Finding Text
Finding 2023-002
Information on the federal program:
Title I, Part A – Improving Basic Programs; Title I, SIA – Reallocated; Title I SIA, Part A – Improving Basic Programs, CFDA #84.010A, Grant Period 7/1/22 – 6/30/23
Compliance/Internal Control over Compliance:
Allowable Costs/Cost Principles – Documentation of Employee Time and Effort
Criteria or specific requirement:
As per 2 C.F.R. Appendix A Part 225 (formerly OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments), Illustrative Time and Activity Report for Title I Instructional Staff, an employee whose salary and wages are supported, in whole or in part, with Federal funds must document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. The Appendix addresses two types of documentation: semiannual certifications and personnel activity reports.Criteria or specific requirement (continued):
Semiannual certifications must be completed semiannually by an employee whose contractual salary is funded in whole by the Federal program. The distribution of the employee’s salary and wages must be supported by periodic certifications that the employee worked solely on the Federal program for the period covered by the certification.
Personnel Activity Reports must be completed monthly by an employee whose contractual salary is partially funded by the Federal program. The distribution of the employee’s salary and wages must be supported by a personnel activity report (PAR) or equivalent documentation. The personnel activity reports must reflect:
Both the Semiannual certifications and the Personnel Activity Reports must reflect:
(1) what, where, and when the Title I work is being performed;
(2) the approving signature of the employee and the supervisory official having firsthand knowledge of the work performed by the employee;
(3) dates coinciding to the payroll periods.
Condition:
There were instances in which multiple personnel did not have a Bi-Annual Certification on file in a manner consistent with the requirement of 2 C.F.R. Appendix A Part 225 (formerly OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments), Illustrative Time and Activity Report for Title I Instructional Staff.Questioned Costs:
Unknown.
Context:
During our audit testing, we noted that the District’s Title I funded personnel were required to prepare and submit time and effort documentation that conform with the requirements of 2 C.F.R. Appendix A Part 225 (formerly OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments), Illustrative Time and Activity Report for Title I Instructional Staff. However, there were instances in which employees that are fully funded by Title I did not have bi-annual certifications prepared for the engagement team to review.
The District is not in compliance with federal requirements regarding allowable costs/cost principles. Ineffective controls to monitor program requirements could result in inaccurate information regarding the employee’s time and effort devoted to the program, the risk of non-compliance and increase the District’s risk of loss of funding.
Cause:
The District’s Title I fully funded personnel did not have any certifications that are required to be prepared Bi-Annually.
Recommendation:
The Palisades Park Board of Education should implement policies and procedures to ensure that Title I fully funded personnel have bi-annual certifications prepared in accordance with 2 C.F.R. Appendix A Part 225 (formerly OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments), Illustrative Time and Activity Report for Title I Instructional Staff.
Management’s response:
The Palisades Park Board of Education will ensure that all required allowable cost/cost principle requirements are met by ensuring that more detailed time and effort documentation is prepared and approved for all employees whose salary is funded fully or in part by Title I.