Finding Text
Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education (CDE) Program Name: COVID-19: COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund and COVID-19: Elementary and Secondary School Emergency Relief II (ESSER II) Fund Assistance Listing Number: 84.425D Compliance Requirement: A/B 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. Condition The Organization did not have sufficient controls in place to ensure that employees charged to the program maintain time accounting documentation in accordance with federal requirements. Questioned Costs There were no direct questioned costs associated with the condition identified. 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 Organization 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) for two of 56 employees selected for testing. Effect The Organization 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 clerical oversight and lack of appropriate review. Repeat Finding No. Recommendation The Organization 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 identified with the Organization?s time accounting documentation as it relates to employees working on multiple activities or cost objectives.