UNITED STATES DEPARTMENT OF EDUCATION
Significant Deficiency in Internal Control over Compliance
2023-001 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal
entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders
12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Condition and Context: For the one vendor in our audit sample, documentation was not provided to support that the
City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities
for the fiscal year 2023 time period.
Questioned Costs: None. The vendor was not suspended or debarred.
Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended
or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or
suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in
Federal assistance programs or activities.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not
suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.
UNITED STATES DEPARTMENT OF EDUCATION
Significant Deficiency in Internal Control over Compliance
2023-001 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal
entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders
12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Condition and Context: For the one vendor in our audit sample, documentation was not provided to support that the
City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities
for the fiscal year 2023 time period.
Questioned Costs: None. The vendor was not suspended or debarred.
Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended
or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or
suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in
Federal assistance programs or activities.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not
suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.
UNITED STATES DEPARTMENT OF EDUCATION
Significant Deficiency in Internal Control over Compliance
2023-001 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal
entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders
12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Condition and Context: For the one vendor in our audit sample, documentation was not provided to support that the
City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities
for the fiscal year 2023 time period.
Questioned Costs: None. The vendor was not suspended or debarred.
Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended
or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or
suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in
Federal assistance programs or activities.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not
suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.
UNITED STATES DEPARTMENT OF EDUCATION
Significant Deficiency in Internal Control over Compliance
2023-001 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal
entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders
12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Condition and Context: For the one vendor in our audit sample, documentation was not provided to support that the
City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities
for the fiscal year 2023 time period.
Questioned Costs: None. The vendor was not suspended or debarred.
Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended
or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or
suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in
Federal assistance programs or activities.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not
suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.
Significant Deficiency in Internal Control over Compliance
2023-002 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal
awards for salaries and wages must be based on records that accurately reflect the work performed. These records
must be supported by a system of internal control which provides reasonable assurance that the charges are accurate,
allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee
is compensated by the non-Federal entity.
Condition and Context: For all of the payroll disbursements in our sample, evidence of management review of time and
effort was not provided.
Questioned Costs: None.
Cause: Procedures were not in place to document the management review of time and effort.
Effect: Significant deficiency in internal controls.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document and maintain on file the management
review of time and effort.
Views of Responsible Officials: Management agrees with the finding.
Significant Deficiency in Internal Control over Compliance
2023-002 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal
awards for salaries and wages must be based on records that accurately reflect the work performed. These records
must be supported by a system of internal control which provides reasonable assurance that the charges are accurate,
allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee
is compensated by the non-Federal entity.
Condition and Context: For all of the payroll disbursements in our sample, evidence of management review of time and
effort was not provided.
Questioned Costs: None.
Cause: Procedures were not in place to document the management review of time and effort.
Effect: Significant deficiency in internal controls.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document and maintain on file the management
review of time and effort.
Views of Responsible Officials: Management agrees with the finding.
Significant Deficiency in Internal Control over Compliance
2023-002 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal
awards for salaries and wages must be based on records that accurately reflect the work performed. These records
must be supported by a system of internal control which provides reasonable assurance that the charges are accurate,
allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee
is compensated by the non-Federal entity.
Condition and Context: For all of the payroll disbursements in our sample, evidence of management review of time and
effort was not provided.
Questioned Costs: None.
Cause: Procedures were not in place to document the management review of time and effort.
Effect: Significant deficiency in internal controls.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document and maintain on file the management
review of time and effort.
Views of Responsible Officials: Management agrees with the finding.
Significant Deficiency in Internal Control over Compliance
2023-002 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal
awards for salaries and wages must be based on records that accurately reflect the work performed. These records
must be supported by a system of internal control which provides reasonable assurance that the charges are accurate,
allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee
is compensated by the non-Federal entity.
Condition and Context: For all of the payroll disbursements in our sample, evidence of management review of time and
effort was not provided.
Questioned Costs: None.
Cause: Procedures were not in place to document the management review of time and effort.
Effect: Significant deficiency in internal controls.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document and maintain on file the management
review of time and effort.
Views of Responsible Officials: Management agrees with the finding.
