2023-020 ALLOWABLE COSTS AND COST PRINCIPLES - SPECIAL EDUCATION CLUSTER
Grant Title: Special Education Cluster (IDEA): Special Education Grants to States, Special Education Preschool Grants
Federal Award Number and Year: 2023 Assistance Listing #: 84.027A, 84.027, 84.027X, 84.173X, 84.173
Federal Agency: US Department of Education
Pass-through Entity number: 43330, 43132, 43210, 43280, 43290
Pass-through Agency: WV Department of Education
CONDITION: The Monroe County Board of Education (the “Board”) did not comply with the allowable costs/cost principle for the Special Education Cluster. Three charges to the Special Education Cluster were duplicate payments and seven charges to the Special Education Cluster did not match supporting documentation.
CONTEXT: 51 non-payroll expenditures were sampled from a population of 100 for the Special Education Cluster, of which:
● Three expenditures, or 6% of the sample size, were duplicate charges to the grant.
CRITERIA: In accordance with 2 CFR Part 200, Subpart E—Cost Principles, federal grant funds must be used in accordance with the specific terms and conditions of the grant, including ensuring that all costs charged to the grant are allowable, reasonable, and adequately supported. The Uniform Guidance requires that expenditures must be necessary and reasonable for the performance of the federal award and must be allocable thereto.
QUESTIONED COSTS: None. Actual and likely questioned costs are below $25,000 and program materiality.
CAUSE: The noncompliance resulted from inadequate internal controls over the review and approval of expenditures charged to the Special Education Cluster programs. Specifically, there was a failure to detect and prevent duplicate payments and to ensure that all expenditures were supported by adequate documentation before approval and payment.
EFFECT: Although the actual and likely costs are below $25,000 and do not exceed program materiality, the identified items could result in the potential disallowance of Federal funds. Additionally, failure to maintain adequate documentation for program expenditures could jeopardize the Board's ability to receive future federal funding and may lead to repayment of questioned costs to the federal government.
REPEAT FINDING: No
RECOMMENDATION: We recommend that the Board strengthen its internal controls over the expenditure review and approval process to ensure that all charges to the Special Education Cluster programs are adequately supported and in compliance with the allowable cost/cost principles requirements under the Uniform Guidance. This includes implementing procedures to prevent duplicate payments and ensuring that all expenditures have the required supporting documentation.
VIEWS OF RESPONSIBLE OFFICIALS: The Board concurs with the finding. The Board acknowledges the importance of adhering to the allowable cost/cost principles requirements and recognizes the need to strengthen its internal controls over federal program expenditures.
2023-018 EQUIPMENT AND REAL PROPERTY MANAGEMENT - ESSER
Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER)
Federal Award Number and Year: 2023
Assistance Listing #: 84.425D and 84.425U
Federal Agency: US Department of Education
Pass-through Entity number: 52110 and 52160
Pass-through Agency: WV Department of Education
CONDITION: The Monroe County Board of Education (the "Board") did not follow the federal requirements for equipment and real property management under the COVID-19 American Rescue Plan ESSER program. The Board maintained photographic evidence of the inventoried items but failed to maintain a detailed listing of the equipment and real property, as required by federal regulations.
CONTEXT: During the audit period, the Board was responsible for managing equipment and real property acquired under the COVID-19 American Rescue Plan ESSER program. However, the documentation reviewed during the audit revealed that the Board had not maintained a formal inventory listing. Instead, the Board relied on photographic records and a project manual to document the existence and condition of the equipment and real property, which is not sufficient to meet the federal requirements.
CRITERIA: In accordance with 2 CFR § 200.313(d), non-Federal entities must maintain accurate records for equipment acquired with federal funds, including a detailed listing that identifies each item, its location, its condition, and other pertinent details. This listing must be updated as needed and must be verified by a physical inventory at least once every two years.
QUESTIONED COSTS: None
CAUSE: The noncompliance appears to have been by a lack of awareness or understanding of the specific federal requirements for maintaining a detailed inventory listing for equipment and real property. The Board relied on photographic records without recognizing the necessity of a formal, detailed listing as mandated by federal regulations.
EFFECT: Failure to maintain a detailed inventory listing as required by federal regulations increases the risk of mismanagement or loss of equipment and real property and could impact the Board's ability to receive future federal funding.
REPEAT FINDING: No
RECOMMENDATION: We recommend that the Board establish and maintain a detailed inventory listing for all equipment and real property acquired with federal funds. This listing should include all information required by federal regulations and should be verified through a physical inventory at least once every two years. Additionally, the Board should provide training to staff responsible for equipment and real property management to ensure compliance with federal requirements.
