Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Cash Management and Allowable Costs/Cost Principles). Program. U.S. Department of Education; Education Innovation and Research, Supporting Preschool and Kindergarten Students; ALN 84.411C; Award Number U411C160089. Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. There are no written policies in place covering payments, allowability of costs charged to federal programs, compensation, or travel costs. Cause. This condition appears to have been caused by a lack of knowledge of applicable federal compliance requirements. Effect. As a result of this condition, the Organization did not fully comply with the Uniform Guidance. Questioned Costs. No costs are required to be questioned as a result of this finding. Recommendation. We recommend that written policies be put in place for all required processes to comply with requirements. View of Responsible Officials. Policies have been created around federal programs regarding (1) payments, (2) allowability of costs charged to federal programs, (3) compensation, and (4) travel costs and will be implemented for all future federal grants.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. U.S. Department of Education; Education Innovation and Research, Supporting Preschool and Kindergarten Students; ALN 84.411C; Award Number U411C160089. Criteria. The Uniform Guidance requires the Organization to support payroll charged to federal grants with adequate documentation in accordance with the Organization's payroll policies. Condition. In four instances out of a sample of twelve transactions, wages charged to the grant were in excess of the actual wages. In addition, there was no evidence of review and approval for any of the twelve transactions tested. Cause. This condition appears to have been caused by manual error and a lack of proper review which may have detected the errors. Effect. As a result of this condition, the Organization over charged wages to the federal grant. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as the actual and projected error was de minimus. Recommendation. We recommend that a supervisory review be performed and documented for payroll calculations to ensure payroll expenses charged to the federal grant are allowable and supported by appropriate documentation. View of Responsible Officials. In the policy for federal grants, it addresses the review of all expenses to ensure incorrect calculations do not happen. This includes a detailed supervisory review of payroll reports.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. U.S. Department of Education; Education Innovation and Research, Supporting Preschool and Kindergarten Students; ALN 84.411C; Award Number U411C160089. Criteria. A recipient of federal awards is required to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the federal government. Such procedures are required whenever the amount disbursed to a single vendor in a given fiscal year is expected to be at least $25,000. Condition. There is no procedure in place to determine whether vendors are suspended or debarred. Cause. This condition appears to have been caused by a lack of knowledge of applicable federal compliance requirements. Effect. As a result of this condition, the Organization was exposed to an increased risk that disbursements of federal awards could be made to vendors suspended or debarred by the federal government. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors involved were actually suspended or debarred. Recommendation. We recommend that all employees administering federal grants and having primary responsibility for compliance with grant requirements be provided the necessary training and supervision to be able to identify and comply with such requirements. View of Responsible Officials. A policy around federal programs has been created and will be implemented for all future federal grants, which includes reviewing vendors for suspension and debarment.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Cash Management). Program. U.S. Department of Education; Education Innovation and Research, Supporting Preschool and Kindergarten Students; ALN 84.411C; Award Number U411C160089. Criteria. Grantees are required to minimize the time elapsing between the transfer of funds from the grantor (U.S. Department of Education) and disbursement by the grantee. Grant expenses are only reimbursed to the extent incurred. Condition. Throughout the period of the grant, the Organization requested drawdowns of federal funds from the grantor in excess of their immediate needs and in excess of grant expenses incurred. Cause. The Organization, in error, throughout the period of the grant, requested federal drawdowns in advance of when funds were needed and for expenses not incurred. In addition, there was no evidence that the drawdown requests were reviewed and approved. Effect. The Organization received federal funds in excess of their immediate needs and in excess of the total amount expended. Upon discovering this error, and after consulting with the U.S. Department of Education, the Organization returned $154,615 to the grantor on November 4, 2022 and $75,167 on March 20, 2023. Questioned Costs. No costs have been questioned as all amounts have been refunded to the U.S. Department of Education. Recommendation. Written policies and related internal controls need to be designed and implemented in order to properly account for federal expenditures and to minimize the time between receipt and disbursement of federal funds. All drawdown requests should have evidence of review and approval. View of Responsible Officials. A policy around federal programs has been created and will be implemented for all future federal grants, which includes cash management to ensure funds drawn down are not in excess of need and amount expended.
