august 10, 2012. overview during the last several years, federal agencies have put more emphasis on...
TRANSCRIPT
August 10, 2012
OverviewDuring the last several years, federal
agencies have put more emphasis on states’ responsibility to provide fiscal oversight of federal funds that they grant to sub-recipients
Federal grants and the requirements have been around for decades
At times LEAs do not comply with certain federal fiscal requirements because they are unaware of them and unaware of the potential loss of funds
OverviewThis training is intended to:
Assist fiscal managers with fiscal administration of those grants
Assist auditors with the audit requirements of federal and state aid received by 2r charter schools
This training does not address:All areas of grant managementSpecific federal program requirements that
accompany every grantGeneral accounting principles
What are the types of requirements that apply to federal grants management and where are they found?
Federal government established uniform procedures for the use of federal funds that are meant to minimize the potential for fraud or misuse of federal funds
Types of Requirements that Apply to Federal GrantsCode of Federal Regulations (CFR)
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?sid=b248f3949e2c06c722742aeb38c17562&c=ecfr&tpl=/ecfrbrowse/Title34/34tab_02.tpl
Education Department General Administrative Regulations (EDGAR)Title 34 (Education), CFR, Parts 74-86 and 97-99http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.html
Types of Requirements that Apply to Federal GrantsAdministration
Office of Management and Budget (OMB) Circular A-102 Common ruleIdentify the administrative systems and procedures
that must be in place to receive, expend, account for and report on the uses of federal funds
Incorporated OMB Circular A-102 into 34 CFR part 80
EDGAR Title 34 (Education), CFR, Part 80Establishes uniform administrative rules for federal
grants to state, local and Indian tribal governments
Types of Requirements that Apply to Federal GrantsManagement
EDGAR Title 34 (Education), CFR Part 76 State-Administered ProgramsHow funds are to be distributed to LEAsProgram or fiscal conditions that must be met
on the state/local levelWhen obligations are madeHow grant recipients are accountable for
fiscal reporting and for the reporting of the program
Types of Requirements that Apply to Federal GrantsCost Principles
OMB Circular A-87 Identify how federal funds can be expended
Types of Requirements that Apply to Federal GrantsOffice of Management and Budget Circularshttp://www.whitehouse.gov/omb/circulars_default/
OMB Circular A-87 - Cost PrinciplesOMB Circular A-102 - Common ruleOMB Circular A-133 - Audit State/LocalOMB Circular A-133 - Compliance Supplement
Education Department General Administrative Regulations (EDGAR)34 CFR Part 80.20(a)Fiscal control and accounting procedures
must be sufficient to:(1) Permit preparation of reports required(2) Permit tracing of funds to a level of
expenditures adequate to establish that such funds have not been used in violation of the applicable standards.
Education Department General Administrative Regulations (EDGAR)(b)The financial management systems must
meet the following standards:Financial ReportingAccounting RecordsInternal ControlBudget ControlAllowable CostSource DocumentationCash Management
Education Department General Administrative Regulations (EDGAR)(c)’An awarding agency may review the
adequacy of the financial management system of any applicant for financial assistance as part of a preaward review or at any time subsequent to award.’
Financial Reporting“Accurate, current, and complete disclosure of
the financial results of financially assisted activities must be made in accordance with the financial reporting requirements of the grant or subgrant.”
Financial ReportingIndividuals who prepare, review and approve
reports possess knowledge, skills and abilities necessary
Written policies and procedures to establish responsibilities and ensure proper monitoring, verification and reporting
Review and approval of reports by appropriate individual prior to submission (separate from preparer)
Accounting system set up to provide the financial information as needed for reporting
Accounting Records“Grantees and subgrantees must maintain
records which adequately identify the source and application of funds provided for financially-assisted activities. These records must contain information pertaining to grant or subgrant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income.”
