FAC Explorer

Audit 312282

FY End
2022-06-30
Total Expended
$250.36M
Findings
180
Programs
20
Organization: Board of Education Baltimore County (MD)
Year: 2022 Accepted: 2023-01-15
Auditor: Cliftonlarsonallen LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
421030 2022-001 Significant Deficiency Yes L
421031 2022-001 Significant Deficiency Yes L
421032 2022-001 Significant Deficiency Yes L
421033 2022-001 Significant Deficiency Yes L
421034 2022-001 Significant Deficiency Yes L
421035 2022-002 Significant Deficiency - I
421036 2022-002 Significant Deficiency - I
421037 2022-002 Significant Deficiency - I
421038 2022-002 Significant Deficiency - I
421039 2022-002 Significant Deficiency - I
421040 2022-002 Significant Deficiency - I
421041 2022-002 Significant Deficiency - I
421042 2022-002 Significant Deficiency - I
421043 2022-002 Significant Deficiency - I
421044 2022-002 Significant Deficiency - I
421045 2022-002 Significant Deficiency - I
421046 2022-002 Significant Deficiency - I
421047 2022-002 Significant Deficiency - I
421048 2022-002 Significant Deficiency - I
421049 2022-002 Significant Deficiency - I
421050 2022-002 Significant Deficiency - I
421051 2022-002 Significant Deficiency - I
421052 2022-002 Significant Deficiency - I
421053 2022-002 Significant Deficiency - I
421054 2022-002 Significant Deficiency - I
421055 2022-002 Significant Deficiency - I
421056 2022-002 Significant Deficiency - I
421057 2022-002 Significant Deficiency - I
421058 2022-002 Significant Deficiency - I
421059 2022-002 Significant Deficiency - I
421060 2022-003 Significant Deficiency - I
421061 2022-003 Significant Deficiency - I
421062 2022-003 Significant Deficiency - I
421063 2022-003 Significant Deficiency - I
421064 2022-003 Significant Deficiency - I
421065 2022-003 Significant Deficiency - I
421066 2022-003 Significant Deficiency - I
421067 2022-003 Significant Deficiency - I
421068 2022-003 Significant Deficiency - I
421069 2022-003 Significant Deficiency - I
421070 2022-003 Significant Deficiency - I
421071 2022-003 Significant Deficiency - I
421072 2022-003 Significant Deficiency - I
421073 2022-003 Significant Deficiency - I
421074 2022-003 Significant Deficiency - I
421075 2022-003 Significant Deficiency - I
421076 2022-003 Significant Deficiency - I
421077 2022-003 Significant Deficiency - I
421078 2022-003 Significant Deficiency - I
421079 2022-003 Significant Deficiency - I
421080 2022-003 Significant Deficiency - I
421081 2022-003 Significant Deficiency - I
421082 2022-003 Significant Deficiency - I
421083 2022-003 Significant Deficiency - I
421084 2022-003 Significant Deficiency - I
421085 2022-002 Significant Deficiency - I
421086 2022-002 Significant Deficiency - I
421087 2022-002 Significant Deficiency - I
421088 2022-002 Significant Deficiency - I
421089 2022-002 Significant Deficiency - I
421090 2022-002 Significant Deficiency - I
421091 2022-002 Significant Deficiency - I
421092 2022-002 Significant Deficiency - I
421093 2022-003 Significant Deficiency - I
421094 2022-003 Significant Deficiency - I
421095 2022-003 Significant Deficiency - I
421096 2022-003 Significant Deficiency - I
421097 2022-003 Significant Deficiency - I
421098 2022-003 Significant Deficiency - I
421099 2022-003 Significant Deficiency - I
421100 2022-003 Significant Deficiency - I
421101 2022-001 Significant Deficiency Yes L
421102 2022-001 Significant Deficiency Yes L
421103 2022-001 Significant Deficiency Yes L
421104 2022-001 Significant Deficiency Yes L
421105 2022-001 Significant Deficiency Yes L
421106 2022-001 Significant Deficiency Yes L
421107 2022-004 Significant Deficiency - B
421108 2022-001 Significant Deficiency Yes L
421109 2022-001 Significant Deficiency Yes L
421110 2022-001 Significant Deficiency Yes L
421111 2022-001 Significant Deficiency Yes L
421112 2022-004 Significant Deficiency - B
421113 2022-004 Significant Deficiency - B
421114 2022-004 Significant Deficiency - B
421115 2022-004 Significant Deficiency - B
421116 2022-001 Significant Deficiency Yes L
