Finding Text
Noncompliance and Material Weakness
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.430(a), which provides that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees:
• Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities;
• Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and
• Is determined and supported as provided in paragraph (i) of this section, Standard for Documentation of Personnel Expenses, when applicable.
Furthermore, Ohio Department of Education Grants Management Guidance 2014-002, revised on June 16, 2016 and August 29, 2019, further clarifies these requirements. The type of documentation required is based on the funding source and/or cost objective:
• Semi-annual certifications are allowed when an employee's compensation is funded by only one Federal grant. An employee funded by a federal grant and the General fund would fall under this category.
• Time and effort documentation is used when an employee's compensation is funded by more than one federal grant.
• The substitute system of collecting time and effort is used when an employee’s compensation is funded by more than one grant.
Due to a deficiency in internal policies and procedures over compliance, the District employee paid from the Special Education Cluster funds did not complete time and effort documentation for payroll expenditures in fiscal year 2023. This resulted in Special Education Cluster actual and projected expenditures of $9,300 not being supported with time and effort documentation. Based on the above guidance, the employee should have completed semi-annual certifications or time and effort documentation as their compensation was funded by a single Federal grant and the General fund.
The District should implement control procedures to verify that all District employees who perform work for federal cost objectives complete time and effort documentation. The documentation should be signed by each individual employee or a supervisor who has firsthand knowledge of the information contained in the documentation.