Guttenberg Board of EducationLocal Government

Finding 2021-001 Information on the federal program: Title I, Part A ? Improving Basic Programs; Reallocated Title I, Part A ? Improving Basic Programs, CFDA #84.010A, Grant Period 7/1/19 ? 6/30/20 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. 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 not all the District?s Title I funded personnel prepared detailed time and activity reports 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 employee time and effort documentation did not detail the Title I activities performed and charged to the federal program and did not contain the signature of the employee and/or the supervisory official. Effect: 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 funded personnel did not consistently prepare detailed time and effort documentation of the Title I activities performed and charged to the federal program and the signature of the employee and/or the supervisory official were not always present. Recommendation: The Guttenberg Board of Education should implement policies and procedures to ensure that Title I funded personnel prepare time and activity reports 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 Guttenberg 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.

Finding 2020-001 Information on the federal program: Title I, Part A ? Improving Basic Programs; Reallocated Title I, Part A ? Improving Basic Programs, CFDA #84.010A, Grant Period 7/1/19 ? 6/30/20 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. 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. -130- K-6 Page 5 of 8 TOWN OF GUTTENBERG BOARD OF EDUCATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR THE FISCAL YEAR ENDED JUNE 30, 2020 (continued) Section III ? Federal Awards and State Financial Assistance Findings and Questioned Cost Finding 2020-001 (continued) Condition: There were instances in which not all the District?s Title I funded personnel prepared detailed time and activity reports 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 employee time and effort documentation did not detail the Title I activities performed and charged to the federal program and did not contain the signature of the employee and/or the supervisory official. In addition, there were various District Title I funded personnel whose time and effort documentation were either not prepared and submitted or were simply not provided for multiple payroll periods. Effect: 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 noncompliance and increase the District?s risk of loss of funding. Cause: The District?s Title I funded personnel did not consistently prepare detailed time and effort documentation of the Title I activities performed and charged to the federal program and the signature of the employee and/or the supervisory official were not always present. In addition, there were District Title I funded personnel whose time and effort documentation were either not prepared and submitted or were simply not provided for multiple payroll periods. Recommendation: The Guttenberg Board of Education should implement policies and procedures to ensure that Title I funded personnel prepare time and activity reports 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 Guttenberg 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.

Finding 2020-002 Information on the federal program: Title I, Part A ? Improving Basic Programs; Reallocated Title I, Part A ? Improving Basic Programs, CFDA #84.010A, Grant Period 7/1/19 ? 6/30/20 Compliance/Internal Control over Compliance: Allowable Costs/Cost Principles Criteria or specific requirement: As per UGG ?200.430, Compensation ? personal services, the Guttenberg Board of Education must approve personnel partially or fully funded by Title I monies via Board Resolution. The Board Resolution must state the Title I funded personnel?s name, salary, work location, and the funding percentage for each program. Condition: The District did not prepare Board Resolutions that approved all Title I funded personnel in the above described format. Questioned Costs: Unknown Context: Based on the results of our audit testing, we noted that the District was required to prepare and submit the Board Resolutions as described above. However, it was noted that not all resolutions detailed the employee and the allocation of their compensation to be funded through Title I funding. Effect: 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, increase the risk of non-compliance and exposes the Board of Education to the risk of loss of funding. Cause: The Guttenberg Board of Education was unable to provide or did not prepare Board Resolutions that approved all Title I funded personnel. Recommendation: The Guttenberg Board of Education should implement policies and procedures to ensure that all employees participating in the Title I program are approved via Board Resolution, and that the Board Resolution stipulates the partial or full funding of the employees? salaries through the distribution of Title I monies. Management?s response: The Guttenberg Board of Education will ensure that all required allowable cost/cost principle requirements are met by approving, via Board Resolution, the employee, their position and the allocation of their compensation to be paid by the applicable Title I allocation.