Education Stabilization Fund - AL #84.425, Year Ended June 30, 2023
Career and Technical Education - AL #84.048, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity - Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Education requires Reconciliation of Cash on Hand Quarterly Reports for any program for which the Center is 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. The Center is required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The Center did not file the required quarterly reports for June 2023 and had a late filing for September 2022 report for grant #224-21-1161. Also, the Center did not file quarterly reports for June 2023 and September 2022 for grant #380-23-0039 and #381-23-0014. \ Cause and Effect: The Center did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the Center is potentially risking a withholding of federal funds until the reports are properly filed.
Identification of Repeat Finding: No.
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the Center 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: The Center acknowledges this finding, and will calendarize the requisite report submission dates on the task lists of the Business Manager, Assistant Business Manager, and the Administrative Director.
Education Stabilization Fund - AL #84.425, Year Ended June 30, 2023
Career and Technical Education - AL #84.048, 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 Center did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the Center made procurements through noncompetitive procurement 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, the Center could use noncompetitive procurement. The Center should consult with the Pennsylvania Department of Education before using this authority. Subsequently, the Center paid for this purchase utilizing the Education Stabilization Fund and Career and Technical Education monies. In using federal funds to pay for these items, the Center inadvertently did not follow its procurement policy.
Cause and Effect: When the Center initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The Center did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: No
Questioned Costs: None
Recommendation: We recommend that when the Center decides to utilize cooperative purchasing programs or noncompetitive purchasing arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The Center 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: The Center acknowledges this finding, and has since revised its procurement process to include the requisite items as required by the US DoE (ED) Uniform Grant Guidance (UGG) in its subsequent purchases with Federal Funds. It is also noted that most if not all of these purchases were made in response to the COVID-19 Pandemic, and with delayed guidance from PA Department of Education’s Federal Programs Office. When alerted to the guidance, the Center implemented the proper procedures
Education Stabilization Fund - AL #84.425, Year Ended June 30, 2023
Career and Technical Education - AL #84.048, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity - Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Education requires Reconciliation of Cash on Hand Quarterly Reports for any program for which the Center is 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. The Center is required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The Center did not file the required quarterly reports for June 2023 and had a late filing for September 2022 report for grant #224-21-1161. Also, the Center did not file quarterly reports for June 2023 and September 2022 for grant #380-23-0039 and #381-23-0014. \ Cause and Effect: The Center did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the Center is potentially risking a withholding of federal funds until the reports are properly filed.
Identification of Repeat Finding: No.
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the Center 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: The Center acknowledges this finding, and will calendarize the requisite report submission dates on the task lists of the Business Manager, Assistant Business Manager, and the Administrative Director.
Education Stabilization Fund - AL #84.425, Year Ended June 30, 2023
Career and Technical Education - AL #84.048, 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 Center did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the Center made procurements through noncompetitive procurement 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, the Center could use noncompetitive procurement. The Center should consult with the Pennsylvania Department of Education before using this authority. Subsequently, the Center paid for this purchase utilizing the Education Stabilization Fund and Career and Technical Education monies. In using federal funds to pay for these items, the Center inadvertently did not follow its procurement policy.
Cause and Effect: When the Center initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The Center did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: No
Questioned Costs: None
Recommendation: We recommend that when the Center decides to utilize cooperative purchasing programs or noncompetitive purchasing arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The Center 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: The Center acknowledges this finding, and has since revised its procurement process to include the requisite items as required by the US DoE (ED) Uniform Grant Guidance (UGG) in its subsequent purchases with Federal Funds. It is also noted that most if not all of these purchases were made in response to the COVID-19 Pandemic, and with delayed guidance from PA Department of Education’s Federal Programs Office. When alerted to the guidance, the Center implemented the proper procedures
Education Stabilization Fund - AL #84.425, Year Ended June 30, 2023
Career and Technical Education - AL #84.048, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity - Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Education requires Reconciliation of Cash on Hand Quarterly Reports for any program for which the Center is 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. The Center is required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The Center did not file the required quarterly reports for June 2023 and had a late filing for September 2022 report for grant #224-21-1161. Also, the Center did not file quarterly reports for June 2023 and September 2022 for grant #380-23-0039 and #381-23-0014. \ Cause and Effect: The Center did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the Center is potentially risking a withholding of federal funds until the reports are properly filed.
