The Wapello Community School District shall establish and maintain a system of internal controls and supporting documentation for salaries and benefits charged, in whole or in part, to federal awards in accordance with:
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2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”)
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Applicable grant terms and conditions
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Generally Accepted Accounting Principles (GAAP)
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Governmental Accounting Standards Boards (GASB) standards
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Applicable state and federal laws and regulations
The district shall maintain records that accurately reflect the work performed and support the distribution of salaries and wages charged to federal programs.
Personnel costs charged to federal awards must be:
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Reasonable and necessary for the performance of the federal award;
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Consistently treated in accordance with district policies and procedures;
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Supported by records that accurately reflect the actual work performed;
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Properly allocated to the benefiting program or cost objective; and
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Supported by a system of internal controls providing reasonable assurance that the charges are accurate, allowable, and properly documented.
Documentation supporting personnel expenses shall:
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Reflect the total activity for which the employee is compensated;
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Be incorporated into the district’s official records;
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Reasonably reflect the employee’s actual work activity;
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Comply with established district administrative procedures;
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Support allocations among multiple federal and non-federal funding sources, when applicable; and
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Be supported by periodic review and supervisory approval.
Employees working solely on a single federal program or cost objective may be required to complete periodic certifications confirming that the employee worked solely on that program for the applicable reporting period.
Employees working on multiple cost objectives or funding sources shall maintain appropriate time and effort documentation that reasonably reflects actual activity performed and supports salary allocations charged to each funding source.
Budget estimates or predetermined distributions may be used for interim accounting purposes provided that:
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The estimates produce reasonable approximations of actual activity;
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The district performs periodic reconciliations between budget estimates and actual work performed; and
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Any necessary adjustments are made timely. All documentation shall be retained in accordance with the district’s record retention policies and applicable federal record retention requirements, including retention for a minimum of three years following submission of the final expenditure report, unless a longer retention period is required by law, audit resolution, or grant terms.
The Superintendent and/or designated School Business Official shall establish administrative procedures necessary to implement this policy, including:
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Documentation standards;
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Review and approval procedures;
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Internal monitoring procedures;
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Corrective actions for noncompliance; and
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Periodic reconciliation of payroll charges to federal awards.
Legal References: Iowa Code 257
Iowa Code 11
281 I.A.C. 97; 98
2 CFR Pt. 200
Approved: 7/8/26
Reviewed:
Revised: