EIN: 646000646
UEI: QP5ZDKCE6B93
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 2, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by January 2, 2025 (601 days ago).
What is a management decision? →Controls were not adhered to within the Office of Special Services to endure that time and effort documentation were maintained in accordance with 2 CFR section 200.430 and Appendix B of 2 CFR Part 225 – Selected Items of Cost. Time and effort documentation for Special Education Cluster employees who worked on one cost objective submitted annual certifications instead of the required semi-annual certifications. The following deficiencies were noted regarding personnel activity reports (PAR forms): (1) PAR forms were not reviewed for mathematical accuracy resulting in incorrect percentages of effort by cost objective; (2) comparisons of actual costs to budgeted distributions based on the monthly activity reports were not performed at least quarterly. The lack of review and comparison of actual cost to budget did not result in excess cost to the federal award. (3) the district did not review, and approved PAR forms within the timeline established by the district on a consistent basis. Date and signature documentation on at least one PAR form for each employee tested was signed and dated after the fifth of the following month. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200.430 – Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. In addition, Appendix B of 2 CFR Part 225 – Selected Items of Cost requires: (1) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee. (2) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports. These reports must meet the following standards: (a) They must reflect an after-the-fact distribution of the actual activity of each employee, (b) They must account for the total activity for which each employee is compensated, (c) They must be prepared at least monthly and must coincide with one or more pay periods, and (d) They must be signed by the employee. (e) Budget estimates or other distribution percentages determined before the services are performed do not qualify as support for charges to Federal awards but may be used for interim accounting purposes, provided that: (i) The governmental unit's system for establishing the estimates produces reasonable approximations of the activity actually performed; (ii) At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports are made. Costs charged to Federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent; and (iii) The budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances. Cause: A lack of oversight by program personnel resulted in documentation for time and effort reporting to not conform to requirements of set forth in 2 CFR 200.430 and Appendix B of 2 CFR Part 225. Effect: Failure to timely and properly prepare and review time and effort reporting could allow for improper charges to be made to the federal award which could result in disallowed charges to the program. Context: Fifteen (15) of fifteen (15) semi-annual certifications examined were prepared for the entire school year instead of on a semi-annual basis. Two personnel activity reports for one employee were not signed by the immediate supervisor. At one or more PAR forms for eight (8) of the eight employees monthly PAR reports tested were not signed and approved timely as defined by the district procedures. Repeat Finding: This is not a repeat finding. Auditor’s Recommendation: The school district should provide training to all employees working on Special Education grants to educate them on the requirements for documenting personnel time and effort both for semi-annual certifications and personnel activity reports. View of Responsible Officials and Planned Corrective Actions: See Auditee’s Corrective Action Plan
Show full finding ▾Hide full finding ▴Finding 2023-001 Material Weakness in Internal Control Over Compliance and Material Non-Compliance Federal Agency: U. S. Department of Education Pass-Through Entity: Mississippi Department of Education Federal Program: Special Education Cluster Special Education Grants to States 84.027 COVID 19 - Special Education Grants to States 84.027X Special Education Grants to States 84.173 COVID 19 - Special Education Grants to States 84.173X Compliance Requirement: Allowable Costs/Cost Principles Repeat Finding from Prior Audit? No Condition: Controls were not adhered to within the Office of Special Services to endure that time and effort documentation were maintained in accordance with 2 CFR section 200.430 and Appendix B of 2 CFR Part 225 – Selected Items of Cost. Time and effort documentation for Special Education Cluster employees who worked on one cost objective submitted annual certifications instead of the required semi-annual certifications. The following deficiencies were noted regarding personnel activity reports (PAR forms): (1) PAR forms were not reviewed for mathematical accuracy resulting in incorrect percentages of effort by cost objective; (2) comparisons of actual costs to budgeted distributions based on the monthly activity reports were not performed at least quarterly. The lack of review and comparison of actual cost to budget did not result in excess cost to the federal award. (3) the district did not review, and approved PAR forms within the timeline established by the district on a consistent basis. Date and signature documentation on at least one PAR form for each employee tested was signed and dated after the fifth of the following month. