Audit 312521

FY End
2022-06-30
Total Expended
$6.18M
Findings
6
Programs
16
Organization: Circle of Nations School INC (ND)
Year: 2022 Accepted: 2023-03-30
Auditor: Eide Bailly LLP

Organization Exclusion Status:

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Findings

ID Ref Severity Repeat Requirement
442917 2022-008 Material Weakness Yes AB
442918 2022-008 Material Weakness - N
442919 2022-009 Material Weakness - AB
1019359 2022-008 Material Weakness Yes AB
1019360 2022-008 Material Weakness - N
1019361 2022-009 Material Weakness - AB

Contacts

Name Title Type
K4ZERNMLBKY3 Jorge Sanchez Auditee
7016727336 Derek Flanagan Auditor
No contacts on file

Notes to SEFA

Title: Basis of Presentation Accounting Policies: Expenditures reported in the schedule are reported on the accrual basis of accounting. When applicable, suchexpenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certaintypes of expenditures are not allowable or are limited as to reimbursement. No federal financial assistance hasbeen provided to a subrecipient. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The accompanying schedule of expenditures of federal awards (the schedule) includes the federal grant activityof Circle of Nations School, Inc. (the School) under programs of the federal government for the year ended June30, 2022. The information is presented in accordance with the requirements of Title 2 U.S. Code of FederalRegulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for FederalAwards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of theSchool, it is not intended to and does not present the financial position or changes in net assets of the School.

