Finding 2023 - 002 Reporting - Native Hawaiian Education – Assistance Listing 84.362A
Criteria: 2 CFR Section 200.328 Financial reporting and Section 200.329 Monitoring and reporting program performance requires the School to provide certain reports during the grant period to the Department of Education.
Condition: The School was unable to provide documentation to support that it complied with the reporting requirements of the Native Hawaiian Education Grant.
Context and Cause of Condition: Due to turnover at the School, the School was unable to access the Native Hawaiian Education Grant portal or unable to find documentation for submitting the required reports.
Questioned Costs: None
Potential Effect: Without proper documentation to support if reporting was completed in accordance with requirements, the School could be found to be out of compliance with terms and conditions of the grant. Failing to comply with grant conditions could impact current and future funding. Management failed to meet or to properly maintain evidence of meeting the reporting requirements of the grant.
Recommendation: We recommend management establish procedures and controls to properly maintain documentation to support that all compliance requirements under all grants have been met and to include required reporting ensuring that all reports are filed and maintained.
Views of Responsible Officials: The School concurs with the finding and recommendation. See Corrective Action Plan.
Finding 2023 - 003 Allowable Costs - Native Hawaiian Education – Assistance Listing 84.362A
Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: During testing of controls over credit card expenditures funded by the Native Hawaiian Education Grant, we noted out of a population of 119 transactions, the School was unable to provide sufficient documentation to substantiate 33 of the transactions. The total population tested was $47,581 and the amount of items unsubstantiated was $3,827.
Context and Cause of Condition: Due to turnover at the School, there was a lack of controls that would normally require sufficient documentation for all expenses incurred by the School to properly substantiate credit card expenditures, mainly around the last two months of the School year.
Questioned Costs: None
Potential Effect: Without sufficient documentation to support the reasonable business purpose of expenses, there in an increased risk for error and/or fraud. These conditions could result in noncompliance and potential loss of current and future funding.
Recommendation: All purchases should be properly substantiated with sufficient documentation that clearly supports the reasonable business purpose of expenses incurred. In addition, all expenses should be approved by a person of proper authority.
Views of Responsible Officials: The School concurs with the finding and recommendation. See Corrective Action Plan.
Finding 2023 - 004 Procurement - Native Hawaiian Education – Assistance Listing 84.362A
Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards of that section.
If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)).
Condition: Procurement documentation for one vendor tested was not prepared and/or retained to support compliance with the regulations above and the School’s procurement policy.
Context and Cause of Condition: Although the School has established policies and procedures in place over the procurement process, there was a lack of diligence in complying with and/or retaining documentation supporting compliance with the policies and procedures.
Potential Effect: Failure to perform and retain documentation of the procurement process resulted in noncompliance with the procurement requirement.
Questioned Costs: None
Recommendation: We recommend management monitor established procurement policies in place to ensure that sufficient documentation is maintained.
Views of Responsible Officials: The School concurs with the finding and recommendation. See Corrective Action Plan.
Finding 2023 - 005 Equipment and Real Property Management - Native Hawaiian Education – Assistance Listing 84.362A
Criteria: The School must follow 2 CFR sections 200.313(b) Equipment Management
Condition: The School purchased approximately 183 laptop computers for distance learning under the Native Hawaiian Education Grant. The School did not implement appropriate tracking procedures to properly document the use and location of the equipment. This resulted in the laptops not being returned to the School.
Context and Cause of Condition: The School failed to implement a process to properly document and inventory equipment purchased with grant funds. In addition, the School did not implement formal policies to lend laptops to students and ensure the School received the laptops back after the students were done using them.
Potential Effect: The School did not comply with the Equipment and Real Property Management requirements of the grant and equipment purchased with grant funds are not available for future program use.
Questioned Costs: None
Recommendation: We recommend management implement a policy that requires all equipment be inventoried and tracked, especially equipment purchased under grant funds. Additionally, the School should establish formal policies and/or agreements with students that requires all School equipment be returned.
Views of Responsible Officials: The School concurs with the finding and recommendation. See Corrective Action Plan.