Accounting RecordsThe foundation of fiscal management of a federal
grant is the grant’s accounting recordCommon errors
School does not create an accounting record for each grant and post expenditures to that account. Rather the school just identifies expenditures for grant reimbursement
Expenditures are originally reported to a general account and later reclassified
Accounting records do not integrate and track against the grant’s approved budget
Accounting record cannot be used for budget control when expenditures are not posted to the grant as they occur and when they are not tracked against an approved budget
Accounting RecordsAn accounting record that incorporates the
amount of the award and approved budget. At a minimum each general area of planned expenditures
Provisions should be made to track expenditures and available balances against each budget line to exercise budget control
An accounting system that provides separate identification of federal and non-federal transactions and allocation transactions applicable to both
Accounting RecordsReports provided timely to administration or
governance board for review and appropriate action
Easy access to accurate information on grant expenditures and comparison to grant budget and claims
Recording of expenditures to appropriate account when incurred to assist with budget control
Tracking ExpendituresWisconsin Uniform Financial Accounting
Requirements (WUFAR)Used for reporting to DPIObject
Service or commodity acquired Salaries, fringe benefits, purchased services, non-capital
objects, capital objects, insurance and judgmentsFunction
Purpose for which an object is used Instruction, support services
Project Identify the activity IDEA, Title I, special education state aid
Accounting RecordsPer EDGAR) §76.730 school shall keep
records that fully show:Amount of funds under the grantHow the funds will be usedTotal cost of the projectShare of the cost provided from other sourcesOther records to facilitate an effective audit
Internal Control“Effective control and accountability must be
maintained for all grant and subgrant cash, real and personal property, and other assets. Grantees and subgrantees must adequately safeguard all such property and must assure that it is used solely for authorized purposes.”
34 CFR 80.36(a) “When procuring property and services under a grant, a State (LEA) will follow the same policies and procedures it uses for procurements from its non-Federal funds.”
Internal ControlInternal controls that separate duties from
being performed by one individual and strengthen accountability for all cash activityNo one person should be able to both authorize
a transaction and record the transaction in the accounting record.
Controls over processing of cash receipts, disbursements and payroll.
Internal ControlA fiscal transaction should be approved:
By a person (program manager) who can attest that the planned/actual expenditure is allowable and approved under the grant and
By another person (business manager/accountant) who can attest to the availability of funds and to its consistency with the approved budget and who enters the transaction into the fiscal record
Each of these individuals should initial or sign the documentation for the transaction
Internal ControlExamples:
Small office of 1 or 2 people requires greater administrative and board participation in the day to day operations
One individual should not be creating PO’s, receiving the goods, authorizing payment and reconciling the bank statement.
Use authorized vendor listHave the administrator or board member review
and approve all expendituresUse pre-numbered checksLimit petty cash transactionsReview and authorize credit card transactions
Internal ControlCommon errors:
Written policy that is:Non-existentOutdatedNot being implemented
Do not document the review of fiscal transactions by two people
Do not routinely require approval of or posting of expenditures
Budget Control“Actual expenditures or outlays must be
compared with budgeted amounts for each grant or subgrant. Financial information must be related to performance or productivity data, including the development of unit cost information whenever appropriate or specifically required in the grant or subgrant agreement. If unit cost data are required, estimates based on available documentation will be accepted whenever possible.”
Budget ControlGrant funds cannot be expended on an
activity until that activity has been approved
When grant is awarded, school has authority to fund the activities at the amounts approved in the application.
Budget ControlDuring the year, funding strategies may
change for a variety of reasonsApproval shall be obtained whenever any of
the following changes is anticipated under a non-construction award:Revision which would result in the need for
additional fundingCumulative transfers among direct cost
categories, or among separately budgeted programs, projects, functions, or activities which exceed or are expected to exceed ten percent of the current total approved budget
Budget ControlCommon error:
Program managers sometimes authorize expenditures for activities that are not part of the approved application or
Make expenditures in anticipation of submitting an amendment
Budget ControlAccounting records should have budget lines for
each general area of planned expendituresProvision to track expenditures and available
balances against each budget line to exercise budget control
Post expenditures as they occur directly to the appropriate budget line within the grant’s accounting record
Whenever changes are planned, review whether an amendment is required and obtain approval for proposed changes before expenditures are made
Allowable Cost“Applicable OMB cost principles, agency
program regulations, and the terms of grant and subgrant agreements will be followed in determining the reasonableness, allowability, and allocability of costs.”