Finding Type. Material Noncompliance/Material Weakness in Internal Control over Compliance (Reporting). Program. U.S. Department of Education; Education Innovation and Research, Supporting Preschool and Kindergarten Students; ALN 84.411C; Award Number U411C160089. Criteria. Recipients use the Federal Financial Report (FFR) to report expenditures and other financial information for federal awards. Such reports must be complete and accurate. Condition. We reviewed the final FFR, which was not complete and accurate. Required information missing from the FFR included cash receipt, cash disbursement, and expenditure data. Cause. The Organization does not appear to understand the reporting requirements. In addition, there was no evidence that the report was reviewed and approved. Effect. The Organization reported incorrect financial information to the grantor. Questioned Costs. No costs are required to be reported as a result of this finding. Recommendation. We recommend that all employees administering federal grants and having primary responsibility for compliance with grant requirements be provided the necessary training to be able to identify and comply with such requirements. All reports should have evidence of review and approval. View of Responsible Officials. A policy around federal programs has been created and will be implemented for all future federal grants, which includes the need for all parties who are involved in the administration to have federal funds training as well as comply with the policy. A position has been added to the organization to oversee all grants to ensure future compliance.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Cash Management and Allowable Costs/Cost Principles). Program. U.S. Department of Education; Education Innovation and Research, Supporting Preschool and Kindergarten Students; ALN 84.411C; Award Number U411C160089. Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. There are no written policies in place covering payments, allowability of costs charged to federal programs, compensation, or travel costs. Cause. This condition appears to have been caused by a lack of knowledge of applicable federal compliance requirements. Effect. As a result of this condition, the Organization did not fully comply with the Uniform Guidance. Questioned Costs. No costs are required to be questioned as a result of this finding. Recommendation. We recommend that written policies be put in place for all required processes to comply with requirements. View of Responsible Officials. Policies have been created around federal programs regarding (1) payments, (2) allowability of costs charged to federal programs, (3) compensation, and (4) travel costs and will be implemented for all future federal grants.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles). Program. U.S. Department of Education; Education Innovation and Research, Supporting Preschool and Kindergarten Students; ALN 84.411C; Award Number U411C160089. Criteria. The Uniform Guidance requires the Organization to support payroll charged to federal grants with adequate documentation in accordance with the Organization's payroll policies. Condition. In four instances out of a sample of twelve transactions, wages charged to the grant were in excess of the actual wages. In addition, there was no evidence of review and approval for any of the twelve transactions tested. Cause. This condition appears to have been caused by manual error and a lack of proper review which may have detected the errors. Effect. As a result of this condition, the Organization over charged wages to the federal grant. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as the actual and projected error was de minimus. Recommendation. We recommend that a supervisory review be performed and documented for payroll calculations to ensure payroll expenses charged to the federal grant are allowable and supported by appropriate documentation. View of Responsible Officials. In the policy for federal grants, it addresses the review of all expenses to ensure incorrect calculations do not happen. This includes a detailed supervisory review of payroll reports.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. U.S. Department of Education; Education Innovation and Research, Supporting Preschool and Kindergarten Students; ALN 84.411C; Award Number U411C160089. Criteria. A recipient of federal awards is required to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the federal government. Such procedures are required whenever the amount disbursed to a single vendor in a given fiscal year is expected to be at least $25,000. Condition. There is no procedure in place to determine whether vendors are suspended or debarred. Cause. This condition appears to have been caused by a lack of knowledge of applicable federal compliance requirements. Effect. As a result of this condition, the Organization was exposed to an increased risk that disbursements of federal awards could be made to vendors suspended or debarred by the federal government. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as none of the vendors involved were actually suspended or debarred. Recommendation. We recommend that all employees administering federal grants and having primary responsibility for compliance with grant requirements be provided the necessary training and supervision to be able to identify and comply with such requirements. View of Responsible Officials. A policy around federal programs has been created and will be implemented for all future federal grants, which includes reviewing vendors for suspension and debarment.
Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Control over Compliance (Cash Management). Program. U.S. Department of Education; Education Innovation and Research, Supporting Preschool and Kindergarten Students; ALN 84.411C; Award Number U411C160089. Criteria. Grantees are required to minimize the time elapsing between the transfer of funds from the grantor (U.S. Department of Education) and disbursement by the grantee. Grant expenses are only reimbursed to the extent incurred. Condition. Throughout the period of the grant, the Organization requested drawdowns of federal funds from the grantor in excess of their immediate needs and in excess of grant expenses incurred. Cause. The Organization, in error, throughout the period of the grant, requested federal drawdowns in advance of when funds were needed and for expenses not incurred. In addition, there was no evidence that the drawdown requests were reviewed and approved. Effect. The Organization received federal funds in excess of their immediate needs and in excess of the total amount expended. Upon discovering this error, and after consulting with the U.S. Department of Education, the Organization returned $154,615 to the grantor on November 4, 2022 and $75,167 on March 20, 2023. Questioned Costs. No costs have been questioned as all amounts have been refunded to the U.S. Department of Education. Recommendation. Written policies and related internal controls need to be designed and implemented in order to properly account for federal expenditures and to minimize the time between receipt and disbursement of federal funds. All drawdown requests should have evidence of review and approval. View of Responsible Officials. A policy around federal programs has been created and will be implemented for all future federal grants, which includes cash management to ensure funds drawn down are not in excess of need and amount expended.
Finding Type. Material Noncompliance/Material Weakness in Internal Control over Compliance (Reporting). Program. U.S. Department of Education; Education Innovation and Research, Supporting Preschool and Kindergarten Students; ALN 84.411C; Award Number U411C160089. Criteria. Recipients use the Federal Financial Report (FFR) to report expenditures and other financial information for federal awards. Such reports must be complete and accurate. Condition. We reviewed the final FFR, which was not complete and accurate. Required information missing from the FFR included cash receipt, cash disbursement, and expenditure data. Cause. The Organization does not appear to understand the reporting requirements. In addition, there was no evidence that the report was reviewed and approved. Effect. The Organization reported incorrect financial information to the grantor. Questioned Costs. No costs are required to be reported as a result of this finding. Recommendation. We recommend that all employees administering federal grants and having primary responsibility for compliance with grant requirements be provided the necessary training to be able to identify and comply with such requirements. All reports should have evidence of review and approval. View of Responsible Officials. A policy around federal programs has been created and will be implemented for all future federal grants, which includes the need for all parties who are involved in the administration to have federal funds training as well as comply with the policy. A position has been added to the organization to oversee all grants to ensure future compliance.