Audit 26690

2022-010: U.S. Department of Education Passed through Opportunity 180 Charter Schools, 84.282 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is the segregation of duties through a review and approval process. Condition: Payroll costs charged to the program did not have evidence of review by an individual independent of the preparation of the allocation to the program. Cause: The School did not have adequate internal controls to ensure review of payroll costs charged to the program occurred and was documented. Effect: Unallowable costs may be charged to the program and not detected by the School. Questioned Costs: None noted Context/Sampling: A non-statistical sample of four payroll transactions out of a population of 29 was selected for testing. There was no evidence of review on any of the four transactions tested. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to ensure review of payroll costs charged to the program occurs and is documented. Views of Responsible Officials: Management agrees with this finding.

2022-011: U.S. Department of Education Passed through Opportunity 180 Charter Schools, 84.282 Cash Management Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is the segregation of duties through a review and approval process. Condition: Reimbursement requests submitted to the grantor did not have evidence of review by an individual independent of the preparation of the reimbursement request. Cause: The School did not have adequate internal controls to ensure review of reimbursement requests occurred or was documented. Effect: Unallowable costs may be charged to the program and not detected by the School. Questioned Costs: None noted Context/Sampling: A non-statistical sample of three reimbursement requests out of a population of five was selected for testing. There was no evidence of review on any of the three reimbursement requests tested. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to ensure review of reimbursement requests occurs and is documented. Views of Responsible Officials: Management agrees with this finding.

2022-012: U.S. Department of Education Passed through Opportunity 180 Charter Schools, 84.282 Other Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires the School to prepare a Schedule of Expenditures of Federal Awards (SEFA). Condition: Amounts were originally reported incorrectly on the SEFA. Cause: The School did not have adequate internal controls to provide for the review of journal entries that allocate expenses to federal programs or the SEFA to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to correction, total expenditures reported under the program were overstated by $36,186 as they included costs from the prior period. Questioned Costs: None noted Context/Sampling: No sampling was used; all program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to provide for the review of journal entries that allocate expenses to federal programs and the SEFA to ensure total federal expenditures are appropriately reported on the SEFA. Views of Responsible Officials: Management agrees with this finding.

2022-010: U.S. Department of Education Passed through Opportunity 180 Charter Schools, 84.282 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is the segregation of duties through a review and approval process. Condition: Payroll costs charged to the program did not have evidence of review by an individual independent of the preparation of the allocation to the program. Cause: The School did not have adequate internal controls to ensure review of payroll costs charged to the program occurred and was documented. Effect: Unallowable costs may be charged to the program and not detected by the School. Questioned Costs: None noted Context/Sampling: A non-statistical sample of four payroll transactions out of a population of 29 was selected for testing. There was no evidence of review on any of the four transactions tested. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to ensure review of payroll costs charged to the program occurs and is documented. Views of Responsible Officials: Management agrees with this finding.

2022-011: U.S. Department of Education Passed through Opportunity 180 Charter Schools, 84.282 Cash Management Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is the segregation of duties through a review and approval process. Condition: Reimbursement requests submitted to the grantor did not have evidence of review by an individual independent of the preparation of the reimbursement request. Cause: The School did not have adequate internal controls to ensure review of reimbursement requests occurred or was documented. Effect: Unallowable costs may be charged to the program and not detected by the School. Questioned Costs: None noted Context/Sampling: A non-statistical sample of three reimbursement requests out of a population of five was selected for testing. There was no evidence of review on any of the three reimbursement requests tested. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to ensure review of reimbursement requests occurs and is documented. Views of Responsible Officials: Management agrees with this finding.

2022-012: U.S. Department of Education Passed through Opportunity 180 Charter Schools, 84.282 Other Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires the School to prepare a Schedule of Expenditures of Federal Awards (SEFA). Condition: Amounts were originally reported incorrectly on the SEFA. Cause: The School did not have adequate internal controls to provide for the review of journal entries that allocate expenses to federal programs or the SEFA to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Prior to correction, total expenditures reported under the program were overstated by $36,186 as they included costs from the prior period. Questioned Costs: None noted Context/Sampling: No sampling was used; all program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to provide for the review of journal entries that allocate expenses to federal programs and the SEFA to ensure total federal expenditures are appropriately reported on the SEFA. Views of Responsible Officials: Management agrees with this finding.