Allowable CostPolicy for procedures regarding
determination of an allowed cost that include:Properly accounting for the expenditure
upfront and determining it as an allowed cost per cost principles when incurred
Review of expenditures claimed for reimbursement by someone other than the individual preparing the claim
Allowable CostCommon error:
Salaries and Wages - no process in place for time and effort reporting Employees that are expected to work solely on a
single federal award or cost objective supported by periodic certifications that the employee worked solely on that program for period covered by certification
Employees that work on multiple activities or cost objectives supported by personnel activity reports or equivalent documentation
Source Documentation“Accounting records must be supported by such
source documentation as cancelled checks, paid bills, payrolls, time and attendance records, contract and subgrant award documents, etc.”
Source DocumentationPolicies and procedures:
Periodic certifications or personnel activity reports
Adequate source documentation to support amounts and items reported
All goods or services are initiated, approved and paid for through the established disbursement internal controls which should include a purchase order, packing slip if applicable, invoice and school check or electronic transfer
Cash Management“Procedures for minimizing the time elapsing
between the transfer of funds from the U.S. Treasury and disbursement by grantees and subgrantees must be followed whenever advance payment procedures are used. Grantees must establish reasonable procedures to ensure the receipt of reports on subgrantees’ cash balances and cash disbursements in sufficient time to enable them to prepare complete and accurate cash transactions reports to the awarding agency. When advances…”
Cash ManagementBasic standard – methods and procedures for
payment shall minimize the time lapsing between the transfer of funds and disbursement by the school
No expenditure may be claimed for reimbursement unless it is obligated
Report expenditures on a timely basis
EDGAR §76.707When Obligations are MadeIf the obligation is for - The obligation is made -(a) Acquisition of real or personal
propertyOn the date on which the school makes a binding written commitment to acquire the property.
(b) Personal services by an employee of the school
When the services are performed.
(c) Personal services by a contractor who is not an employee of the school
On the date on which the school makes a binding written commitment to obtain the services
(d) Performance of work other than personal services
On the date on which the school makes a binding written commitment to obtain the work.
(e) Public utility services When the school receives the services
(f) Travel When the travel is taken.
(g) Rental of real or personal property
When the school uses the property.
(h) A pre-agreement cost that was properly approved by the State under the cost principles identified in 34 CFR 74.171 and 80.22.
EDGAR §80.32 Equipment
May be used in the program or project for which acquired as long as needed, whether or not the project or program continues to be supported by federal funds
When no longer needed may be used in other activities currently or previously supported by a federal agency
EDGAR §80.32 Equipment
Shall be available for use on other projects or programs currently or previously supported by federal government providing that use will not interfere with work on the projects or program for which it was originally acquired
When acquiring replacement equipment, may use the equipment to be replaced as a trade-in or sell the property and use the proceeds to offset the cost of the replacement property subject to the approval of DPI
Property ManagementRecords must be maintained that include the
following:Description of the propertySerial number or other identification numberSource of propertyWho holds titleAcquisition dateCost of the propertyPercentage of federal participation in the cost of the
propertyLocationUse and condition of the propertyAny ultimate disposition data including date of
disposal and sale price of the property
Property ManagementPhysical inventory of property must be taken
and reconciled with the property records at least once every two years.
A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft. Any lost, damage, or theft shall be investigated.
Adequate maintenance procedures must be developed to keep the property in good condition.
Property Management
If school is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return.
Property ManagementWhen original or replacement equipment
acquired under a grant is no longer needed for original project or program or for other activities currently or previously supported by a federal agency, disposition of the equipment will be made as follows: 1) Current fair market value < $5,000 may be
retained, sold or disposed of with no further obligation to the federal government.
2) Current fair market value > $5,000 may be retained or sold and the federal government shall have a right to an amount calculated by multiplying the current market value or proceeds from sale by the federal share of the equipment.