VIEWS OF RESPONSIBLE OFFICIALS: The Board acknowledges the finding and agrees with the recommendation.
2023-018 EQUIPMENT AND REAL PROPERTY MANAGEMENT - ESSER
Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER)
Federal Award Number and Year: 2023
Assistance Listing #: 84.425D and 84.425U
Federal Agency: US Department of Education
Pass-through Entity number: 52110 and 52160
Pass-through Agency: WV Department of Education
CONDITION: The Monroe County Board of Education (the "Board") did not follow the federal requirements for equipment and real property management under the COVID-19 American Rescue Plan ESSER program. The Board maintained photographic evidence of the inventoried items but failed to maintain a detailed listing of the equipment and real property, as required by federal regulations.
CONTEXT: During the audit period, the Board was responsible for managing equipment and real property acquired under the COVID-19 American Rescue Plan ESSER program. However, the documentation reviewed during the audit revealed that the Board had not maintained a formal inventory listing. Instead, the Board relied on photographic records and a project manual to document the existence and condition of the equipment and real property, which is not sufficient to meet the federal requirements.
CRITERIA: In accordance with 2 CFR § 200.313(d), non-Federal entities must maintain accurate records for equipment acquired with federal funds, including a detailed listing that identifies each item, its location, its condition, and other pertinent details. This listing must be updated as needed and must be verified by a physical inventory at least once every two years.
QUESTIONED COSTS: None
CAUSE: The noncompliance appears to have been by a lack of awareness or understanding of the specific federal requirements for maintaining a detailed inventory listing for equipment and real property. The Board relied on photographic records without recognizing the necessity of a formal, detailed listing as mandated by federal regulations.
EFFECT: Failure to maintain a detailed inventory listing as required by federal regulations increases the risk of mismanagement or loss of equipment and real property and could impact the Board's ability to receive future federal funding.
REPEAT FINDING: No
RECOMMENDATION: We recommend that the Board establish and maintain a detailed inventory listing for all equipment and real property acquired with federal funds. This listing should include all information required by federal regulations and should be verified through a physical inventory at least once every two years. Additionally, the Board should provide training to staff responsible for equipment and real property management to ensure compliance with federal requirements.
VIEWS OF RESPONSIBLE OFFICIALS: The Board acknowledges the finding and agrees with the recommendation.
2023-019 ALLOWABLE COSTS AND COST PRINCIPLES - ESSER
Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER)
Federal Award Number and Year: 2023
Assistance Listing #: 84.425D and 84.425U
Federal Agency: US Department of Education
Pass-through Entity number: 52110 and 52160
Pass-through Agency: WV Department of Education
CONDITION: The Monroe County Board of Education (the “Board”) did not comply with the allowable costs/cost principle related to the ESSER grant. Several expenditures to the ESSER had supporting documentation which did not agree to the costs charged to the grant.
CONTEXT: 51 non-payroll expenditures were sampled from a population of 134 for ESSER, of which:
Three expenditures, or 6% of the sample size, did not agree with the charges recorded to the grant.
CRITERIA: According to Title 2 CFR Part 200.403(g), Uniform Guidance, for costs to be allowable under federal awards, they must be adequately documented, and must align with the purposes of the grant. The Board is required to maintain accurate and complete records to support that expenditures are reasonable, necessary, and allocable to the grant.
QUESTIONED COSTS: None. Actual and likely questioned costs are below $25,000 and program materiality.
CAUSE: The noncompliance occurred due to insufficient review processes and oversight of expenditures charged to the grant. The Board’s current internal controls were not effective in ensuring that all costs met the allowable costs/cost principles criteria.
EFFECT: Although the actual and likely costs are below $25,000 and do not exceed program materiality, charging costs to the program that do not agree with supporting documentation may result in the disallowance of the questioned costs by the federal grantor agency. This could lead to financial liabilities for the Board and potentially jeopardize future federal funding.
REPEAT FINDING: No
RECOMMENDATION: We recommend that the Board strengthen its internal controls over the review and approval of expenditures charged to federal grants. This should include ensuring that all expenditures are adequately documented and that they align with the purposes of the grant. Training should be provided to relevant staff on the requirements of Title 2 CFR Part 200.403 to prevent future occurrences of this finding.
