Finding 946576 (2023-001)

Significant Deficiency 2023-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Education Stabilization Funds (ESF) COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing No. 84.425U Criteria: Salaries, wages and any other forms of compensation charged to Federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart I, 2 CFR §200.430. Condition: Subpart I, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries, wages and other forms of compensation must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one federal award, or a Federal award and non-Federal award. The preparation of personnel activity reports (PARs), timesheets, or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District inadvertently charged resource officers payroll costs to a federal grant, however, it was determined that these payroll costs were not budgeted in the federal grant and should not have been charged to the federal grant. Cause: This was an oversight by the District as these costs were not budgeted in the federal grant form FS-10, and should not have been charged to the federal grant. These payroll costs should have been charged to the general fund, however, this was not captured as part of the review for the reimbursement of expenditures for the federal grant. As described in Subpart I, 2 CFR §200.430, the District is required to document and maintain the support for salaries, wages and other forms of compensation to ensure they are properly charged to Federal awards. Effect: Noncompliance can result in the incorrect amount for services rendered being charged to the Federal award. Questioned Costs: None Recommendation: The District should ensure that they review, monitor, and update the appropriate documentation to support the salaries, wages and other forms of compensation charged to Federal awards in accordance with the requirements of the Uniform Guidance at Subpart I, 2 CFR §200.430. In the event that modifications for costs charged to grants are necessary, the district should make the appropriate amendments. Since this particular grant will not be closed out until September 30, 2024, the District should contact the New York State Department of Education (NYSED) and file the appropriate amendment, or work with NYSED to adjust future reimbursements to adjust for the amounts overcharged to the federal grant. In addition, the District should review its procedures for reviewing reimbursement for federal grants to ensure that any payroll costs charged to federal grants are supported by the proper documentation and are properly budgeted for that grant. Views of Responsible Officials of Auditee: The District implemented a new summer program utilizing federal grant funds approved by the NYSED. The District charged resource officers payroll costs that occurred during the scheduled approved summer program, however it was determined that these payroll costs were not budgeted in the federal grant, per the FS-10. Since the grant funding period of this grant is still open, the District contacted NYSED to determine the necessary course of action to rectify this matter. It was determined that the District will prepare and submit an FS-10A amending the original FS-10, to include the resource officer’s payroll costs in the grant as it relates to the approved summer program. In addition, the District will review its internal review procedures to ensure that payroll costs charged to federal grants are supported by the proper documentation for each employee and are allowable per the approved budget of the federal grant. The FS-10A will be prepared and filed prior to the June 30, 2024 by the Assistant Superintendent for Curriculum.