SIGNIFICANT DEFICIENCY Finding: 2022-004 Agency: U.S. Department of Education Program: Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Assistance Listing Number: 84.425D ALLOWABLE COSTS/COST PRINCIPLES Criteria: 2 CFR Part 200 Subpart E, Cost Principles, states that compensation for employees engaged in work on Federal awards must be documented as provided in 2 CFR Section 200.430(i). Although 2 CFR Section 200.430(i) does not specifically require semi-annual certifications, the Foster-Glocester Regional School District has a policy in place for time and effort reporting on Federal grant programs. The policy requires semi-annual certifications for employees charged to Federal grants working on a single cost objective. Condition: During our test of controls over compliance with allowable costs/cost principles requirements, we noted that the required semi-annual certifications were not completed for employees working on a single cost objective during fiscal year 2022. Cause: The School District did not follow its established time and effort reporting policies and procedures. Effect: The School District did not have the required documentation on file for employees charged to a single cost objective in conformance with the School District?s policy. Questioned Costs: None Recommendation: We recommend that the School District follow established time and effort reporting procedures to ensure that proper documentation is maintained for employees engaged in work on Federal grant programs. Corrective Action/Auditee Views: The District?s payroll process is significantly lacking proper control procedures. With the hiring of a new financial manager, policies, procedures and controls will be implemented immediately, including the proper tracking of time and effort for employees charged to federal grants as required. Anticipated Completion Date: September 1, 2023 Contact Person: Amanda Raymond, Director of Finance
SIGNIFICANT DEFICIENCY Finding: 2022-003 Agency: U.S. Environmental Protection Agency Program: Capitalization Grants for Drinking Water State Revolving Funds Federal Assistance Listing Number: 66.468 SUSPENSION AND DEBARMENT Criteria: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended, or debarred or otherwise excluded from participating in the transaction. ?Covered transactions? include those procurement contracts for goods and services awarded under non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. Foster-Glocester Regional School District has a policy in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded. Condition: During our test of controls over compliance with suspension and debarment requirements, we selected a contract subject to suspension and debarment requirements that had no documentation on file that the School District verified the entity was not suspended, debarred, or otherwise excluded. Cause: The School District did not follow established suspension and debarment policies and procedures. Effect: Contracts for goods and service that were ?covered transactions? were entered into prior to verifying that an entity was not suspended, debarred, or otherwise excluded. Questioned Costs: None Recommendation: We recommend that the School District follow established verification procedures to ensure that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded. Corrective Action/Auditee Views: While the District did get signed certification from the vendor that the organization had not been suspended or debarred, the District did not take the further step to check the government website for verification. The District will ensure that this step will be taken in the future. Also, the vendor in question was checked as of 4/18/23 on the government website and did not appear as debarred or suspended. Anticipated Completion Date: Completed Contact Person: Amanda Raymond, Director of Finance
SIGNIFICANT DEFICIENCY Finding: 2022-004 Agency: U.S. Department of Education Program: Elementary and Secondary School Emergency Relief (ESSER) Fund Federal Assistance Listing Number: 84.425D ALLOWABLE COSTS/COST PRINCIPLES Criteria: 2 CFR Part 200 Subpart E, Cost Principles, states that compensation for employees engaged in work on Federal awards must be documented as provided in 2 CFR Section 200.430(i). Although 2 CFR Section 200.430(i) does not specifically require semi-annual certifications, the Foster-Glocester Regional School District has a policy in place for time and effort reporting on Federal grant programs. The policy requires semi-annual certifications for employees charged to Federal grants working on a single cost objective. Condition: During our test of controls over compliance with allowable costs/cost principles requirements, we noted that the required semi-annual certifications were not completed for employees working on a single cost objective during fiscal year 2022. Cause: The School District did not follow its established time and effort reporting policies and procedures. Effect: The School District did not have the required documentation on file for employees charged to a single cost objective in conformance with the School District?s policy. Questioned Costs: None Recommendation: We recommend that the School District follow established time and effort reporting procedures to ensure that proper documentation is maintained for employees engaged in work on Federal grant programs. Corrective Action/Auditee Views: The District?s payroll process is significantly lacking proper control procedures. With the hiring of a new financial manager, policies, procedures and controls will be implemented immediately, including the proper tracking of time and effort for employees charged to federal grants as required. Anticipated Completion Date: September 1, 2023 Contact Person: Amanda Raymond, Director of Finance
SIGNIFICANT DEFICIENCY Finding: 2022-003 Agency: U.S. Environmental Protection Agency Program: Capitalization Grants for Drinking Water State Revolving Funds Federal Assistance Listing Number: 66.468 SUSPENSION AND DEBARMENT Criteria: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended, or debarred or otherwise excluded from participating in the transaction. ?Covered transactions? include those procurement contracts for goods and services awarded under non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. Foster-Glocester Regional School District has a policy in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded. Condition: During our test of controls over compliance with suspension and debarment requirements, we selected a contract subject to suspension and debarment requirements that had no documentation on file that the School District verified the entity was not suspended, debarred, or otherwise excluded. Cause: The School District did not follow established suspension and debarment policies and procedures. Effect: Contracts for goods and service that were ?covered transactions? were entered into prior to verifying that an entity was not suspended, debarred, or otherwise excluded. Questioned Costs: None Recommendation: We recommend that the School District follow established verification procedures to ensure that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded. Corrective Action/Auditee Views: While the District did get signed certification from the vendor that the organization had not been suspended or debarred, the District did not take the further step to check the government website for verification. The District will ensure that this step will be taken in the future. Also, the vendor in question was checked as of 4/18/23 on the government website and did not appear as debarred or suspended. Anticipated Completion Date: Completed Contact Person: Amanda Raymond, Director of Finance