Contact Information for Program Accountants
DPI Website – Divisions and Teams – School Management Services – Federal Aids and Audit
Each Accountant Assigned Specific GrantsAccounting Staff and Assignments
http://dpi.wi.gov/sms/fedasign.htmlLink to Aids Register Codes
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Federal Aids and Audit Section
Financial Management Handbook for Federal and State Grant Programs
http://dpi.wi.gov/sms/handbook.html
Fiscal Requirements and Procedures to Assist Grant Recipients
Proper Disbursement, Accounting and Accountability for Federal and State Funds
48
Federal Aids and Audit Section
Claiming for Grant Funds – Accountants
Claims Must Match BudgetsFinal Claim Report Must be SignedCertifying Accuracy of the ReportFiscal Claim Report PI-1086
http://dpi.wi.gov.sms/pi-1086.htmlInstructions
http://dpi.wi.gov.sms/pdf/instruct.pdf49
Claims
• To receive reimbursement for grant expenditures submit a Program Fiscal Report (Form PI-1086).
• Quarterly claims are recommended, however, you can submit monthly claims.
• A final claim is due 90 days after the end of the project. Most programs require expenses to be paid by June 30 and final claims submitted by September 30.
• An authorized signature is required on the final claim.
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Claims
A signed copy of the final claim can be submitted by: MAIL: Department of Public Instruction
Federal Aids and Audit Section P O Box 7841
Madison WI 53707-7841 FAX: 608/267-9207 (Attn. to Grant Accountant) E-MAIL: To the DPI accountant assigned to the program. See the following link for the assignment sheet:
http://dpi.wi.gov/sms/fedasign.html
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District / Agency No. CFDA No. or State Statute Report for Period Ending
9999 84.987 8/31/2011Grant Number Project Beginning Date Project Ending Date
12-123456789-1 7/1/2011 6/30/2012
Account CodeFund-Obj.-Func.-Proj.
xx-xxx-xxxxxx-400 10,000.00 10,000.00
xx-xxx-xxxxxx-400 2,000.00 6,000.00
xx-xxx-xxxxxx-400 6,000.00 14,000.00
xx-xxx-xxxxxx-400 1,500.00 5,500.00
19,500.00$ 35,500.00$
Total Funds Received to Date
Total Disbursements to Date
Cash on Hand at Endof Period
5,500.00$ 19,500.00$ (14,000.00)$ $ 14,000.00
Date Signed Mo./Day/Yr.
Matching Funds If Appli-cable Documentation on file at District Office
Report Type Check all that apply
CERTIFICATION
$
$TOTALS
Email Address
Unliquidated Encumbrances Payables
Unencumbered Balance
INSTRUCTIONS: Report project transactions by account.
WISCONSIN DEPARTMENT OF PUBLIC INSTRUCTIONSCHOOL MANAGEMENT SERVICES TEAMFEDERAL AIDS AND AUDIT SECTIONP.O. BOX 7841MADISON, WI 53707-7841 Fax: (608) 267-9207
Title of District / Agency Administrator or Designee Print or type
55,000.00$
Phone Area/No.
999-999-9999
Instruction - Fringe Benefits
Notice of Award Program Name
Total Disbursementsto Date
Instruction - Purchased Services
Aaron Rogers
7,000.00
SUMMARY
Account Name Approved Budget
Instruction - Salaries
Any District Legal NameDistrict / Agency Legal Name
Program
Instruction - Non Capital Objections
Name of District / Agency Administrator or Designee Print or type
Name of Person Preparing this Report
20,000.00
8,000.00
20,000.00
DPI USE ONLYAmount Approved
Cash Summary
Signature of District / Agency Administrator or Designee
http://dpi.w i.gov/sms/pdf/instruct.pdf
Mail to: Wisconsin Department of Public InstructionPROGRAM FISCAL REPORTPI-1086 (Rev. 08-11)
Refer to instructions at:
BY SIGNING THIS REPORT, I CERTIFY that it is true, complete, and accurate to the best of my know ledge. I am aw are that any false, f ictitious, or fraudulent information may subject me tocriminal, civil, or administrative penalties. (U.S. Code, Title 18, Section 1001)
Amount RequestedThis Claim Advance Final Claim
Partial Claim Revised Final
Insert four digit code(For LEA's only)
School District/ University/ Agency Name
FOR DISTRICTS ---use WUFAR account codes
If FINAL, must be signed by authorized person
This amount needs to be filled in, insert amount to be claimed only
use last approved budget for claims
• Instructions for completing the Program Fiscal Report
• District Number: LEAs use the 4-digit agency code.
