Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The District did not file the required quarterly reports for September 2022 and December 2022 for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477 in a timely manner within the 10-day requirement. Also, the District did not file the required quarterly reports for June 2023 for grant for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477.
Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed.
Identification of Repeat Finding: Yes, #2022-002
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320.
Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy.
Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: Yes, #2022-003
Questioned Costs: None
Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. If an employee works solely on a single Federal award or cost objective, charges for the employee’s salary and wages must be supported by periodic certifications that the employee worked solely on that program or cost objective for the period covered by the certification.
Those certifications must:
- Be prepared at least semiannually.
- Signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee.
Condition: A sample of 24 payroll transactions were selected for testing from a population of 239 transactions. The sample included 14 staff members including afterschool and summer school. There were five teachers included in the sample with no time and effort certifications maintained to support the portion of time and effort dedicated to the ARP ESSER program.
Cause and Effect: Due to staff turnover during the year, the district neglected to maintain the required documentation. The district receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the district may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate.
Identification of Repeat Finding: No.
Questioned Costs: Salary and related benefits of employees charged to the program including related social security and retirement and insurance = $369,766.
Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The District did not file the required quarterly reports for September 2022 and December 2022 for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477 in a timely manner within the 10-day requirement. Also, the District did not file the required quarterly reports for June 2023 for grant for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477.
Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed.
Identification of Repeat Finding: Yes, #2022-002
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320.
Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy.
Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: Yes, #2022-003
Questioned Costs: None
Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. If an employee works solely on a single Federal award or cost objective, charges for the employee’s salary and wages must be supported by periodic certifications that the employee worked solely on that program or cost objective for the period covered by the certification.
Those certifications must:
- Be prepared at least semiannually.
- Signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee.
Condition: A sample of 24 payroll transactions were selected for testing from a population of 239 transactions. The sample included 14 staff members including afterschool and summer school. There were five teachers included in the sample with no time and effort certifications maintained to support the portion of time and effort dedicated to the ARP ESSER program.
Cause and Effect: Due to staff turnover during the year, the district neglected to maintain the required documentation. The district receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the district may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate.
Identification of Repeat Finding: No.
Questioned Costs: Salary and related benefits of employees charged to the program including related social security and retirement and insurance = $369,766.
Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The District did not file the required quarterly reports for September 2022 and December 2022 for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477 in a timely manner within the 10-day requirement. Also, the District did not file the required quarterly reports for June 2023 for grant for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477.
Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed.
Identification of Repeat Finding: Yes, #2022-002
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320.
Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy.
Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: Yes, #2022-003
Questioned Costs: None
Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. If an employee works solely on a single Federal award or cost objective, charges for the employee’s salary and wages must be supported by periodic certifications that the employee worked solely on that program or cost objective for the period covered by the certification.
Those certifications must:
- Be prepared at least semiannually.
- Signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee.
Condition: A sample of 24 payroll transactions were selected for testing from a population of 239 transactions. The sample included 14 staff members including afterschool and summer school. There were five teachers included in the sample with no time and effort certifications maintained to support the portion of time and effort dedicated to the ARP ESSER program.
Cause and Effect: Due to staff turnover during the year, the district neglected to maintain the required documentation. The district receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the district may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate.
Identification of Repeat Finding: No.
Questioned Costs: Salary and related benefits of employees charged to the program including related social security and retirement and insurance = $369,766.
Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The District did not file the required quarterly reports for September 2022 and December 2022 for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477 in a timely manner within the 10-day requirement. Also, the District did not file the required quarterly reports for June 2023 for grant for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477.
Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed.
Identification of Repeat Finding: Yes, #2022-002
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320.
Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy.
Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: Yes, #2022-003
Questioned Costs: None
Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. If an employee works solely on a single Federal award or cost objective, charges for the employee’s salary and wages must be supported by periodic certifications that the employee worked solely on that program or cost objective for the period covered by the certification.
Those certifications must:
- Be prepared at least semiannually.
- Signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee.
Condition: A sample of 24 payroll transactions were selected for testing from a population of 239 transactions. The sample included 14 staff members including afterschool and summer school. There were five teachers included in the sample with no time and effort certifications maintained to support the portion of time and effort dedicated to the ARP ESSER program.
Cause and Effect: Due to staff turnover during the year, the district neglected to maintain the required documentation. The district receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the district may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate.
Identification of Repeat Finding: No.
Questioned Costs: Salary and related benefits of employees charged to the program including related social security and retirement and insurance = $369,766.
Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The District did not file the required quarterly reports for September 2022 and December 2022 for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477 in a timely manner within the 10-day requirement. Also, the District did not file the required quarterly reports for June 2023 for grant for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477.
Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed.
Identification of Repeat Finding: Yes, #2022-002
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320.
Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy.
Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: Yes, #2022-003
Questioned Costs: None
Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. If an employee works solely on a single Federal award or cost objective, charges for the employee’s salary and wages must be supported by periodic certifications that the employee worked solely on that program or cost objective for the period covered by the certification.
Those certifications must:
- Be prepared at least semiannually.
- Signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee.
Condition: A sample of 24 payroll transactions were selected for testing from a population of 239 transactions. The sample included 14 staff members including afterschool and summer school. There were five teachers included in the sample with no time and effort certifications maintained to support the portion of time and effort dedicated to the ARP ESSER program.
Cause and Effect: Due to staff turnover during the year, the district neglected to maintain the required documentation. The district receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the district may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate.
