BOARD OF EDUCATION, CITY OF BUFFALO, NY

2022-001 Federal Program ? U.S. Department of Education, Passed through New York State Education Department, CFDA #84.425U, Education Stabilization Fund: American Rescue Plan Elementary and Secondary School Emergency Relief Fund. Criteria ? Salaries and wages of employees are deemed allowable costs under this grant when supported by appropriate time and attendance records as verification of work performed. Condition ? The Board was unable to provide timesheets for four employees for the July 16, 2021 pay period. Cause ? The Board implemented new payroll procedures during the selected pay period to try to reduce the amount of manual recordkeeping required. They found this system to be ineffective and subsequently reverted to their prior recordkeeping system. Effect ? The Board cannot provide support that costs incurred relative to the July 16, 2021 pay period were allowable. Questioned Costs ? None. Context ? Timesheets are necessary to prove allowability of payroll costs in a given pay period. Auditors? Recommendation ? We recommend that the Board ensure maintenance of appropriate timesheets for all individuals paid under Federal grants. View of Responsible Officials of the Auditee ? Management immediately reverted to its prior recordkeeping process after this pay period, when it realized the process did not work well for purposes of review and approval. The subsequent pay period?s timesheets were provided to the auditors, which show implementation of the former process and maintenance of appropriate records. Management believes this issue has already been rectified.

Finding 2022-001: CFDA #84.425U Education Stabilization Fund: American Rescue Plan Elementary and Secondary School Emergency Relief Fund Corrective Action: Immediately after the pay period in question, management reverted to its previous recordkeeping system to ensure compliance with documentation requirements. Contact: James Barnes, Interim CFO Anticipated Completion Date: Completed

2019-001 Allowable Costs - Time and Effort CFDA No. 84.010 ? Title I 84.027/ 84.173 ? Special Education Cluster 84.377 ? School Improvement Grant 84.424 ? Title IV Year Ended June 30, 2019 Passed through the New York State Education Department Federal Agency: U.S. Department of Education Criteria: The Board is required to establish and adhere to controls that comply with cost principles identified by the Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart E; Sections 200.430, 200.430(a) and 200.430(i) Standards for Documentation of Personnel Expenses. In addition, per the OMB Compliance Supplement, the Board is required to maintain time and effort distribution records in accordance with Uniform Guidance. Condition: The Board?s control process to ensure that payroll expenditures are properly allocated to each applicable grant program includes the preparation, maintenance and review of time and effort certifications. During the audit it was noted instances where certifications were not completed and reviewed timely, or, in some cases, were not completed at all. Cause: Insufficient monitoring of this control process to ensure the time and effort certifications were being completed and maintained in order to determine the allocation of time and effort to grant programs was updated in a timely manner. Effect: Multiple instances where time and effort certifications were not prepared timely or were unavailable for audit. Due to the lack of available documentation, we were unable to determine if all payroll expenditures tested under the major federal programs noted above were appropriately charged and allowable in order to be deemed in compliance with the Uniform Guidance. Failure to ensure compliance with the Uniform Guidance could have funding implications in the future. Questioned costs: Questioned costs cannot be reasonably determined. Context: This finding was identified through inquiries of management and audit testing related to allowable cost activities for the major federal programs noted above. Recommendation: We recommend that the Board review and establish written control procedures related their standards of documentation of personnel expenditures to ensure that the Board is in compliance with the requirements of the Uniform Guidance. In particular, we recommend the Board establish monitoring procedures over their time and effort certifications to confirm they are being completed and maintained in a timely manner, and to verify all time and effort is being appropriately charged to the related federal programs.

Accounting Department - Rm. 815 City Hall Phone (716) 816-3086 Fax (716) 851-3502 BUFFALO BOARD OF EDUCATION 815 City Hall Buffalo, New York 14202 December 13, 2019 Corrective Action Plan for Single Audit Report On December 13, 2019, Freed Maxick issued the Board of Education Single Audit Report on federal grants. Their report included a finding relating to time and effort cerfications. Finding: 2019-001 Allowable Costs- Time and Effort Auditor Observation: The Board?s control process to ensure that payroll expenditures are properly allocated to each applicable grant program includes the preparation, maintenance and review of time and effort certifications. During the audit it was noted instances where certifications were not completed and reviewed timely, or, in some cases, were not completed at all. Auditor Recommendation: We recommend that the Board review and establish written control procedures related to their standards of documentation of personnel expenditures to ensure that the Board is in compliance with requirements of the Uniform Guidance. In particular, we recommend the Board establish monitoring procedures over their time and effort certifications to confirm they are being completed and maintained in a timely manner, and to verify all time and effort is being appropriately charged to the related federal programs. Management Response: 1) There are three main areas that the District plans to include in its corrective action plan, each of which will begin immediately, but have different anticipated implementation dates: a) Initially, the District will revise and formalize written procedures related to the documentation of personnel expenditures, specifically related to time and effort certification collection, to be in compliance with the Uniform Guidance. A communication will be drafted to remind District staff involved in the process of the importance of their timely compliance, while a more robust monitoring system will be implemented. b) The District will also examine best practices relative to the duties, responsibilities, and reporting structure for grant managers, who are integral to the process of ensuring personnel and non-personnel expenditures are appropriately charged to their related federal programs. Necessary organizational changes will be implemented after this analysis. 2 c) Additionally, to improve the efficiency and accuracy of the time and effort collection process, the District will research electronic systems that comply with the Uniform Guidance time and effort collection requirements. This may include incorporating time and effort certifications into an automated time keeping system. 2) Responsible persons: a. Revise and formalize procedures for time and effort certifications - Keith Robertson, Assistant Superintendent of Budget and Grant Management b. Grants department reorganization - Keith Robertson, Assistant Superintendent of Budget and Grant Management c. Research and implement alternative methods to complete time and effort certifications - Julie Carbone, Financial Controller 3) Timing: a. Revise and formalize procedures for time and effort certifications ? February 2020 b. Grants department reorganization - August 2020 c. Research and implement alternative methods to complete time and effort certifications - December 2020