Identification of Repeat Finding: No.
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the Center 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: The Center acknowledges this finding, and will calendarize the requisite report submission dates on the task lists of the Business Manager, Assistant Business Manager, and the Administrative Director.
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 Department of Education, passed through entity Pennsylvania Department of Education states “Per Compliance Supplement (Part 4 84.425-Education Stabilization Funds) Governors, SEAs, and subrecipients must receive prior approval for capital expenditures for equipment acquisition or improvements to land, buildings, or equipment: For capital equipment or improvements to land, buildings, or equipment that were purchased with grant funds, the Governor (or mayor of the District of Columbia) or SEA must receive prior approval from ED.”
Condition: The Center did not receive proper approval for the purchase of capital equipment purchased with grant funds in the current year.
Cause and Effect: Because the Center did not receive proper approval for purchases of capital equipment, the Center is risking the allowability of the costs funded by the grant funds passed through by the Pennsylvania Department of Education.
Identification of Repeat Finding: No.
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the Center does not purchase equipment outside the standards set by the grant agreement and compliance supplement.
Management Response: The Center acknowledges this finding, and has since revised its permission process to include the requisite steps as required by the US DoE (ED) Uniform Grant Guidance (UGG) in its subsequent purchases with Federal Funds. It is also noted that most if not all of these purchases were made after the receipt of delayed guidance from PA Department of Education’s Federal Programs Office. When alerted to the guidance, the Center implemented the proper procedures.
Education Stabilization Fund - AL #84.425, Year Ended June 30, 2023
Career and Technical Education - AL #84.048, 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 Center did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the Center made procurements through noncompetitive procurement 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, the Center could use noncompetitive procurement. The Center should consult with the Pennsylvania Department of Education before using this authority. Subsequently, the Center paid for this purchase utilizing the Education Stabilization Fund and Career and Technical Education monies. In using federal funds to pay for these items, the Center inadvertently did not follow its procurement policy.
Cause and Effect: When the Center initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The Center did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: No
Questioned Costs: None
Recommendation: We recommend that when the Center decides to utilize cooperative purchasing programs or noncompetitive purchasing arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The Center 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: The Center acknowledges this finding, and has since revised its procurement process to include the requisite items as required by the US DoE (ED) Uniform Grant Guidance (UGG) in its subsequent purchases with Federal Funds. It is also noted that most if not all of these purchases were made in response to the COVID-19 Pandemic, and with delayed guidance from PA Department of Education’s Federal Programs Office. When alerted to the guidance, the Center implemented the proper procedures
Child Nutrition Cluster - AL #10.555, Year Ended June 30, 2023
U.S. Department of Agriculture
Pass-Through Entity - Pennsylvania Department of Education
Criteria: A child’s eligibility for free or reduced-price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies (LEAs), institutions, and sponsors determine eligibility by comparing the data reported by the child’s household to published income eligibility guidelines.
Condition: The Center did not retain the eligibility documentation for one student and there was an incorrect computation for one student.
Cause and Effect: Although the Center uses eTrition software to verify eligibility, the system is dependent upon information being entered accurately based on submitted applications or the state’s Compass system for direct certification. The Center received federal funds which it may not have been entitled to receive.
Identification of Repeat Finding: No.
Questioned Costs: ($3.93 Reduced Lunch federal reimbursement - $0.77 Paid Lunch federal reimbursement) x 180 days x 2 students = $1,137.60
Recommendation: We recommend that controls be reviewed and revised to ensure that accuracy and completeness of data used to determine eligibility requirements are reviewed and agreed to proper documentation as necessary by staff and reviewed by a knowledgeable supervisor.
Management Response: The Center acknowledges this finding, and will take the steps necessary to ensure that the information in the system is updated regularly.