Identification of Repeat Finding: No.
Questioned Costs: Salary and related benefits of employees charged to the program including related social security and retirement and insurance = $369,766.
Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The District did not file the required quarterly reports for September 2022 and December 2022 for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477 in a timely manner within the 10-day requirement. Also, the District did not file the required quarterly reports for June 2023 for grant for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477.
Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed.
Identification of Repeat Finding: Yes, #2022-002
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320.
Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy.
Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: Yes, #2022-003
Questioned Costs: None
Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. If an employee works solely on a single Federal award or cost objective, charges for the employee’s salary and wages must be supported by periodic certifications that the employee worked solely on that program or cost objective for the period covered by the certification.
Those certifications must:
- Be prepared at least semiannually.
- Signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee.
Condition: A sample of 24 payroll transactions were selected for testing from a population of 239 transactions. The sample included 14 staff members including afterschool and summer school. There were five teachers included in the sample with no time and effort certifications maintained to support the portion of time and effort dedicated to the ARP ESSER program.
Cause and Effect: Due to staff turnover during the year, the district neglected to maintain the required documentation. The district receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the district may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate.
Identification of Repeat Finding: No.
Questioned Costs: Salary and related benefits of employees charged to the program including related social security and retirement and insurance = $369,766.
Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The District did not file the required quarterly reports for September 2022 and December 2022 for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477 in a timely manner within the 10-day requirement. Also, the District did not file the required quarterly reports for June 2023 for grant for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477.
Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed.
Identification of Repeat Finding: Yes, #2022-002
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320.
Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy.
Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: Yes, #2022-003
Questioned Costs: None
Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. If an employee works solely on a single Federal award or cost objective, charges for the employee’s salary and wages must be supported by periodic certifications that the employee worked solely on that program or cost objective for the period covered by the certification.
Those certifications must:
- Be prepared at least semiannually.
- Signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee.
Condition: A sample of 24 payroll transactions were selected for testing from a population of 239 transactions. The sample included 14 staff members including afterschool and summer school. There were five teachers included in the sample with no time and effort certifications maintained to support the portion of time and effort dedicated to the ARP ESSER program.
Cause and Effect: Due to staff turnover during the year, the district neglected to maintain the required documentation. The district receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the district may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate.
Identification of Repeat Finding: No.
Questioned Costs: Salary and related benefits of employees charged to the program including related social security and retirement and insurance = $369,766.
Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after funds are expended but no later than 30 days after the ending date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The District did not file the required quarterly reports for September 2022 and December 2022 for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477 in a timely manner within the 10-day requirement. Also, the District did not file the required quarterly reports for June 2023 for grant for grant #200-210475, #223-210475, #224-210475, #225-210475, and #181-212477.
Cause and Effect: The District's Business office did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the District is potentially risking a withholding of federal funds by the PDE until the reports are properly filed.
Identification of Repeat Finding: Yes, #2022-002
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the District files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320.
Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the District made procurements through sole source arrangements. Consistent with 2 CFR § 200.320(c)(3), an LEA may determine that its response to the COVID-19 pandemic qualifies as a public exigency or emergency that does not permit the delay that would result from competitive bidding. Under these circumstances, and to the degree doing so is consistent with its own policies and procedures, an LEA could use noncompetitive procurement. The LEA should consult with its SEA before using this authority. Subsequently, the District paid for this purchase utilizing the Education Stabilization Fund. In using federal funds to pay for these items, the District inadvertently did not follow its procurement policy.
Cause and Effect: When the District initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The District did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: Yes, #2022-003
Questioned Costs: None
Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs or sole source arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The District should then document its process and how it complies with the procurement standards and keep such documentation with Federal Award budget/procurement documents.
Management Response: See Corrective Action Plan on pages 84 - 85.
Education Stabilization Fund – AL #84.425, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity – Pennsylvania Department of Education
Criteria: Uniform Guidance requires an employee whose salary and wages are supported, in whole or in part, with Federal funds to document his/her time spent working on Federal programs in order to ensure that charges to each Federal program reflect an accurate account of the employee’s time and effort devoted to that program. If an employee works solely on a single Federal award or cost objective, charges for the employee’s salary and wages must be supported by periodic certifications that the employee worked solely on that program or cost objective for the period covered by the certification.
Those certifications must:
- Be prepared at least semiannually.
- Signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee.
Condition: A sample of 24 payroll transactions were selected for testing from a population of 239 transactions. The sample included 14 staff members including afterschool and summer school. There were five teachers included in the sample with no time and effort certifications maintained to support the portion of time and effort dedicated to the ARP ESSER program.
Cause and Effect: Due to staff turnover during the year, the district neglected to maintain the required documentation. The district receives federal funding based on allowable costs charged to the program. If documentation is not maintained to support the allowability of costs charged to the program, the district may be utilizing the funds for expenses which are unallowable. This may result in the return of federal funds to the funding agency for the unallowable costs, if deemed appropriate.
Identification of Repeat Finding: No.
Questioned Costs: Salary and related benefits of employees charged to the program including related social security and retirement and insurance = $369,766.
Recommendation: We recommend that controls be reviewed and revised to ensure that time and effort distribution records are prepared for staff who are charged to federal programs. These records should also be reviewed, approved, and maintained by administrative personnel.
Management Response: See Corrective Action Plan on pages 84 - 85.