Finding Text
2022-001 ? Level of Effort U.S. Department of Education: Passed through State of New Jersey, Department of Education: Higher Education Institutional Aid - Proyecto Stem: Evidence-Based Approaches to STEM Enrollment, Retention, and Graduation at Urban Public Hispanic-Serving Institution (ALN 84.031C) Federal Award Numbers and Years: P031C160155 (7/1/2021 ? 6/30/2022) Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Prior Year Finding: None Finding Type: Significant Deficiency and Noncompliance Criteria: The specific requirements for matching, level of effort, and earmarking are unique to each Federal program and are found in the statutes, regulations, and the terms and conditions of awards pertaining to the program. Level of effort includes requirements for (a) a specified level of service to be provide from period to period, (b) a specified level of expenditures from non-Federal or Federal sources for specified activities to be maintained from period to period, and (c) Federal funds to supplement and not supplant non-Federal funding of services. Additionally, in accordance with Federal requirements, the University shall maintain internal controls over Federal programs designed to provide reasonable assurance that transactions are executed in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program. Condition and Context: The grant as the following level of effort requirements for key personnel in the award notification letter: We tested the level of effort requirement for the Project Director and Program Assistant and noted that the level of effort percentage certified by the Project Director and Program Assistant and the amount reported in the University?s attestation system were less than the level of effort percentage required in the grant agreement. The hours worked amounted to 27.98% and 20.83%, respectively. However, we noted that the salaries charged to the grant were commensurate with the actual effort reported by the Project Director and the Program Assistant and did not exceed the budgeted amounts in the award notification. Total salaries charged to the grants in 2022 was $320,663, of which $16,244 was for the Project Director and $5,000 was for the Program Assistant. The University?s policies and procedures to ensure compliance with the above requirements did not include certain internal controls that were designed properly and operating effectively to ensure that the level of effort requirement was being met. Cause: Due to turnover at the University, the Project Director and Program Assistant were required to work on other projects. The University did not notify the granting agency in the change in the level of effort for these employees. As the salaries charged to the grants and requested for reimbursement in 2022 was commensurate with the actual level of effort reimbursed for, there are no questioned costs. Effect: The Project Director?s and Program Assistant?s level of effort on the grant is significantly below what was reported in the grant application. However, the salaries charged to the grant and requested for reimbursement are commensurate with the actual level of effort reimbursed for. Questioned Costs: None Recommendation: The University should review its policies and procedures to communicate changes in level of effort to the granting agency in a timely manner and maintain documentation regarding the notification and any subsequent correspondence from the granting agency.