Holland Central School DistrictLocal Government

2021-001 Activities Allowed or Unallowed and Allowable Costs - Time and Effort Documentation Assistance Listing No. 84.027/84.173: Special Education Cluster Year Ended: June 30, 2021 Federal Agency: U.S. Department of Education Passed through the New York State Education Department Criteria: The District 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 District is required to maintain time and effort distribution records in accordance with Uniform Guidance. Condition: The District uses time and effort certifications as their control process for ensuring that payroll expenditures are properly allocated to each applicable grant program. During the audit it was noted that some certifications were unavailable and one instance was documented incorrectly. 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 and charged accurately. Effect: Ineffective controls could result in future allocation of unallowable costs or activities to the program. Questioned costs: Questioned costs cannot be reasonably determined. Context: This finding was identified through inquiries of management and audit testing related to activities allowed or unallowed and allowable cost for the major federal program noted above. Recommendation: We recommend that the District review and establish written control procedures related their standards of documentation of personnel expenditures to ensure that the District is in compliance with the requirements of the Uniform Guidance. In particular, we recommend the District 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. Views of Responsible Officials and Planned Corrective Actions: Time and Effort Certifications from employees who were grant funded or partially grant funded in 2020-2021 were the responsibility of the Special Education Director for IDEA Grants, and the Director of Curriculum for the Title and UPK Grants. These directors were also responsible for submitting any grant amendments for their federal programs. When both of these directors left their positions with the district the summer of 2021, the Business Administrator changed the responsibility of collecting the time and effort certifications for the following school year to the District Treasurer. There also was a typo on one of the certification forms, but that has been corrected and the employee verified the correct percentage of her time allocated to one of the grants. The District has reviewed and established written control procedures related to its standards of documentations of personnel expenditures to ensure the District is in compliance with the Uniform Guidance. The Business Official also reviews each grant quarterly to ensure all time and effort is being appropriately charged to the related federal programs. As of July 1, 2021, the Business Official reviews the grants with the Special Education Director and the Director of Curriculum, and copies of all amendments are now filed in the Business Office.