Child Nutrition Cluster - AL #10.555, Year Ended June 30, 2023
U.S. Department of Agriculture
Pass-Through Entity - Pennsylvania Department of Education
Criteria: A child’s eligibility for free or reduced-price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies (LEAs), institutions, and sponsors determine eligibility by comparing the data reported by the child’s household to published income eligibility guidelines.
Condition: The Center did not retain the eligibility documentation for one student and there was an incorrect computation for one student.
Cause and Effect: Although the Center uses eTrition software to verify eligibility, the system is dependent upon information being entered accurately based on submitted applications or the state’s Compass system for direct certification. The Center received federal funds which it may not have been entitled to receive.
Identification of Repeat Finding: No.
Questioned Costs: ($3.93 Reduced Lunch federal reimbursement - $0.77 Paid Lunch federal reimbursement) x 180 days x 2 students = $1,137.60
Recommendation: We recommend that controls be reviewed and revised to ensure that accuracy and completeness of data used to determine eligibility requirements are reviewed and agreed to proper documentation as necessary by staff and reviewed by a knowledgeable supervisor.
Management Response: The Center acknowledges this finding, and will take the steps necessary to ensure that the information in the system is updated regularly.
Child Nutrition Cluster - AL #10.555, Year Ended June 30, 2023
U.S. Department of Agriculture
Pass-Through Entity - Pennsylvania Department of Education
Criteria: A child’s eligibility for free or reduced-price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies (LEAs), institutions, and sponsors determine eligibility by comparing the data reported by the child’s household to published income eligibility guidelines.
Condition: The Center did not retain the eligibility documentation for one student and there was an incorrect computation for one student.
Cause and Effect: Although the Center uses eTrition software to verify eligibility, the system is dependent upon information being entered accurately based on submitted applications or the state’s Compass system for direct certification. The Center received federal funds which it may not have been entitled to receive.
Identification of Repeat Finding: No.
Questioned Costs: ($3.93 Reduced Lunch federal reimbursement - $0.77 Paid Lunch federal reimbursement) x 180 days x 2 students = $1,137.60
Recommendation: We recommend that controls be reviewed and revised to ensure that accuracy and completeness of data used to determine eligibility requirements are reviewed and agreed to proper documentation as necessary by staff and reviewed by a knowledgeable supervisor.
Management Response: The Center acknowledges this finding, and will take the steps necessary to ensure that the information in the system is updated regularly.
Child Nutrition Cluster - AL #10.555, Year Ended June 30, 2023
U.S. Department of Agriculture
Pass-Through Entity - Pennsylvania Department of Education
Criteria: A child’s eligibility for free or reduced-price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies (LEAs), institutions, and sponsors determine eligibility by comparing the data reported by the child’s household to published income eligibility guidelines.
Condition: The Center did not retain the eligibility documentation for one student and there was an incorrect computation for one student.
Cause and Effect: Although the Center uses eTrition software to verify eligibility, the system is dependent upon information being entered accurately based on submitted applications or the state’s Compass system for direct certification. The Center received federal funds which it may not have been entitled to receive.
Identification of Repeat Finding: No.
Questioned Costs: ($3.93 Reduced Lunch federal reimbursement - $0.77 Paid Lunch federal reimbursement) x 180 days x 2 students = $1,137.60
Recommendation: We recommend that controls be reviewed and revised to ensure that accuracy and completeness of data used to determine eligibility requirements are reviewed and agreed to proper documentation as necessary by staff and reviewed by a knowledgeable supervisor.
Management Response: The Center acknowledges this finding, and will take the steps necessary to ensure that the information in the system is updated regularly.
Education Stabilization Fund - AL #84.425, Year Ended June 30, 2023
Career and Technical Education - AL #84.048, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity - Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Education requires Reconciliation of Cash on Hand Quarterly Reports for any program for which the Center is 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. The Center is required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The Center did not file the required quarterly reports for June 2023 and had a late filing for September 2022 report for grant #224-21-1161. Also, the Center did not file quarterly reports for June 2023 and September 2022 for grant #380-23-0039 and #381-23-0014. \ Cause and Effect: The Center did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the Center is potentially risking a withholding of federal funds until the reports are properly filed.
