Finding 617976 (2022-001)

2022-001 ? Material Weakness and Compliance Qualification ? Allowable Costs (Repeat Finding ? See Finding 2021-001) Program: Education Stabilization Fund ? Elementary and Secondary School Emergency Relief (?ESSER?) Fund (ALN 84.425D and 84.425U) ? United States Department of Education ? Virginia Department of Education; Federal Award Year: 2022. Criteria: Office of Management and Budget's (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subtitle A, Chapter II, Part 200, Subpart E ? Cost Principles subsection 200.430 ? Compensation ? Personal Services subsection (i) ? Standards for Documentation of Personnel Expenses subsection (1) states: ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vi) [Reserved] (vii) 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 (2) or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.? Condition: For a sample of forty (40) payroll and forty (40) non-payroll transactions, we noted: *Seven (7) instances where either the employee or their supervisor didn?t certify the employee?s timesheet hours. *One (1) instance where an employee did not certify their timesheet, but their supervisor did. *One (1) instance where an employee received ineligible paid leave. Cause: Employees and supervisors did not adhere to County time certification policies and procedures. Effect: Noncompliance may result in action by the grantor. Questioned Costs: $15,158 known questioned costs from a sample of personnel costs of $93,640 and a population approximating $7,900,000. Our testing of non-personnel costs approximating $9,150,000 from a population approximating $17,570,000 noted no internal control or compliance findings. Recommendation: Hourly employees and those charging time to a grant should have approved timesheets/records prior to payroll certification and processing. Views of Responsible Officials and Planned Corrective Action: Management concurs with the recommendation. The noted lack of time certifications was not consistent with policy, primarily occurring with substitute staff positions during School Year 2022-2023 and during the second year of the pandemic where classroom instructional roles were transitioning. Payroll staff will reinforce the importance of timesheet approvals by substitute employees and their supervisors prior to semi-monthly processing.