421117 2022-004 Significant Deficiency - B
421118 2022-001 Significant Deficiency Yes L
421119 2022-004 Significant Deficiency - B
997472 2022-001 Significant Deficiency Yes L
997473 2022-001 Significant Deficiency Yes L
997474 2022-001 Significant Deficiency Yes L
997475 2022-001 Significant Deficiency Yes L
997476 2022-001 Significant Deficiency Yes L
997477 2022-002 Significant Deficiency - I
997478 2022-002 Significant Deficiency - I
997479 2022-002 Significant Deficiency - I
997480 2022-002 Significant Deficiency - I
997481 2022-002 Significant Deficiency - I
997482 2022-002 Significant Deficiency - I
997483 2022-002 Significant Deficiency - I
997484 2022-002 Significant Deficiency - I
997485 2022-002 Significant Deficiency - I
997486 2022-002 Significant Deficiency - I
997487 2022-002 Significant Deficiency - I
997488 2022-002 Significant Deficiency - I
997489 2022-002 Significant Deficiency - I
997490 2022-002 Significant Deficiency - I
997491 2022-002 Significant Deficiency - I
997492 2022-002 Significant Deficiency - I
997493 2022-002 Significant Deficiency - I
997494 2022-002 Significant Deficiency - I
997495 2022-002 Significant Deficiency - I
997496 2022-002 Significant Deficiency - I
997497 2022-002 Significant Deficiency - I
997498 2022-002 Significant Deficiency - I
997499 2022-002 Significant Deficiency - I
997500 2022-002 Significant Deficiency - I
997501 2022-002 Significant Deficiency - I
997502 2022-003 Significant Deficiency - I
997503 2022-003 Significant Deficiency - I
997504 2022-003 Significant Deficiency - I
997505 2022-003 Significant Deficiency - I
997506 2022-003 Significant Deficiency - I
997507 2022-003 Significant Deficiency - I
997508 2022-003 Significant Deficiency - I
997509 2022-003 Significant Deficiency - I
997510 2022-003 Significant Deficiency - I
997511 2022-003 Significant Deficiency - I
997512 2022-003 Significant Deficiency - I
997513 2022-003 Significant Deficiency - I
997514 2022-003 Significant Deficiency - I
997515 2022-003 Significant Deficiency - I
997516 2022-003 Significant Deficiency - I
997517 2022-003 Significant Deficiency - I
997518 2022-003 Significant Deficiency - I
997519 2022-003 Significant Deficiency - I
997520 2022-003 Significant Deficiency - I
997521 2022-003 Significant Deficiency - I
997522 2022-003 Significant Deficiency - I
997523 2022-003 Significant Deficiency - I
997524 2022-003 Significant Deficiency - I
997525 2022-003 Significant Deficiency - I
997526 2022-003 Significant Deficiency - I
997527 2022-002 Significant Deficiency - I
997528 2022-002 Significant Deficiency - I
997529 2022-002 Significant Deficiency - I
997530 2022-002 Significant Deficiency - I
997531 2022-002 Significant Deficiency - I
997532 2022-002 Significant Deficiency - I
997533 2022-002 Significant Deficiency - I
997534 2022-002 Significant Deficiency - I
997535 2022-003 Significant Deficiency - I
997536 2022-003 Significant Deficiency - I
997537 2022-003 Significant Deficiency - I
997538 2022-003 Significant Deficiency - I
997539 2022-003 Significant Deficiency - I
997540 2022-003 Significant Deficiency - I
997541 2022-003 Significant Deficiency - I
997542 2022-003 Significant Deficiency - I
997543 2022-001 Significant Deficiency Yes L
997544 2022-001 Significant Deficiency Yes L
997545 2022-001 Significant Deficiency Yes L
997546 2022-001 Significant Deficiency Yes L
997547 2022-001 Significant Deficiency Yes L
997548 2022-001 Significant Deficiency Yes L
997549 2022-004 Significant Deficiency - B
997550 2022-001 Significant Deficiency Yes L
997551 2022-001 Significant Deficiency Yes L
997552 2022-001 Significant Deficiency Yes L
997553 2022-001 Significant Deficiency Yes L
997554 2022-004 Significant Deficiency - B
997555 2022-004 Significant Deficiency - B
997556 2022-004 Significant Deficiency - B
997557 2022-004 Significant Deficiency - B
997558 2022-001 Significant Deficiency Yes L
997559 2022-004 Significant Deficiency - B
997560 2022-001 Significant Deficiency Yes L
997561 2022-004 Significant Deficiency - B

