Finding Text
Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education Program Name: Education Stabilization Fund Federal Financial Assistance Listing/Federal CFDA Number: 84.425 Compliance Requirement: A/B (Activities Allowed or Unallowed and Allowable Costs/Cost Principles) Criteria or Specific Requirements Per Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430(i)(1)(vii), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. A semi-annual certification may be completed if 100% of an employee?s time if charged to one Federal award. Condition The District did not have sufficient controls in place to ensure that employees who were charged to Education Stabilization Fund programs completed time accounting documentation in accordance with federal requirements. The District was not able to provide time accounting documentation for 10 of 37 payroll items selected for testing. Questioned Costs This finding represents a significant deficiency in internal control over federal compliance. However, there were no questioned costs associated with this finding as we did not identify any unallowable expenditures as a result of the finding. Context A significant amount of the federal expenditures related to these programs are derived from payroll costs. While the salaries appear to be reasonable and necessary for the program objectives, the District did not provide the required supporting documentation as outlined in the Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430 (i)(1)(vii). Further, there does not appear to be adequate policies and procedures necessary to support that the District has controls over compliance objectives. Effect The District has not complied with the requirements identified in Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430 (i)(1)(vii). Cause The condition identified appears to have materialized due to the District?s lack of established procedures to ensure compliance with the requirements under Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430 (i)(1)(vii). Repeat Finding No. Recommendation The District should review the requirements stated in Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.430 (i)(1)(vii) and implement a procedure to address the control deficiency currently identified with the District?s time accounting documentation as it relates to employees working on multiple activities or cost objectives.