Finding Details

Material Weakness in Internal Control Over Compliance and Material Instance of Noncompliance2022-008 Department of EducationFederal Financial Assistance Listing/CFDA Number 84.425Education Stabilization FundSpecial Tests and ProvisionsCriteria ? Uniform Guidance and 2 CFR 656.40 through 656.41 set forth the standardsnonfederal entities other than states must follow when operating federal programs.Condition ? In our testing of Special Tests and Provisions, it was identified that the School didnot satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The School did not ensureproper inclusion of prevailing wage rate clauses were included in a construction contract andalso did not obtain proper support to ensure required certified payrolls were submitted.Cause ? Lack of oversight, awareness, or understanding of all of the specific requirements underUniform Guidance and applicable CFR sections, and controls were not adequately designed toensure compliance with all of these requirements.Effect ? Lack of compliance to federal requirements increases the overall risk of non-compliance.Questioned Costs ? None reportedContext/Sampling ? All contracts were selected for testing.Repeat Finding from Prior Years ? No.Recommendation ? We recommend that management establish controls to follow all applicablerequirements under Uniform Guidance and applicable CFR sections.View of responsible officials ? There is no disagreement with the finding.
Material Weakness in Internal Control Over Compliance and Material Instance of Noncompliance2022-008 Department of EducationFederal Financial Assistance Listing/CFDA Number 84.425Education Stabilization FundSpecial Tests and ProvisionsCriteria ? Uniform Guidance and 2 CFR 656.40 through 656.41 set forth the standardsnonfederal entities other than states must follow when operating federal programs.Condition ? In our testing of Special Tests and Provisions, it was identified that the School didnot satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The School did not ensureproper inclusion of prevailing wage rate clauses were included in a construction contract andalso did not obtain proper support to ensure required certified payrolls were submitted.Cause ? Lack of oversight, awareness, or understanding of all of the specific requirements underUniform Guidance and applicable CFR sections, and controls were not adequately designed toensure compliance with all of these requirements.Effect ? Lack of compliance to federal requirements increases the overall risk of non-compliance.Questioned Costs ? None reportedContext/Sampling ? All contracts were selected for testing.Repeat Finding from Prior Years ? No.Recommendation ? We recommend that management establish controls to follow all applicablerequirements under Uniform Guidance and applicable CFR sections.View of responsible officials ? There is no disagreement with the finding.
Material Weakness in Internal Control Over Compliance and Immaterial Instance of Noncompliance2022-009 Department of EducationFederal Financial Assistance Listing/CFDA Number 84.425Education Stabilization FundAllowable Costs/Activities Allowed or UnallowedCriteria ? A good system of internal control includes an adequate system for ensuring allexpenditures are properly recorded and allowable under the related federal grant in accordancewith 2 CFR 200.430(i).Condition ? In our testing of allowable costs and activities we noted four instances ofexpenditures that were not COVID related and therefore not allowable under the terms of thegrant.Cause ? Procedures are not in place to adequately identify unallowable costs or activities.Effect ? A lack of internal controls over allowable costs and activities could result in improperuse of federal funds and non-compliance with the provisions of applicable grant requirements.Questioned Costs ? $27,110Context/Sampling ? A nonstatistical sample of 60 transactions out of 994 total transactions wereselected for testing, which accounted for $833,248 of $1,232,609 of federal programexpenditures.Repeat Finding from Prior Years ? No.Recommendation ? The School should review internal control procedures to ensure federalexpenditures are being properly reviewed for unallowable costs and activities.Views of Responsible Officials ? There is no disagreement with the audit finding.
Material Weakness in Internal Control Over Compliance and Material Instance of Noncompliance2022-008 Department of EducationFederal Financial Assistance Listing/CFDA Number 84.425Education Stabilization FundSpecial Tests and ProvisionsCriteria ? Uniform Guidance and 2 CFR 656.40 through 656.41 set forth the standardsnonfederal entities other than states must follow when operating federal programs.Condition ? In our testing of Special Tests and Provisions, it was identified that the School didnot satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The School did not ensureproper inclusion of prevailing wage rate clauses were included in a construction contract andalso did not obtain proper support to ensure required certified payrolls were submitted.Cause ? Lack of oversight, awareness, or understanding of all of the specific requirements underUniform Guidance and applicable CFR sections, and controls were not adequately designed toensure compliance with all of these requirements.Effect ? Lack of compliance to federal requirements increases the overall risk of non-compliance.Questioned Costs ? None reportedContext/Sampling ? All contracts were selected for testing.Repeat Finding from Prior Years ? No.Recommendation ? We recommend that management establish controls to follow all applicablerequirements under Uniform Guidance and applicable CFR sections.View of responsible officials ? There is no disagreement with the finding.
Material Weakness in Internal Control Over Compliance and Material Instance of Noncompliance2022-008 Department of EducationFederal Financial Assistance Listing/CFDA Number 84.425Education Stabilization FundSpecial Tests and ProvisionsCriteria ? Uniform Guidance and 2 CFR 656.40 through 656.41 set forth the standardsnonfederal entities other than states must follow when operating federal programs.Condition ? In our testing of Special Tests and Provisions, it was identified that the School didnot satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The School did not ensureproper inclusion of prevailing wage rate clauses were included in a construction contract andalso did not obtain proper support to ensure required certified payrolls were submitted.Cause ? Lack of oversight, awareness, or understanding of all of the specific requirements underUniform Guidance and applicable CFR sections, and controls were not adequately designed toensure compliance with all of these requirements.Effect ? Lack of compliance to federal requirements increases the overall risk of non-compliance.Questioned Costs ? None reportedContext/Sampling ? All contracts were selected for testing.Repeat Finding from Prior Years ? No.Recommendation ? We recommend that management establish controls to follow all applicablerequirements under Uniform Guidance and applicable CFR sections.View of responsible officials ? There is no disagreement with the finding.
Material Weakness in Internal Control Over Compliance and Immaterial Instance of Noncompliance2022-009 Department of EducationFederal Financial Assistance Listing/CFDA Number 84.425Education Stabilization FundAllowable Costs/Activities Allowed or UnallowedCriteria ? A good system of internal control includes an adequate system for ensuring allexpenditures are properly recorded and allowable under the related federal grant in accordancewith 2 CFR 200.430(i).Condition ? In our testing of allowable costs and activities we noted four instances ofexpenditures that were not COVID related and therefore not allowable under the terms of thegrant.Cause ? Procedures are not in place to adequately identify unallowable costs or activities.Effect ? A lack of internal controls over allowable costs and activities could result in improperuse of federal funds and non-compliance with the provisions of applicable grant requirements.Questioned Costs ? $27,110Context/Sampling ? A nonstatistical sample of 60 transactions out of 994 total transactions wereselected for testing, which accounted for $833,248 of $1,232,609 of federal programexpenditures.Repeat Finding from Prior Years ? No.Recommendation ? The School should review internal control procedures to ensure federalexpenditures are being properly reviewed for unallowable costs and activities.Views of Responsible Officials ? There is no disagreement with the audit finding.