UNITED STATES DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Material Weakness in Internal Control over Compliance and Material Noncompliance
2023-003 HOME Investment Partnership Program, ALN. 14.239
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Subrecipient Monitoring
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.332 – Requirements for Pass-
Through Entities states, in part, that all pass-through entities must monitor the activities of the subrecipient as
necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes,
regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.
Condition and Context: For one (1) vendor in our sample of five (5) in a population of 13, documentation of monitoring
was not provided. For one (1) vendor in our sample of five (5) in a population of 13, there was no evidence of
management review of monitoring procedures.
Questioned Costs: None
Cause: Procedures were not in place to fully document subrecipient monitoring for all subrecipients.
Effect: Noncompliance with the federal grant program occurred.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to fully document subrecipient monitoring for all
subrecipients.
Views of Responsible Officials: Management agrees with the finding.
Material Weakness in Internal Control over Compliance and Material Noncompliance
2023-004 HOME Investment Partnership Program, ALN. 14.239
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Special Tests and Provisions
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 24 Part 92.504(d) states that during the
period of affordability, the participating jurisdiction must perform on-site inspections of HOME-assisted rental
housing to determine compliance with the property standards of § 92.251 and to verify the information submitted by
the owners in accordance with the requirements of § 92.252. The inspections must be in accordance with the
inspection procedures that the participating jurisdiction establishes to meet the inspection requirements of § 92.251.
Condition and Context: For one (1) out of nine (9) inspections selected for testing in our audit sample, the inspection
was not conducted within the required timeframe in accordance with federal requirements.
Questioned Costs: None
Cause: Procedures were not in place to perform inspections timely for all inspections.
Effect: Noncompliance with the federal grant program occurred.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to perform inspections timely for all inspections.
Views of Responsible Officials: Management agrees with the finding.
UNITED STATES DEPARTMENT OF EDUCATION
Significant Deficiency in Internal Control over Compliance
2023-001 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal
entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders
12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Condition and Context: For the one vendor in our audit sample, documentation was not provided to support that the
City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities
for the fiscal year 2023 time period.
Questioned Costs: None. The vendor was not suspended or debarred.
Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended
or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or
suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in
Federal assistance programs or activities.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not
suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.
UNITED STATES DEPARTMENT OF EDUCATION
Significant Deficiency in Internal Control over Compliance
2023-001 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal
entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders
12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Condition and Context: For the one vendor in our audit sample, documentation was not provided to support that the
City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities
for the fiscal year 2023 time period.
Questioned Costs: None. The vendor was not suspended or debarred.
Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended
or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or
suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in
Federal assistance programs or activities.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not
suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.
UNITED STATES DEPARTMENT OF EDUCATION
Significant Deficiency in Internal Control over Compliance
2023-001 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal
entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders
12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Condition and Context: For the one vendor in our audit sample, documentation was not provided to support that the
City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities
for the fiscal year 2023 time period.
Questioned Costs: None. The vendor was not suspended or debarred.
Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended
or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or
suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in
Federal assistance programs or activities.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not
suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.
UNITED STATES DEPARTMENT OF EDUCATION
Significant Deficiency in Internal Control over Compliance
2023-001 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Suspension and Debarment
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.214 states that nonfederal
entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders
12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that
are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Condition and Context: For the one vendor in our audit sample, documentation was not provided to support that the
City verified the vendor was not debarred or suspended from participation in Federal assistance programs or activities
for the fiscal year 2023 time period.
Questioned Costs: None. The vendor was not suspended or debarred.
Cause: Procedures were not adhered to for the documentation of the verification that all vendors were not suspended
or debarred from participation in Federal assistance programs or activities.
Effect: While this did not occur in the instances identified in this finding, lack of verification of vendors’ debarment or
suspension status could cause federal grant funds to be expended with vendors that are excluded from participation in
Federal assistance programs or activities.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document the verification that all vendors are not
suspended or debarred from participation in Federal assistance programs or activities.
Views of Responsible Officials: Management agrees with the finding.
Significant Deficiency in Internal Control over Compliance
2023-002 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal
awards for salaries and wages must be based on records that accurately reflect the work performed. These records
must be supported by a system of internal control which provides reasonable assurance that the charges are accurate,
allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee
is compensated by the non-Federal entity.
Condition and Context: For all of the payroll disbursements in our sample, evidence of management review of time and
effort was not provided.
Questioned Costs: None.