Programs

ALN Program Spent Major Findings
10.559 Summer Food Service Program for Children $61.59M - 0
84.165 Magnet Schools Assistance $2.67M - 0
10.555 National School Lunch Program $1.15M - 0
84.181 Special Education-Grants for Infants and Families $705,135 - 0
93.575 Child Care and Development Block Grant $537,628 - 0
21.019 Coronavirus Relief Fund $265,665 - 0
16.839 Stop School Violence $253,707 - 0
10.582 Fresh Fruit and Vegetable Program $235,901 - 0
84.371 Striving Readers $218,243 - 0
84.425 Education Stabilization Fund $189,766 Yes 2
10.558 Child and Adult Care Food Program $185,650 - 0
84.010 Title I Grants to Local Educational Agencies $130,367 - 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $87,993 Yes 1
84.173 Special Education_preschool Grants $56,516 Yes 2
84.365 English Language Acquisition State Grants $44,388 - 0
84.367 Improving Teacher Quality State Grants $31,694 Yes 1
84.424 Student Support and Academic Enrichment Program $30,000 - 0
84.027 Special Education_grants to States $5,556 Yes 2
84.048 Career and Technical Education -- Basic Grants to States $3,343 - 0
10.553 School Breakfast Program $0 - 0

Contacts

Name Title Type
Z83MQKEJGYF7 Christopher Hartlove Auditee
4438094197 Cheri Amoss Auditor
No contacts on file

Notes to SEFA

Title: RELATION TO THE BASIC FINANCIAL STATEMENTS AND FEDERAL FINANCIAL REPORTS Accounting Policies: Reporting EntityThe accompanying Schedule of Expenditures of Federal Awards (the Schedule) presents the activity of all federal award programs of the Board of Education of Baltimore County (the Board), a component unit of Baltimore County, Maryland, for the year ended June 30, 2022.Basis of AccountingThe accompanying Schedule has been prepared using the modified accrual basis of accounting, except for the U.S. Department of Agriculture (USDA) programs which are presented using the accrual basis of accounting. This basis of accounting is fully described in Note 1 to the Boards basic financial statements. Such expenditures are recognized following the cost principles in the Uniform Guidance, with the exception of Assistance Listing 21.019, which follows criteria determined by the Department of Treasury for allowability of costs. Under these principles, certain type of expenditures are not allowable or are limited as toreimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Amounts reported in the accompanying Schedule agree with amounts reported in the Boards basic financial statements and the related federal financial reports submitted by the Board.The following is a reconciliation of federal awards reported in the Schedule to federal revenue reported in the Boards basic financial statements for the year ended June 30, 2022:Total Federal Expenditures Reported in the Schedule $250,361,930 Federal Revenues Included in the Basic Financial Statements that are Not Required to be Included in the Schedule: Medicaid Funds Included in Contract for Services8,370,413 R.O.T.C. Funds Included in Contract for Services 568,300 Other Grant Revenues Not Included in the Schedule (49,780)Total $259,250,863 Total Federal Revenues Reported in the Basic Financial Statements:Special Revenue Fund $183,023,267 Food Service Fund 75,659,296 General Fund 568,300 Total $259,250,863

Finding Details

Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-002
Finding Number: 2022-002Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)220391-02 (7/1/21 ? 9/30/23)221324-01 (7/1/21 ? 9/30/23)Compliance Requirement: ProcurementType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.318, a non-Federal entity must have and use documentedprocurement procedures, consistent with State, local, and tribal laws and regulations and the standardsof this section, for the acquisition of property or services required under a Federal award or subaward.Per 2 CFR section 200.319, all procurement transactions for the acquisition of property or servicesrequired under a Federal award must be conducted in a manner providing full and open competitionconsistent with the standards of this section and ? 200.320.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:Per its approved Procurement Policy, the Board is required to obtain 2 quotes for purchases between$15,000 and $50,000. We noted 4 out of 8 samples where only 1 quote was obtained for purchaseswithin the thresholds noted above.Questioned Costs:None noted.Cause:The Board did not retain documentation as to why the Procurement Policy was not followed.Effect: The Board could be circumventing the Procurement Policy.Recommendation:We recommend that the Board ensures that documentation of Procurement's decisions on anypurchases that are excluded from the requirements noted in the Procurement Policy are retained foraudit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-003
Finding Number: 2022-003Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: Special Education ClusterAssistance Listing: 84.027, 84.173Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211021-03 (10/1/20 ? 9/30/22)Compliance Requirement: Suspension and DebarmentType of Finding Significant Deficiency in Internal Control over ComplianceCriteria or Specific Requirement:Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adoptingregulations, is not suspended or debarred or otherwise excluded from participating in the transaction.For 2 out of 5 samples, the Board did not maintain documentation supporting when it had checked theentities? suspension and debarment status.Questioned Costs:None noted.Cause:The Board did not retain documentation showing the date it performed the suspension/debarmentcheck.Effect:Failure to adhere to suspension and debarment requirements may result in the Board entering into acontract or purchase with a vendor that is suspended or debarred and not authorized to provide goodsand services to the program.Recommendation:We recommend that the Board enhance its procedures and internal controls to ensure that it retainsdocumentation of procurement suspension/debarment status verifications for its vendors and that thisdocumentation is available for audit purposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding 2022-001
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding 2022-004
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.