VIEWS OF RESPONSIBLE OFFICIALS: The Board acknowledges the finding and agrees with the recommendation and is committed to improving its internal controls to ensure compliance with federal regulations.
2023-021 ACTIVITIES ALLOWED/UNALLOWED - ESSER
Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER)
Federal Award Number and Year: 2023
Assistance Listing #: 84.425U
Federal Agency: US Department of Education
Pass-through Entity number: 52160
Pass-through Agency: WV Department of Education
CONDITION: The Monroe County Board of Education (the “Board”) did not comply with the activities allowed/unallowed requirement. We noted a charge to the ESSER grant that is an unallowed activity.
CONTEXT: 51 non-payroll expenditures were sampled from a population of 134 for the ESSER grant, of which:
● One expenditure, or 2% of the sample size, were for admission to a “Minions” movie totaling $585.00.
CRITERIA: Per the 2023 Compliance Supplement and the Uniform Guidance (2 CFR Part 200), all expenditures charged to the ESSER program must be necessary, reasonable, and allocable to the program's purpose. Costs such as entertainment, including admission to movies, are generally unallowable unless they meet specific educational purposes aligned with the program’s objectives.
QUESTIONED COSTS: None. Actual and likely questioned costs are below $25,000 and program materiality.
CAUSE: The noncompliance occurred due to a lack of understanding or misinterpretation of the ESSER program's allowable activities. The Board may have believed the expenditure aligned with the program's objectives of supporting students, but it did not meet the strict requirements set forth by federal regulations.
EFFECT: Although the actual and likely costs are below $25,000 and do not exceed program materiality, the identified items increases the risk of unallowable activities being charged to federal programs. This finding could result in the need to return federal funds, negatively impacting the Board's financial resources and its ability to effectively manage the ESSER program.
REPEAT FINDING: No
RECOMMENDATION: We recommend that the Board enhance its review and approval process for expenditures charged to the ESSER program. This should include additional training for staff involved in the approval of such expenditures, ensuring that all charges are necessary, reasonable, and directly related to the program’s objectives. The Board should also review and potentially seek reimbursement of the questioned costs identified in this finding.
VIEWS OF RESPONSIBLE OFFICIALS: The Board acknowledges the finding and agrees that the expenditure in question was not in compliance with the ESSER program's allowable activites.
2023-020 ALLOWABLE COSTS AND COST PRINCIPLES - SPECIAL EDUCATION CLUSTER
Grant Title: Special Education Cluster (IDEA): Special Education Grants to States, Special Education Preschool Grants
Federal Award Number and Year: 2023 Assistance Listing #: 84.027A, 84.027, 84.027X, 84.173X, 84.173
Federal Agency: US Department of Education
Pass-through Entity number: 43330, 43132, 43210, 43280, 43290
Pass-through Agency: WV Department of Education
CONDITION: The Monroe County Board of Education (the “Board”) did not comply with the allowable costs/cost principle for the Special Education Cluster. Three charges to the Special Education Cluster were duplicate payments and seven charges to the Special Education Cluster did not match supporting documentation.
CONTEXT: 51 non-payroll expenditures were sampled from a population of 100 for the Special Education Cluster, of which:
● Three expenditures, or 6% of the sample size, were duplicate charges to the grant.
CRITERIA: In accordance with 2 CFR Part 200, Subpart E—Cost Principles, federal grant funds must be used in accordance with the specific terms and conditions of the grant, including ensuring that all costs charged to the grant are allowable, reasonable, and adequately supported. The Uniform Guidance requires that expenditures must be necessary and reasonable for the performance of the federal award and must be allocable thereto.
QUESTIONED COSTS: None. Actual and likely questioned costs are below $25,000 and program materiality.
CAUSE: The noncompliance resulted from inadequate internal controls over the review and approval of expenditures charged to the Special Education Cluster programs. Specifically, there was a failure to detect and prevent duplicate payments and to ensure that all expenditures were supported by adequate documentation before approval and payment.
EFFECT: Although the actual and likely costs are below $25,000 and do not exceed program materiality, the identified items could result in the potential disallowance of Federal funds. Additionally, failure to maintain adequate documentation for program expenditures could jeopardize the Board's ability to receive future federal funding and may lead to repayment of questioned costs to the federal government.
REPEAT FINDING: No
RECOMMENDATION: We recommend that the Board strengthen its internal controls over the expenditure review and approval process to ensure that all charges to the Special Education Cluster programs are adequately supported and in compliance with the allowable cost/cost principles requirements under the Uniform Guidance. This includes implementing procedures to prevent duplicate payments and ensuring that all expenditures have the required supporting documentation.
