Audit 295508

FY End
2023-06-30
Total Expended
$12.45M
Findings
2
Programs
12
Year: 2023 Accepted: 2024-03-18

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
380796 2023-001 Significant Deficiency - B
957238 2023-001 Significant Deficiency - B

Programs

Contacts

Name Title Type
DFXNLUKXDLH6 Jennifer Segui Auditee
6317301520 Michael J. Leone, CPA Auditor
No contacts on file

Notes to SEFA

Title: SUBRECIPIENTS Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or limited as to reimbursement. Matching costs (the District’s share of certain program costs) are not included in the reported expenditures. Pass-through numbers are presented where available. The amounts reported as federal expenditures were obtained from the federal financial reports for the applicable program and periods. The amounts reported in these reports are prepared from records maintained for each program, which are reconciled with the District’s financial reporting system. Non-cash assistance is reported in the schedule at the fair market value of commodities received, which is provided by New York State under the National School Lunch Program. De Minimis Rate Used: N Rate Explanation: South Country Central School District has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. No amounts were provided to subrecipients.
Title: OTHER DISCLOSURES Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or limited as to reimbursement. Matching costs (the District’s share of certain program costs) are not included in the reported expenditures. Pass-through numbers are presented where available. The amounts reported as federal expenditures were obtained from the federal financial reports for the applicable program and periods. The amounts reported in these reports are prepared from records maintained for each program, which are reconciled with the District’s financial reporting system. Non-cash assistance is reported in the schedule at the fair market value of commodities received, which is provided by New York State under the National School Lunch Program. De Minimis Rate Used: N Rate Explanation: South Country Central School District has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. No insurance is carried specifically to cover equipment purchased with federal funds. Any equipment purchased with federal funds has only a nominal value, and is covered by the District’s casualty insurance policies. There were no loans or loan guarantees outstanding at year end.

Finding Details

Significant Deficiency 2023-001. Allowable Costs/Cost Principles United States Federal Communications Commission: COVID-19: Emergency Connectivity Fund Program ALN: 32.009 Criteria: The District is required to make purchases for only eligible devices or equipment for unmet student or staff members needs in order to comply with the program application and guidelines for the Emergency Connectivity Fund Program. This requirement is also in accordance with the allowability of reasonable costs under the Uniform Guidance Subpart E, 2 CFR §200.404. Condition: Subpart E, 2 CFR §200.404 of the Uniform guidance requires that any monies charged to the Emergency Connectivity Fund Program be reasonable costs allowable under the approved grant application, including the grant requirement that reimbursed costs for devices or equipment are only eligible for a one-per user limitation. During the current year, we noted that the District purchased and was reimbursed for additional devices or equipment beyond the unmet need and the one per-user limitation. Cause: The District’s final reimbursement of funds, incorrectly included purchases for devices and equipment, which was over the unmet need of the District and also included reimbursement for equipment and devices that exceeded the allowable one-per user limitation. Effect: Noncompliance with these requirements resulted in the District being reimbursed more than the unmet need of students and staff members, and the provision of devices or equipment that was in excess of user limitation per the grant requirements. Questioned Costs: $29,376 of reimbursements received were more than the allowable costs under the grant (92 devices or equipment at an approximate cost of $319.30 each). Context: The program guidelines specify that devices or equipment are to be provided for unmet student or staff member needs and at a one per-user limitation. During a review of the District’s current year inventory tracking system, it was discovered that there were devices or equipment purchased, distributed, and reimbursed for more students than originally applied for, and in some instances more than the one-per user limitation. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should gain a better understanding of the program application and guidelines and ensure that they comply with those guidelines and are only reimbursed for allowable items provided to eligible students and staff members per the grant terms. Under this specific grant, there was limited funding for eligible schools to purchase no more than one connected device per student or school staff member, as a result of the implications brought about by COVID-19. The District should review its determination of students and staff members with an unmet need and request reimbursement for only those devices approved in the original application. In addition, the District should contact the federal agency to see how they need to remediate the excess reimbursement received for the amount that was ineligible in accordance with the grant. Views of Responsible Officials of Auditee: The District agrees with the recommendation, and the Assistant Superintendent for Finance and Management Services will contact the federal agency to determine the appropriate action for the reimbursement of the excess funds received.
Significant Deficiency 2023-001. Allowable Costs/Cost Principles United States Federal Communications Commission: COVID-19: Emergency Connectivity Fund Program ALN: 32.009 Criteria: The District is required to make purchases for only eligible devices or equipment for unmet student or staff members needs in order to comply with the program application and guidelines for the Emergency Connectivity Fund Program. This requirement is also in accordance with the allowability of reasonable costs under the Uniform Guidance Subpart E, 2 CFR §200.404. Condition: Subpart E, 2 CFR §200.404 of the Uniform guidance requires that any monies charged to the Emergency Connectivity Fund Program be reasonable costs allowable under the approved grant application, including the grant requirement that reimbursed costs for devices or equipment are only eligible for a one-per user limitation. During the current year, we noted that the District purchased and was reimbursed for additional devices or equipment beyond the unmet need and the one per-user limitation. Cause: The District’s final reimbursement of funds, incorrectly included purchases for devices and equipment, which was over the unmet need of the District and also included reimbursement for equipment and devices that exceeded the allowable one-per user limitation. Effect: Noncompliance with these requirements resulted in the District being reimbursed more than the unmet need of students and staff members, and the provision of devices or equipment that was in excess of user limitation per the grant requirements. Questioned Costs: $29,376 of reimbursements received were more than the allowable costs under the grant (92 devices or equipment at an approximate cost of $319.30 each). Context: The program guidelines specify that devices or equipment are to be provided for unmet student or staff member needs and at a one per-user limitation. During a review of the District’s current year inventory tracking system, it was discovered that there were devices or equipment purchased, distributed, and reimbursed for more students than originally applied for, and in some instances more than the one-per user limitation. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should gain a better understanding of the program application and guidelines and ensure that they comply with those guidelines and are only reimbursed for allowable items provided to eligible students and staff members per the grant terms. Under this specific grant, there was limited funding for eligible schools to purchase no more than one connected device per student or school staff member, as a result of the implications brought about by COVID-19. The District should review its determination of students and staff members with an unmet need and request reimbursement for only those devices approved in the original application. In addition, the District should contact the federal agency to see how they need to remediate the excess reimbursement received for the amount that was ineligible in accordance with the grant. Views of Responsible Officials of Auditee: The District agrees with the recommendation, and the Assistant Superintendent for Finance and Management Services will contact the federal agency to determine the appropriate action for the reimbursement of the excess funds received.