Cause: Procedures were not in place to document the management review of time and effort.
Effect: Significant deficiency in internal controls.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document and maintain on file the management
review of time and effort.
Views of Responsible Officials: Management agrees with the finding.
Significant Deficiency in Internal Control over Compliance
2023-002 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal
awards for salaries and wages must be based on records that accurately reflect the work performed. These records
must be supported by a system of internal control which provides reasonable assurance that the charges are accurate,
allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee
is compensated by the non-Federal entity.
Condition and Context: For all of the payroll disbursements in our sample, evidence of management review of time and
effort was not provided.
Questioned Costs: None.
Cause: Procedures were not in place to document the management review of time and effort.
Effect: Significant deficiency in internal controls.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document and maintain on file the management
review of time and effort.
Views of Responsible Officials: Management agrees with the finding.
Significant Deficiency in Internal Control over Compliance
2023-002 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal
awards for salaries and wages must be based on records that accurately reflect the work performed. These records
must be supported by a system of internal control which provides reasonable assurance that the charges are accurate,
allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee
is compensated by the non-Federal entity.
Condition and Context: For all of the payroll disbursements in our sample, evidence of management review of time and
effort was not provided.
Questioned Costs: None.
Cause: Procedures were not in place to document the management review of time and effort.
Effect: Significant deficiency in internal controls.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document and maintain on file the management
review of time and effort.
Views of Responsible Officials: Management agrees with the finding.
Significant Deficiency in Internal Control over Compliance
2023-002 Special Education Cluster, ALN. 84.027, 84.173
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Allowable Costs/Cost Principles
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.430 indicates charges to federal
awards for salaries and wages must be based on records that accurately reflect the work performed. These records
must be supported by a system of internal control which provides reasonable assurance that the charges are accurate,
allowable, and properly allocated. Such records must also reasonably reflect the total activity for which the employee
is compensated by the non-Federal entity.
Condition and Context: For all of the payroll disbursements in our sample, evidence of management review of time and
effort was not provided.
Questioned Costs: None.
Cause: Procedures were not in place to document the management review of time and effort.
Effect: Significant deficiency in internal controls.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to document and maintain on file the management
review of time and effort.
Views of Responsible Officials: Management agrees with the finding.
UNITED STATES DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Material Weakness in Internal Control over Compliance and Material Noncompliance
2023-003 HOME Investment Partnership Program, ALN. 14.239
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Subrecipient Monitoring
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 2 Part 200.332 – Requirements for Pass-
Through Entities states, in part, that all pass-through entities must monitor the activities of the subrecipient as
necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes,
regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.
Condition and Context: For one (1) vendor in our sample of five (5) in a population of 13, documentation of monitoring
was not provided. For one (1) vendor in our sample of five (5) in a population of 13, there was no evidence of
management review of monitoring procedures.
Questioned Costs: None
Cause: Procedures were not in place to fully document subrecipient monitoring for all subrecipients.
Effect: Noncompliance with the federal grant program occurred.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to fully document subrecipient monitoring for all
subrecipients.
Views of Responsible Officials: Management agrees with the finding.
Material Weakness in Internal Control over Compliance and Material Noncompliance
2023-004 HOME Investment Partnership Program, ALN. 14.239
Award Period: July 1, 2022 – June 30, 2023
Compliance Requirement: Special Tests and Provisions
Criteria or Specific Requirement: The Code of Federal Regulations (CFR) Title 24 Part 92.504(d) states that during the
period of affordability, the participating jurisdiction must perform on-site inspections of HOME-assisted rental
housing to determine compliance with the property standards of § 92.251 and to verify the information submitted by
the owners in accordance with the requirements of § 92.252. The inspections must be in accordance with the
inspection procedures that the participating jurisdiction establishes to meet the inspection requirements of § 92.251.
Condition and Context: For one (1) out of nine (9) inspections selected for testing in our audit sample, the inspection
was not conducted within the required timeframe in accordance with federal requirements.
Questioned Costs: None
Cause: Procedures were not in place to perform inspections timely for all inspections.
Effect: Noncompliance with the federal grant program occurred.
Repeat Finding: No.
Recommendation: We recommend procedures be strengthened to perform inspections timely for all inspections.
Views of Responsible Officials: Management agrees with the finding.