• District/Agency Legal Name: Name of LEA.• CFDA Number or State Statute• Report for Period Ending: Report month and
year through which report is completed. • Project Grant Number: Report Grant
Number from Notification of Grant Award.
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Claim Instructions
• Program Name: For example, ESEA Title II B Math & Science Partnership.
• Project Beginning Date: Beginning date as specified in Notification of Grant Award.
• Project Ending Date: Ending date as specified in Notification of Grant Award.
• Account Code: WUFAR Codes for LEAs.
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Claim Instructions
• Account Name: Report categories from the Budget Summary page (example, PI-9550-IIB) from application.
• Approved Budget: Enter the budget amounts as approved from the application Budget Summary page.
• Unliquidated Encumbrances: Report unpaid obligations (i.e., payables, open purchase orders, personal services contracts, etc.). Encumbrances should be liquidated on the final report.
• Total Disbursements: Report the cumulative total of disbursements made to date.
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Claim Instructions
• Unencumbered Balance: Report the amount of funds that have neither been obligated nor disbursed.
• Cash Summary: Report total funds received to date, disbursed and remaining.
• Amount Requested: Enter amount requested for this claim.
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Claim Instructions
Federal Grant Guidance is available at: http://dpi.wi.gov/sms/handbook.html
Federal Aids & Audit Personnel and Staff Assignments:http://dpi.wi.gov/sms/fedasign.html
Program Fiscal Report (PI-1086) and Instructions:http://dpi.wi.gov/sms/pi-1086.html
Related Links:http://dpi.wi.gov/sms/relatedlinks.html
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Audit RequirementWis. Stat. 118.40 (2r)(b)(2)
“A charter shall include all of the provisions specified under sub.(1m)(b)3. to 14.”Wis. Stat. 118.40 (1m)(b)11
“The manner in which annual audits of the financial and programmatic operations of the school will be performed.”
2r Independent Charter Schools2r charter schools are considered a local educational
agency. Wis. Stat. 115.775; “….an operator of a charter school under s. 118.40(2r) is a local educational agency, as defined in 20 USC 1401 (19)...”
United States code: title 20,1401 defines an LEA as: “local education agency” means a public board of education or other public authority legally constituted within a State for either administrative control or direction of, or to perform a service function for, public elementary schools or secondary schools in a city, county, township, school district, or other political subdivision of a State, or for such combination of school districts or counties as are recognized in a State as an administrative agency for its public elementary schools or secondary schools.”
Federal Single AuditNon-Federal entities that expend $500,000 or
more in a year in Federal awards shall have a single or program-specific audit conducted for that year in accordance with the provisions of OMB Circular A-133.
Non-Federal entities that expend less than $500,000 a year in Federal awards are exempt from Federal audit requirements for that year,, but records must be available for review or audit by appropriate officials of the Federal agency, pass-through entity, and General Accounting Office (GAO).
Federal and State AidAids Register -
http://dpi.wi.gov/sfs/online_ar.htmlReflects payments the school received from the
department during the year. Does not reflect year end receivables but does include prior year end receivables. STRICTLY cash basis!
State Single Audit GuidelinesAvailable at:
http://www.doa.state.wi.us/section.asp?linkid=81&locid=167
*SSAG Summary 2011Department of Public Instruction Appendix to the State Single Audit
Guidelines for Programs from the Department of Public Instruction
State Single Audit Guidelines2.1 Audit requirement for DPI programs
Audits of agencies receiving state aid for programs from the Department of Public Instruction will be in accordance with the following standards prescribed by the department. These agencies include school districts, 2r independent charter schools, cooperative educational services agencies (CESA) and county children with disability education boards (CCDEB).
State Single Audit Guidelines State Single Audit Guidelines – Agencies receiving
state aid that have audits in accordance with OMB Circular A-133 “Audits of States, Local Governments, and Non-Profit Organizations” and that receive more than $25,000 in department funds, need to have audits in accordance with the State Single Audit Guidelines, including this appendix to the Guidelines.
Wisconsin Public School District Audit Manual – Agencies with designated major state programs must have an audit of compliance with the requirement applicable to those designated state programs and must also issue a report on its system of internal control over compliance in accordance with the Wisconsin Public School District Audit Manual.
