Finding 2025-001
significant deficiency
- Program
- CHILD NUTRITION CLUSTER (10.553, 10.555); TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES (84.010)
- Compliance requirement
- Activities allowed or unallowed; Allowable costs/cost principles
- FAC record
- FY2025 audit on fac.gov
Finding text from the filing
2025-001 – Significant Deficiency in Internal Controls over Compliance – Time and Effort Documentation
Federal Programs: Child Nutrition Cluster (ALNs 10.553, 10.555) and ESEA Title I Part A, Improving Basic Program (ALN 84.010)
Federal Agencies: U.S. Department of Agriculture and U.S. Department of Education
Pass-through Entities and Identifying Numbers: Texas Education Agency (71402401, 71402501, 71302401, 71302501, 24610101189902, 25610101189902) and Texas Department of Agriculture (N/A)
Criteria: The District’s responsibility for internal controls over compliance extends to ensuring that adequate documentation is maintained related to time and effort documentation that supports proper allocation and is performed after-the-fact.
Cause: The District lacked adequate controls to ensure after-the-fact time and effort documentation was completed and that supervisory review of this documentation was performed and retained.
Effect: Without the applicable required time and effort documentation, payroll expenditures from federal awards could be for individuals, cost objectives, or activities not allowable under the federal programs, which could require the District to repay the federal funds.
Questioned Costs: None identified
Recommendation: The District should implement procedures to ensure that individuals paid from federal grants follow the time and effort documentation requirements as required under the District’s federal grant manual and 2 CFR 200.430. This includes clearly stating cost objectives, support for the allocation of payroll, documentation of time and effort subsequent to work being performed, and documentation to support an after-the-fact review.
View of Responsible Officials: Management agrees with the finding and will implement procedures to ensure all salary charges to federal programs are supported by the required documentation and supervisory review.
Condition: The District did not maintain adequate time and effort documentation as required by federal regulations for employees charging time to federal programs. Employees charging time to the Child Nutrition Program did not have documentation that an after-the fact review was performed. Additionally, employees charging time to Title I did not have documentation that time and effort was performed subsequent to the work being performed and an after-the-fact review was not performed.