Contra Costa SELPA

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi‐funded positions by the time spent on each program and to semi‐annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: •Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; •Be incorporated into the official records of the non‐Federal entity •Reasonably reflect the total activity for which the employee is compensated by the non‐Federal entity, not exceeding 100% of compensated activities •Encompass both federally assisted and all other activities compensated by the non‐Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity’s written policy; •Comply with the established accounting policies and practices of the non‐Federal entity. •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. •Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund (Resource 3210 and 3213). All 6 (six) employees tested with salaries coded to the Education Stabilization Fund (Resource 3210 and 3213) during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi-funded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi‐annually for single funded employees and monthly for multi-funded employees. Corrective Action Plan: See next page for the corrective action plan.

Response to Audit Finding# 2023-001: Time and Effort Reporting (50000) Views of Responsible Officials: The Business Department in coordination with the Human Resources Department has developed standard operating procedures to meet the federal funding time accounting requirement. Employees paid from federal funds are required to complete multi-funded certification forms, whether 100% federally funded or less. The Site Principals will validate the multi-funded certification forms to ensure accuracy of time worked by the employee. All forms are to be signed by both the employee and Principal. In November and April of each year, the business department will review and complete all necessary certification forms.

2022-002

FINDING #2023-001: ALLOWABLE COSTS/COST PRINCIPLES – TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 ‐ Education Stabilization Fund Discretionary Grants: Elementary, Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi‐funded positions by the time spent on each program and to semi‐annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: •Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; •Be incorporated into the official records of the non‐Federal entity •Reasonably reflect the total activity for which the employee is compensated by the non‐Federal entity, not exceeding 100% of compensated activities •Encompass both federally assisted and all other activities compensated by the non‐Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non‐Federal entity’s written policy; •Comply with the established accounting policies and practices of the non‐Federal entity. •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. •Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund (Resource 3210 and 3213). All 6 (six) employees tested with salaries coded to the Education Stabilization Fund (Resource 3210 and 3213) during the fiscal year did not have any time certifications on file for the 2022-23 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi-funded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: Yes, this is a repeat finding of Finding #2022-002. Recommendation: We recommend they prepare time certification semi‐annually for single funded employees and monthly for multi-funded employees. Corrective Action Plan: See next page for the corrective action plan.

Response to Audit Finding# 2023-001: Time and Effort Reporting (50000) Views of Responsible Officials: The Business Department in coordination with the Human Resources Department has developed standard operating procedures to meet the federal funding time accounting requirement. Employees paid from federal funds are required to complete multi-funded certification forms, whether 100% federally funded or less. The Site Principals will validate the multi-funded certification forms to ensure accuracy of time worked by the employee. All forms are to be signed by both the employee and Principal. In November and April of each year, the business department will review and complete all necessary certification forms.

2022-002

FINDING #2022-002: ALLOWABLE COSTS/COST PRINCIPLES ? TIME AND EFFORT REPORTING (50000) Assistance Listing Number and Title: 84.425 - Education Stabilization Fund Discretionary Grants: Elementary, Secondary School Emergency Relief (ESSER) Fund Federal Grantor Name: U.S. Department of Education; Passed through California Department of Education Criteria: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, requires an accounting for personnel time on multi-funded positions by the time spent on each program and to semi-annually certify positions charged 100% to federal programs. Standards for Documentation of Personnel Expenses Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities ? Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; ? Comply with the established accounting policies and practices of the non-Federal entity. ? 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. ? Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards but may be used for interim accounting purposes. Condition: Auditor selected employees with salaries coded to the Education Stabilization Fund (Resource 3210, 3212, and 3213). All 7 (seven) employees tested with salaries coded to the Education Stabilization Fund (Resource 3210, 3212, and 3213) during the fiscal year did not have any time certifications on file for the 2021-22 year. It is required that the time certifications for single-funded employees be prepared twice a year and monthly for multi-funded employees. Cause: The District has not been following its policy for proper time accounting. Effect: The District is not in compliance. Questioned Costs: Although the District was not in compliance, we were able to review alternative documentation to determine that employees charged to the program were allowable. Repeat Finding: This is not a repeat finding. Recommendation: We recommend they prepare time certification semi-annually for single funded employees and monthly for multi-funded employees. Views of Responsible Officials: See Corrective Action Plan on following page.

Response to Audit Finding #2022-002: ALLOWABLE COSTS/COST PRINCIPLES - TIME AND EFFORT REPORTTNG (50000) Views of Responsible Officials: The Business office in coordination with the HR Department has developed standard operating procedures in order to meet the federal funding time accounting requirement. Employees paid from federal funds are required to complete multi-funded certification forms, whether 100% federally funded or less. The Principals will validate the multi-funded certification forms to ensure accuracy of time worked by the employee. All forms are to be signed by the employee and Principal. ln November and April of each year, the business department will review and file all certification forms.

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