure all expenditures are allowable, compensation is approved, and appropriate records to support work performed are maintained.