VIEWS OF RESPONSIBLE OFFICIALS: The Board concurs with the finding. The Board acknowledges the importance of adhering to the allowable cost/cost principles requirements and recognizes the need to strengthen its internal controls over federal program expenditures.
2023-018 EQUIPMENT AND REAL PROPERTY MANAGEMENT - ESSER
Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER)
Federal Award Number and Year: 2023
Assistance Listing #: 84.425D and 84.425U
Federal Agency: US Department of Education
Pass-through Entity number: 52110 and 52160
Pass-through Agency: WV Department of Education
CONDITION: The Monroe County Board of Education (the "Board") did not follow the federal requirements for equipment and real property management under the COVID-19 American Rescue Plan ESSER program. The Board maintained photographic evidence of the inventoried items but failed to maintain a detailed listing of the equipment and real property, as required by federal regulations.
CONTEXT: During the audit period, the Board was responsible for managing equipment and real property acquired under the COVID-19 American Rescue Plan ESSER program. However, the documentation reviewed during the audit revealed that the Board had not maintained a formal inventory listing. Instead, the Board relied on photographic records and a project manual to document the existence and condition of the equipment and real property, which is not sufficient to meet the federal requirements.
CRITERIA: In accordance with 2 CFR § 200.313(d), non-Federal entities must maintain accurate records for equipment acquired with federal funds, including a detailed listing that identifies each item, its location, its condition, and other pertinent details. This listing must be updated as needed and must be verified by a physical inventory at least once every two years.
QUESTIONED COSTS: None
CAUSE: The noncompliance appears to have been by a lack of awareness or understanding of the specific federal requirements for maintaining a detailed inventory listing for equipment and real property. The Board relied on photographic records without recognizing the necessity of a formal, detailed listing as mandated by federal regulations.
EFFECT: Failure to maintain a detailed inventory listing as required by federal regulations increases the risk of mismanagement or loss of equipment and real property and could impact the Board's ability to receive future federal funding.
REPEAT FINDING: No
RECOMMENDATION: We recommend that the Board establish and maintain a detailed inventory listing for all equipment and real property acquired with federal funds. This listing should include all information required by federal regulations and should be verified through a physical inventory at least once every two years. Additionally, the Board should provide training to staff responsible for equipment and real property management to ensure compliance with federal requirements.
VIEWS OF RESPONSIBLE OFFICIALS: The Board acknowledges the finding and agrees with the recommendation.
2023-018 EQUIPMENT AND REAL PROPERTY MANAGEMENT - ESSER
Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER)
Federal Award Number and Year: 2023
Assistance Listing #: 84.425D and 84.425U
Federal Agency: US Department of Education
Pass-through Entity number: 52110 and 52160
Pass-through Agency: WV Department of Education
CONDITION: The Monroe County Board of Education (the "Board") did not follow the federal requirements for equipment and real property management under the COVID-19 American Rescue Plan ESSER program. The Board maintained photographic evidence of the inventoried items but failed to maintain a detailed listing of the equipment and real property, as required by federal regulations.
CONTEXT: During the audit period, the Board was responsible for managing equipment and real property acquired under the COVID-19 American Rescue Plan ESSER program. However, the documentation reviewed during the audit revealed that the Board had not maintained a formal inventory listing. Instead, the Board relied on photographic records and a project manual to document the existence and condition of the equipment and real property, which is not sufficient to meet the federal requirements.
CRITERIA: In accordance with 2 CFR § 200.313(d), non-Federal entities must maintain accurate records for equipment acquired with federal funds, including a detailed listing that identifies each item, its location, its condition, and other pertinent details. This listing must be updated as needed and must be verified by a physical inventory at least once every two years.
QUESTIONED COSTS: None
CAUSE: The noncompliance appears to have been by a lack of awareness or understanding of the specific federal requirements for maintaining a detailed inventory listing for equipment and real property. The Board relied on photographic records without recognizing the necessity of a formal, detailed listing as mandated by federal regulations.
EFFECT: Failure to maintain a detailed inventory listing as required by federal regulations increases the risk of mismanagement or loss of equipment and real property and could impact the Board's ability to receive future federal funding.
REPEAT FINDING: No
RECOMMENDATION: We recommend that the Board establish and maintain a detailed inventory listing for all equipment and real property acquired with federal funds. This listing should include all information required by federal regulations and should be verified through a physical inventory at least once every two years. Additionally, the Board should provide training to staff responsible for equipment and real property management to ensure compliance with federal requirements.
