West Des Moines Community School District

2019-001 U.S. Department of Agriculture Passed Through State Department of Agriculture and State of Iowa Department of Education/ Child Nutrition Cluster: National School Breakfast Program (CFDA 10.553) National School Lunch Program (CFDA 10.555) Commodities-Noncash (CFDA 10.555) Summer Food Service Program For Children (CFDA 10.559) Federal Award Numbers: 77-1737 Federal Award Year: 2019, 2018, and 2017 Finding: The District has inadequate documentation for allowable costs pertaining to compensation expenditures of split-funded employees. Criteria: Title 2 U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) in Section 200.430 Compensation-personal services paragraph (i) Standards for Documentation of Personnel Expenses states? ?(vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e. estimates determine before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity?s written policies) are identified and entered into the records in a timely manner?.and (C) The non-Federal entity?s system of internal controls includes processes to review after-the-fact interim changes made to a Federal awards based on budget estimates. All necessary adjustments must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.? Condition: The District did not maintain documentation supporting the compensation expenditures charged to the program for eleven building secretaries that have a portion of their compensation charged to the Nutrition Program. An initial allocation percentage was determined for budget purposes. The employee timesheets do not separately indicate the time actually spent on the Nutrition program. Questioned Costs: $0 Context: There are eleven elementary building secretaries that have a portion of their compensation charged to the Nutrition Program. Effect: Noncompliance with program requirements could occur and not be timely identified. The program may not be properly charged for the actual time worked on the activity. Cause: The employees are building secretaries for the District?s elementary schools that have different time record keeping documentation than Nutrition program employees and are supervised by building principles rather than by the Nutrition department. Identification of as a Repeat Finding: This is a repeat finding. Recommendation: We recognize the District implemented requesting signed certifications from the elementary building secretaries as planned when the finding was initially identified in fiscal year 2017. We recommend the District implement a process to accurately document the actual hours worked for the Nutrition program. Response and Corrective Action Plan: Beginning July 1, 2019, only nutrition employees are charged to the program. New position were posted during fiscal year 2019 to eliminate having non-nutrition employees allocate time for the program.

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