Identification of Repeat Finding: No.
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the Center 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: The Center acknowledges this finding, and will calendarize the requisite report submission dates on the task lists of the Business Manager, Assistant Business Manager, and the Administrative Director.
Education Stabilization Fund - AL #84.425, Year Ended June 30, 2023
Career and Technical Education - AL #84.048, 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 Center did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the Center made procurements through noncompetitive procurement 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, the Center could use noncompetitive procurement. The Center should consult with the Pennsylvania Department of Education before using this authority. Subsequently, the Center paid for this purchase utilizing the Education Stabilization Fund and Career and Technical Education monies. In using federal funds to pay for these items, the Center inadvertently did not follow its procurement policy.
Cause and Effect: When the Center initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The Center did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: No
Questioned Costs: None
Recommendation: We recommend that when the Center decides to utilize cooperative purchasing programs or noncompetitive purchasing arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The Center 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: The Center acknowledges this finding, and has since revised its procurement process to include the requisite items as required by the US DoE (ED) Uniform Grant Guidance (UGG) in its subsequent purchases with Federal Funds. It is also noted that most if not all of these purchases were made in response to the COVID-19 Pandemic, and with delayed guidance from PA Department of Education’s Federal Programs Office. When alerted to the guidance, the Center implemented the proper procedures
Education Stabilization Fund - AL #84.425, Year Ended June 30, 2023
Career and Technical Education - AL #84.048, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity - Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Education requires Reconciliation of Cash on Hand Quarterly Reports for any program for which the Center is 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. The Center is required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The Center did not file the required quarterly reports for June 2023 and had a late filing for September 2022 report for grant #224-21-1161. Also, the Center did not file quarterly reports for June 2023 and September 2022 for grant #380-23-0039 and #381-23-0014. \ Cause and Effect: The Center did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the Center is potentially risking a withholding of federal funds until the reports are properly filed.
Identification of Repeat Finding: No.
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the Center 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: The Center acknowledges this finding, and will calendarize the requisite report submission dates on the task lists of the Business Manager, Assistant Business Manager, and the Administrative Director.
Education Stabilization Fund - AL #84.425, Year Ended June 30, 2023
Career and Technical Education - AL #84.048, 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 Center did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the Center made procurements through noncompetitive procurement 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, the Center could use noncompetitive procurement. The Center should consult with the Pennsylvania Department of Education before using this authority. Subsequently, the Center paid for this purchase utilizing the Education Stabilization Fund and Career and Technical Education monies. In using federal funds to pay for these items, the Center inadvertently did not follow its procurement policy.
Cause and Effect: When the Center initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The Center did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: No
Questioned Costs: None
Recommendation: We recommend that when the Center decides to utilize cooperative purchasing programs or noncompetitive purchasing arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The Center 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: The Center acknowledges this finding, and has since revised its procurement process to include the requisite items as required by the US DoE (ED) Uniform Grant Guidance (UGG) in its subsequent purchases with Federal Funds. It is also noted that most if not all of these purchases were made in response to the COVID-19 Pandemic, and with delayed guidance from PA Department of Education’s Federal Programs Office. When alerted to the guidance, the Center implemented the proper procedures
Education Stabilization Fund - AL #84.425, Year Ended June 30, 2023
Career and Technical Education - AL #84.048, Year Ended June 30, 2023
U.S. Department of Education
Pass-Through Entity - Pennsylvania Department of Education
Criteria: The Pennsylvania Department of Education requires Reconciliation of Cash on Hand Quarterly Reports for any program for which the Center is 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. The Center is required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports.
Condition: The Center did not file the required quarterly reports for June 2023 and had a late filing for September 2022 report for grant #224-21-1161. Also, the Center did not file quarterly reports for June 2023 and September 2022 for grant #380-23-0039 and #381-23-0014. \ Cause and Effect: The Center did not file the quarterly cash on hand reports timely. By not filing the required reports in a timely manner, the Center is potentially risking a withholding of federal funds until the reports are properly filed.