State Special Education AidThe Department of Public Instruction has
designated certain programs to be state major programs when agencies receive these programs directly from the department. In the parlance of OMB Circular A-133, the department considers these programs to be Type A programs that cannot be treated as low risk programs. Therefore, these programs are to be tested as major programs in all audits for which the auditee receives funding for these programs directly from the department:
Designated major programs Section 3.1 General Aids (not applicable to 2r charter
schools)Section 3.2 Special Education and School Age Parents
Aid
Audit RequirementWis. Stat. 115.88(1m)(am)
“(am) Subject to par. (b), if the operator of a charter school established under s. 118.40 (2r) operates a special education program and the state superintendent is satisfied that the operator of the charter school is complying with 20 USC 1400 to 1491o, the state superintendent shall certify to the department of administration in favor of the operator of the charter school a sum equal to the amount that the operator of the charter school expended during the previous school year for salaries of full-time or part-time licensed teachers, licensed coordinators of special education, school nurses, licensed school social workers, licensed school psychologists, licensed school counselors, paraprofessionals, licensed consulting teachers to work with any teacher of regular education programs who has a child with a disability in a class and any other personnel, as determined by the state superintendent, as costs eligible for reimbursement from the appropriation under s. 20.255 (2)(b). The state superintendent may audit costs under this paragraph and adjust reimbursement to cover only actual, eligible costs.”
Auditing State Special Education AidAudit Program available at:
http://dpi.wi.gov/sms/cs_currentChrSchs.html
Reports Needed
Audit Procedures
Reporting
Auditing State Special Education AidReports Needed
All special education excess costs identified Includes all costs and not just those eligible for state
categorical aid Special Education claim filed with DPI
May not be available at time of audit Special Education Categorical Aid Eligible Costs
Resource guide on what is eligible Special education license staff listings (valid and
non-valid) Online or per request from DPI
Auditing State Special Education AidState Special Education Categorical
Project Codes:Project 011 - State Categorical Aid Aidable
Cost Project 019 - Non-Aidable Cost Project 340 - Cost Reimbursable by Direct
Federal IDEA Monies Project 810 - Cost Reimbursable by Direct
Federal ARRA Monies
Auditing State Special Education AidAudit Procedures
Verify claim to expenditures in general ledgerNo valid license list
http://dpi.wi.gov/sfs/safrlinks.html Do not need to test the individuals on the list Send an e-mail to DPI with the salaries and benefits reported If individual was incorrect on PI-1202, obtain written
representation from school administrator or individual authorized to complete the PI-1202
Perform payroll test Valid license list Payroll register and general ledger
Review: Personal services costs or employee travel Payments to non-governmental agencies Pupil transportation costs Vehicle acquisition
Auditing State Special Education AidReporting
Questioned Cost Excel spreadsheet e-mailed to DPI (online) Included in “Summary of Audit Findings” in the
single audit report
Identify total eligible cost on “Schedule of State Awards” footnote
Reporting Package Financial Statement(s)
Opinion on Financial Statements
Schedule of Expenditures of Federal Awards
Schedule of Expenditures of State Awards
Summary Schedule of Prior Audit Findings
Schedule of Findings and Questioned Costs
Corrective Action Plan
Date Collection Form filed with Federal Clearinghouse
Reporting PackageIndependent Auditor’s Report on Internal Control over
Financial Reporting and on Compliance and Other matters Based on an Audit of Financial Statements Performed in Accordance with Government Auditing Standards
Independent Auditor’s Report on Compliance with Requirements that Could have a Direct and Material Effect on Each Major Federal and State Program and on Internal Control over Compliance in Accordance with OMB Circular A-133 and the State Single Audit Guidelines
If the school is not required to have a federal single audit: Independent Auditor’s Report on Compliance with Requirements
Applicable to State programs and Internal Control Over Compliance Samples available at: http://dpi.wi.gov/sfs/aud_list.html
Single Audit Report
Single Audit Report
Single Audit Report
Single Audit Report
Report Due Dates
October 12, 2012 Special Ed - No Valid License Worksheet (if applicable)
December 3, 2012 Audited Financial Statements
December 3, 2012 Federal and State Single Audit Report
May 1, 2013 Membership Audit
Common Control Deficiencies Segregation of Duties
Preparation of financial statements and schedule of financial assistance
Material Adjustments
Internal Control Deficiencies
FindingClaims submitted for reimbursement are not
reviewed by anyone other than the preparerDistrict has no review procedure related to
claims submitted for reimbursement
Auditor RecommendationAn individual other than the preparer of the
claim should review and approve the claim prior to submission
Review of claims filed
Allowable Costs/Cost PrinciplesCompensation for Personnel Services (includes
salaries, wages, and fringe benefits)
Compensation considered reasonable to the extent that it is consistent with that paid for similar work in other activities of the governmental unit
Time and Effort Reporting Allowable if costs are reasonable, comparable for
similar work, and charges are supported with time distribution records or other documentation as stipulated in OMB A-87.