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200.430 – Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance) requires charges to federal award for salaries and wages to be based on records that accurately reflect the work performed. These records must (1) be supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated, (2) reasonably reflect total activity for which the employee is compensated, (3) encompass both federally assisted and all other activities compensated by the entity, (4) support the distribution of the employee’s wages among specific cost objectives if the employee works on more than one federal award, (5) be reconciled with payroll budget estimates with necessary adjustments made to accounting records to ensure that excess costs are not charged to federal programs. In addition, Appendix B of 2 CFR Part 225 – Selected Items of Cost requires: (1) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee. (2) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports. These reports must meet the following standards: (a) They must reflect an after-the-fact distribution of the actual activity of each employee, (b) They must account for the total activity for which each employee is compensated, (c) They must be prepared at least monthly and must coincide with one or more pay periods, and (d) They must be signed by the employee. (e) Budget estimates or other distribution percentages determined before the services are performed do not qualify as support for charges to Federal awards but may be used for interim accounting purposes, provided that: (i) The governmental unit's system for establishing the estimates produces reasonable approximations of the activity actually performed; (ii) At least quarterly, comparisons of actual costs to budgeted distributions based on the monthly activity reports are made. Costs charged to Federal awards to reflect adjustments made as a result of the activity actually performed may be recorded annually if the quarterly comparisons show the differences between budgeted and actual costs are less than ten percent; and (iii) The budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances. Cause: A lack of oversight by program personnel resulted in documentation for time and effort reporting to not conform to requirements of set forth in 2 CFR 200.430 and Appendix B of 2 CFR Part 225. Effect: Failure to timely and properly prepare and review time and effort reporting could allow for improper charges to be made to the federal award which could result in disallowed charges to the program. Context: Fifteen (15) of fifteen (15) semi-annual certifications examined were prepared for the entire school year instead of on a semi-annual basis. Two personnel activity reports for one employee were not signed by the immediate supervisor. At one or more PAR forms for eight (8) of the eight employees monthly PAR reports tested were not signed and approved timely as defined by the district procedures. Repeat Finding: This is not a repeat finding. Auditor’s Recommendation: The school district should provide training to all employees working on Special Education grants to educate them on the requirements for documenting personnel time and effort both for semi-annual certifications and personnel activity reports. View of Responsible Officials and Planned Corrective Actions: See Auditee’s Corrective Action Plan
Finding 2023-001 a. Name of Contact Person Responsible for Corrective Action: Rhonda D. Locke b. Corrective Action Planned: • Special Education Director and Assistant Special Education Director will attend the Annual Fiscal Conference presented by OSEP through MDE. • Special Education Director and Assistant Special Education Director will train all certified staff in the proper method to complete monthly personnel activity reports [to include but not limited to: how to calculate percentages of effort by cost objective, expected timelines, and proper documentation]. • Special Education Director and Assistant Special Education Director will train all non-certified staff in the proper method to complete semi-annual certification reports [to include but not limited to: how to complete semi annual certification reports, expected timelines, and proper documentation/signatures]. • Special Education Director and Assistant Special Education Director will train the bookkeeper in the proper procedures for collecting and maintaining monthly personnel activity reports and semi-annual certification reports. • Special Education Director and/or Assistant Special Education Director will provide new PARs spread sheets to ensure all formulas for calculation of hours are correct and without corruption. • Special Education Director will review and sign each of the PARs monthly to ensure percentages of effort by cost objective are in line with expected activity compensation, signatures are provided by each employee, and each completion date is prior to the 5th of the month. • Assistant Special Education Director and/or Bookkeeper will contact each of the assistant teachers to provide an advanced reminder regarding the completion of the semi-annual certification reports no later than end of business on the last working day of December and May. c. Anticipated Completion Date: July 3, 2025
FAC accepted this audit on March 19, 2017 — management decision was due September 19, 2017.
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2015-002
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2015-001
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