Identification of Repeat Finding: No.
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the Center 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: The Center acknowledges this finding, and will calendarize the requisite report submission dates on the task lists of the Business Manager, Assistant Business Manager, and the Administrative Director.
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 Department of Education, passed through entity Pennsylvania Department of Education states “Per Compliance Supplement (Part 4 84.425-Education Stabilization Funds) Governors, SEAs, and subrecipients must receive prior approval for capital expenditures for equipment acquisition or improvements to land, buildings, or equipment: For capital equipment or improvements to land, buildings, or equipment that were purchased with grant funds, the Governor (or mayor of the District of Columbia) or SEA must receive prior approval from ED.”
Condition: The Center did not receive proper approval for the purchase of capital equipment purchased with grant funds in the current year.
Cause and Effect: Because the Center did not receive proper approval for purchases of capital equipment, the Center is risking the allowability of the costs funded by the grant funds passed through by the Pennsylvania Department of Education.
Identification of Repeat Finding: No.
Questioned Costs: None
Recommendation: Procedures should be established to ensure that the Center does not purchase equipment outside the standards set by the grant agreement and compliance supplement.
Management Response: The Center acknowledges this finding, and has since revised its permission process to include the requisite steps as required by the US DoE (ED) Uniform Grant Guidance (UGG) in its subsequent purchases with Federal Funds. It is also noted that most if not all of these purchases were made after the receipt of delayed guidance from PA Department of Education’s Federal Programs Office. When alerted to the guidance, the Center implemented the proper procedures.
Education Stabilization Fund - AL #84.425, Year Ended June 30, 2023
Career and Technical Education - AL #84.048, 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 Center did not follow the appropriate procedures to comply with Uniform Grant Guidance. During testing, it was noted that the Center made procurements through noncompetitive procurement 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, the Center could use noncompetitive procurement. The Center should consult with the Pennsylvania Department of Education before using this authority. Subsequently, the Center paid for this purchase utilizing the Education Stabilization Fund and Career and Technical Education monies. In using federal funds to pay for these items, the Center inadvertently did not follow its procurement policy.
Cause and Effect: When the Center initially made the purchases, they did not follow the more stringent requirements imposed by Uniform Guidance. The Center did not follow its procurement policy and ultimately did not comply with the standard of the Uniform Grant Guidance.
Identification of Repeat Finding: No
Questioned Costs: None
Recommendation: We recommend that when the Center decides to utilize cooperative purchasing programs or noncompetitive purchasing arrangements and use federal funds to pay for those purchases they ensure that they comply with their procurement policy. The Center 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: The Center acknowledges this finding, and has since revised its procurement process to include the requisite items as required by the US DoE (ED) Uniform Grant Guidance (UGG) in its subsequent purchases with Federal Funds. It is also noted that most if not all of these purchases were made in response to the COVID-19 Pandemic, and with delayed guidance from PA Department of Education’s Federal Programs Office. When alerted to the guidance, the Center implemented the proper procedures
Child Nutrition Cluster - AL #10.555, Year Ended June 30, 2023
U.S. Department of Agriculture
Pass-Through Entity - Pennsylvania Department of Education
Criteria: A child’s eligibility for free or reduced-price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies (LEAs), institutions, and sponsors determine eligibility by comparing the data reported by the child’s household to published income eligibility guidelines.
Condition: The Center did not retain the eligibility documentation for one student and there was an incorrect computation for one student.
Cause and Effect: Although the Center uses eTrition software to verify eligibility, the system is dependent upon information being entered accurately based on submitted applications or the state’s Compass system for direct certification. The Center received federal funds which it may not have been entitled to receive.
Identification of Repeat Finding: No.
Questioned Costs: ($3.93 Reduced Lunch federal reimbursement - $0.77 Paid Lunch federal reimbursement) x 180 days x 2 students = $1,137.60
Recommendation: We recommend that controls be reviewed and revised to ensure that accuracy and completeness of data used to determine eligibility requirements are reviewed and agreed to proper documentation as necessary by staff and reviewed by a knowledgeable supervisor.