Finding 2023 - 002 Reporting - Native Hawaiian Education – Assistance Listing 84.362A
Criteria: 2 CFR Section 200.328 Financial reporting and Section 200.329 Monitoring and reporting program performance requires the School to provide certain reports during the grant period to the Department of Education.
Condition: The School was unable to provide documentation to support that it complied with the reporting requirements of the Native Hawaiian Education Grant.
Context and Cause of Condition: Due to turnover at the School, the School was unable to access the Native Hawaiian Education Grant portal or unable to find documentation for submitting the required reports.
Questioned Costs: None
Potential Effect: Without proper documentation to support if reporting was completed in accordance with requirements, the School could be found to be out of compliance with terms and conditions of the grant. Failing to comply with grant conditions could impact current and future funding. Management failed to meet or to properly maintain evidence of meeting the reporting requirements of the grant.
Recommendation: We recommend management establish procedures and controls to properly maintain documentation to support that all compliance requirements under all grants have been met and to include required reporting ensuring that all reports are filed and maintained.
Views of Responsible Officials: The School concurs with the finding and recommendation. See Corrective Action Plan.
Finding 2023 - 003 Allowable Costs - Native Hawaiian Education – Assistance Listing 84.362A
Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition: During testing of controls over credit card expenditures funded by the Native Hawaiian Education Grant, we noted out of a population of 119 transactions, the School was unable to provide sufficient documentation to substantiate 33 of the transactions. The total population tested was $47,581 and the amount of items unsubstantiated was $3,827.
Context and Cause of Condition: Due to turnover at the School, there was a lack of controls that would normally require sufficient documentation for all expenses incurred by the School to properly substantiate credit card expenditures, mainly around the last two months of the School year.
Questioned Costs: None
Potential Effect: Without sufficient documentation to support the reasonable business purpose of expenses, there in an increased risk for error and/or fraud. These conditions could result in noncompliance and potential loss of current and future funding.
Recommendation: All purchases should be properly substantiated with sufficient documentation that clearly supports the reasonable business purpose of expenses incurred. In addition, all expenses should be approved by a person of proper authority.
Views of Responsible Officials: The School concurs with the finding and recommendation. See Corrective Action Plan.
Finding 2023 - 004 Procurement - Native Hawaiian Education – Assistance Listing 84.362A
Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards of that section.
If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)).
Condition: Procurement documentation for one vendor tested was not prepared and/or retained to support compliance with the regulations above and the School’s procurement policy.
Context and Cause of Condition: Although the School has established policies and procedures in place over the procurement process, there was a lack of diligence in complying with and/or retaining documentation supporting compliance with the policies and procedures.
Potential Effect: Failure to perform and retain documentation of the procurement process resulted in noncompliance with the procurement requirement.
Questioned Costs: None
Recommendation: We recommend management monitor established procurement policies in place to ensure that sufficient documentation is maintained.
Views of Responsible Officials: The School concurs with the finding and recommendation. See Corrective Action Plan.
Finding 2023 - 005 Equipment and Real Property Management - Native Hawaiian Education – Assistance Listing 84.362A
Criteria: The School must follow 2 CFR sections 200.313(b) Equipment Management
Condition: The School purchased approximately 183 laptop computers for distance learning under the Native Hawaiian Education Grant. The School did not implement appropriate tracking procedures to properly document the use and location of the equipment. This resulted in the laptops not being returned to the School.
Context and Cause of Condition: The School failed to implement a process to properly document and inventory equipment purchased with grant funds. In addition, the School did not implement formal policies to lend laptops to students and ensure the School received the laptops back after the students were done using them.
Potential Effect: The School did not comply with the Equipment and Real Property Management requirements of the grant and equipment purchased with grant funds are not available for future program use.
Questioned Costs: None
Recommendation: We recommend management implement a policy that requires all equipment be inventoried and tracked, especially equipment purchased under grant funds. Additionally, the School should establish formal policies and/or agreements with students that requires all School equipment be returned.
Views of Responsible Officials: The School concurs with the finding and recommendation. See Corrective Action Plan.