Types of Compliance Requirements
Time and Effort Reporting Finding Payroll certifications were not prepared to support
the salaries of individuals tested The District's management was unaware of the
requirement under OMB Circular A-87
Auditor Recommendation District obtain semi-annual payroll certifications
and timesheets for all employees funded by Federal programs
Allowable Costs/Cost Principles
Time and Effort ReportingDPI Response for 2010-11 findings
The District needs to implement a procedure for the preparation of semi-annual certifications or personnel activity reports as soon a they receive the auditor finding.
DPI will be following up with a notification that monitoring will occur for verification of personnel claimed on the grant in the 2011-12 school year.
Allowable Costs/Cost Principles
Finding Special Education Teacher not properly licensed
Auditor Recommendation District review staff each year for appropriate
license
Allowable Costs - Unlicensed Staff
Finding District charged a portion of special education
aide’s wages and fringe benefits to the IDEA Flow through grant but the aide did not work with special education students
District did not timely review employee eligibility to be charged to the grant. Error was found by the District while preparing the time and effort certifications.
Auditor Recommendation. District personnel review employees charged to
federal grants to ensure compliance with allowable cost principles.
Allowable Costs-Excess Salaries
Finding Not segregating all of the ARRA grant expenditures
by using project codes to track them ARRA reporting requires all expenditures for these
grants need to be accounted for separately
Auditor Recommendation District record all ARRA grant expenditures to the
proper project code and submit quarterly grant reimbursements based on those expenditures
Allowable Costs-Use of Project Codes
FindingGeneral ledger detail did not agree to the line
item expenditures reported on the grant claims
District did not request amendments to original budget approved by DPI
Lines for salaries, employee benefits, purchased services, non-capital objects, and capital objects were not in agreement.
Total expenditures charged to the grant agreed in total to the grant claims
Allowable Costs
Auditor Recommendation Before submitting reimbursement request, District
should request a budget amendment to move expenditures between the budget line items, if necessary
Allowable Costs
Finding Drew down Title I funds before incurring the
expenditure Lack of controls in place to prevent the drawdown
prior to the expenditure
Auditor Recommendation Procedures be put in place to verify expenditure
occurred prior to the claim
Cash Management
Audit Finding filed with DPI
DPI School Finance Auditor Reviews
School Finance Auditor provides appropriate program staff with the finding
Program staff follow up with districtResolution requiredFollow up in subsequent yearFiscal Monitoring
DPI Follow-up and Resolution to Federal Audit Findings
Requires the State as the pass-through agency to issue a management decision on audit findings and ensure that appropriate and timely corrective action is taken.
The management decision states whether or not the audit finding is sustained, the reasons for the decision, and the expected action to repay disallowed costs, make financial adjustments or take other action.
Prior to issuing the management decision, the State may request additional information or documentation
OMB Circular A-133
Questions?
ContactsBob Soldner, Director
(608) [email protected]
Liz Kane, Assistant Director(608) [email protected]
Kathy Guralski, School Finance Auditor(608) 266-2658 [email protected]
Margaret McMurray, Consultant(608) 266-5728
Michele Tessner , School Finance Auditor(608) 267-9218 [email protected]
Mark Magnuson, Grant Accountant(608) 266-3489 [email protected]