Liverpool Central School DistrictLocal Government

Criteria: According to the Uniform Guidance in CFR Part 200, Part III, Section M - Subrecipient Monitoring, a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Internal controls should provide reasonable assurance that the District complies with subrecipient monitoring requirements according to the Uniform Guidance. Cause/Condition: In the case of one subaward tested, the District did not obtain appropriate documentation from the subrecipient to provide evidence as to the authorized use of the funds per requirements of the program. Current internal control policies and procedures were not operating effectively to ensure compliance. Effect: The District was not in compliance with subrecipient monitoring requirements in accordance with the Uniform Guidance. Context: The subaward tested for which the District did not obtain appropriate documentation from the subrecipient was an instance where the subaward was paid to another area school district. This was the only instance of a subaward to another area school district in the population. Recommendation: We recommend management enhance existing policies and procedures for the review of documentation submitted to the District to satisfy subrecipient monitoring requirements. Questioned Costs: None. Management?s Response: The District will improve enforcement of our current system where subrecipients of flow-through funds will provide documentation as to how the District's monies will be allocated for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.

Criteria: Internal controls should provide reasonable assurance that the District complies with activities allowed or unallowed and allowable costs and cost principles according to the Uniform Guidance. Cause/Condition: The District's current policies and procedures are not operating effectively to ensure that salary related to hourly employees charged to the Title I Grant is supported by hours worked and approved by a supervisor. Instances of timesheets not being signed as approved by a supervisor were noted. Effect: The District did not have proper documentation of internal controls over compliance with activities allowed or unallowed and allowable costs and cost principles requirements. Recommendation: We recommend management develop and document policies and procedures that will allow for an appropriate approval of timesheets of hourly employees in the event of the primary supervisor being unavailable. Existing policies and procedures should also be reviewed with all supervisors to ensure compliance. Questioned Costs: None. Management?s Response: In response to the finding relating to instances of timesheets not being signed as approved by a supervisor for salary related to hourly employees charged to the Title I Grants the District will modify our policies and procedures to allow for an appropriate approval of timesheets of hourly employees in the event of the primary supervisor being unavailable. In the future if these instances occur an approval will be obtained from another Principal in the High School, there are 6 Principals in the High School/Annex buildings, and for the other buildings an Executive Director and if an Executive Director is not available the Deputy Superintendent will approve the hourly employees timesheets. If staff are being paid from a grant, the timesheet that needs approval will be sent to the Executive Director in charge of the grant, if that person is available. If the Grant Administrator is not available the approver should verify the staff being paid out of a particular grant. with the Deputy Treasurer, Dan Burns. In the event of another Executive Order, requiring all non-essential workers to work remotely we will accept email approval from the Building Administrators or other Administrators approving the hourly timesheets. This policy was communicated via email to all relevant parties on September 22, 2020.