VIEWS OF RESPONSIBLE OFFICIALS: The Board acknowledges the finding and agrees with the recommendation.
2023-019 ALLOWABLE COSTS AND COST PRINCIPLES - ESSER
Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER)
Federal Award Number and Year: 2023
Assistance Listing #: 84.425D and 84.425U
Federal Agency: US Department of Education
Pass-through Entity number: 52110 and 52160
Pass-through Agency: WV Department of Education
CONDITION: The Monroe County Board of Education (the “Board”) did not comply with the allowable costs/cost principle related to the ESSER grant. Several expenditures to the ESSER had supporting documentation which did not agree to the costs charged to the grant.
CONTEXT: 51 non-payroll expenditures were sampled from a population of 134 for ESSER, of which:
Three expenditures, or 6% of the sample size, did not agree with the charges recorded to the grant.
CRITERIA: According to Title 2 CFR Part 200.403(g), Uniform Guidance, for costs to be allowable under federal awards, they must be adequately documented, and must align with the purposes of the grant. The Board is required to maintain accurate and complete records to support that expenditures are reasonable, necessary, and allocable to the grant.
QUESTIONED COSTS: None. Actual and likely questioned costs are below $25,000 and program materiality.
CAUSE: The noncompliance occurred due to insufficient review processes and oversight of expenditures charged to the grant. The Board’s current internal controls were not effective in ensuring that all costs met the allowable costs/cost principles criteria.
EFFECT: Although the actual and likely costs are below $25,000 and do not exceed program materiality, charging costs to the program that do not agree with supporting documentation may result in the disallowance of the questioned costs by the federal grantor agency. This could lead to financial liabilities for the Board and potentially jeopardize future federal funding.
REPEAT FINDING: No
RECOMMENDATION: We recommend that the Board strengthen its internal controls over the review and approval of expenditures charged to federal grants. This should include ensuring that all expenditures are adequately documented and that they align with the purposes of the grant. Training should be provided to relevant staff on the requirements of Title 2 CFR Part 200.403 to prevent future occurrences of this finding.
VIEWS OF RESPONSIBLE OFFICIALS: The Board acknowledges the finding and agrees with the recommendation and is committed to improving its internal controls to ensure compliance with federal regulations.
2023-021 ACTIVITIES ALLOWED/UNALLOWED - ESSER
Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER)
Federal Award Number and Year: 2023
Assistance Listing #: 84.425U
Federal Agency: US Department of Education
Pass-through Entity number: 52160
Pass-through Agency: WV Department of Education
CONDITION: The Monroe County Board of Education (the “Board”) did not comply with the activities allowed/unallowed requirement. We noted a charge to the ESSER grant that is an unallowed activity.
CONTEXT: 51 non-payroll expenditures were sampled from a population of 134 for the ESSER grant, of which:
● One expenditure, or 2% of the sample size, were for admission to a “Minions” movie totaling $585.00.
CRITERIA: Per the 2023 Compliance Supplement and the Uniform Guidance (2 CFR Part 200), all expenditures charged to the ESSER program must be necessary, reasonable, and allocable to the program's purpose. Costs such as entertainment, including admission to movies, are generally unallowable unless they meet specific educational purposes aligned with the program’s objectives.
QUESTIONED COSTS: None. Actual and likely questioned costs are below $25,000 and program materiality.
CAUSE: The noncompliance occurred due to a lack of understanding or misinterpretation of the ESSER program's allowable activities. The Board may have believed the expenditure aligned with the program's objectives of supporting students, but it did not meet the strict requirements set forth by federal regulations.
EFFECT: Although the actual and likely costs are below $25,000 and do not exceed program materiality, the identified items increases the risk of unallowable activities being charged to federal programs. This finding could result in the need to return federal funds, negatively impacting the Board's financial resources and its ability to effectively manage the ESSER program.
REPEAT FINDING: No
RECOMMENDATION: We recommend that the Board enhance its review and approval process for expenditures charged to the ESSER program. This should include additional training for staff involved in the approval of such expenditures, ensuring that all charges are necessary, reasonable, and directly related to the program’s objectives. The Board should also review and potentially seek reimbursement of the questioned costs identified in this finding.
VIEWS OF RESPONSIBLE OFFICIALS: The Board acknowledges the finding and agrees that the expenditure in question was not in compliance with the ESSER program's allowable activites.