Management Response: The Center acknowledges this finding, and will take the steps necessary to ensure that the information in the system is updated regularly.
Child Nutrition Cluster - AL #10.555, Year Ended June 30, 2023
U.S. Department of Agriculture
Pass-Through Entity - Pennsylvania Department of Education
Criteria: A child’s eligibility for free or reduced-price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies (LEAs), institutions, and sponsors determine eligibility by comparing the data reported by the child’s household to published income eligibility guidelines.
Condition: The Center did not retain the eligibility documentation for one student and there was an incorrect computation for one student.
Cause and Effect: Although the Center uses eTrition software to verify eligibility, the system is dependent upon information being entered accurately based on submitted applications or the state’s Compass system for direct certification. The Center received federal funds which it may not have been entitled to receive.
Identification of Repeat Finding: No.
Questioned Costs: ($3.93 Reduced Lunch federal reimbursement - $0.77 Paid Lunch federal reimbursement) x 180 days x 2 students = $1,137.60
Recommendation: We recommend that controls be reviewed and revised to ensure that accuracy and completeness of data used to determine eligibility requirements are reviewed and agreed to proper documentation as necessary by staff and reviewed by a knowledgeable supervisor.
Management Response: The Center acknowledges this finding, and will take the steps necessary to ensure that the information in the system is updated regularly.
Child Nutrition Cluster - AL #10.555, Year Ended June 30, 2023
U.S. Department of Agriculture
Pass-Through Entity - Pennsylvania Department of Education
Criteria: A child’s eligibility for free or reduced-price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies (LEAs), institutions, and sponsors determine eligibility by comparing the data reported by the child’s household to published income eligibility guidelines.
Condition: The Center did not retain the eligibility documentation for one student and there was an incorrect computation for one student.
Cause and Effect: Although the Center uses eTrition software to verify eligibility, the system is dependent upon information being entered accurately based on submitted applications or the state’s Compass system for direct certification. The Center received federal funds which it may not have been entitled to receive.
Identification of Repeat Finding: No.
Questioned Costs: ($3.93 Reduced Lunch federal reimbursement - $0.77 Paid Lunch federal reimbursement) x 180 days x 2 students = $1,137.60
Recommendation: We recommend that controls be reviewed and revised to ensure that accuracy and completeness of data used to determine eligibility requirements are reviewed and agreed to proper documentation as necessary by staff and reviewed by a knowledgeable supervisor.
Management Response: The Center acknowledges this finding, and will take the steps necessary to ensure that the information in the system is updated regularly.
Child Nutrition Cluster - AL #10.555, Year Ended June 30, 2023
U.S. Department of Agriculture
Pass-Through Entity - Pennsylvania Department of Education
Criteria: A child’s eligibility for free or reduced-price meals under a Child Nutrition Cluster program may be established by the submission of an annual application or statement which furnishes such information as family income and family size. Local educational agencies (LEAs), institutions, and sponsors determine eligibility by comparing the data reported by the child’s household to published income eligibility guidelines.
Condition: The Center did not retain the eligibility documentation for one student and there was an incorrect computation for one student.
Cause and Effect: Although the Center uses eTrition software to verify eligibility, the system is dependent upon information being entered accurately based on submitted applications or the state’s Compass system for direct certification. The Center received federal funds which it may not have been entitled to receive.
Identification of Repeat Finding: No.
Questioned Costs: ($3.93 Reduced Lunch federal reimbursement - $0.77 Paid Lunch federal reimbursement) x 180 days x 2 students = $1,137.60
Recommendation: We recommend that controls be reviewed and revised to ensure that accuracy and completeness of data used to determine eligibility requirements are reviewed and agreed to proper documentation as necessary by staff and reviewed by a knowledgeable supervisor.
Management Response: The Center acknowledges this finding, and will take the steps necessary to ensure that the information in the system is updated regularly.