FAC Explorer

Audit 325582

FY End
2023-06-30
Total Expended
$1.12M
Findings
2
Programs
2
Organization: Corporacion Educativa Ramon Barquin Dba American Military Academy (PR)
Year: 2023 Accepted: 2024-10-23
Auditor: J&j CPA LLC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
503464 2023-001 Significant Deficiency - I
1079906 2023-001 Significant Deficiency - I

Programs

ALN Program Spent Major Findings
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $875,282 Yes 1
84.425 Education Stabilization Fund $245,690 - 0

Contacts

Name Title Type
RP7JHAKMNP87 Juan Carlos Consuegra Auditee
7872328035 Josue Cabrera Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Corporación Educativa Ramón Barquín d/b/a American Military Academy’s has elected not to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: N/A The Schedule of Expenditures of Federal Awards (the "Schedule") is presented on the accrual basis of accounting, and its purpose is to present, in summary form, the student financial assistance, training and other activities of Corporación Educativa Ramón Barquín d/b/a American Military Academy for the year ended June 30, 2023, which have been financed by federal agencies. Catalog of Federal Domestic Assistance ("CFDA") numbers are presented for those programs for which such numbers are available. Federal programs are presented, as appropriate, by Federal Department.
Title: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Corporación Educativa Ramón Barquín d/b/a American Military Academy’s has elected not to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: N/A Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Corporación Educativa Ramón Barquín d/b/a American Military Academy’s has elected not to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance.
Title: MAJOR FEDERAL AWARDS Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Corporación Educativa Ramón Barquín d/b/a American Military Academy’s has elected not to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: N/A The Disaster Grants – Public Assistance Program – (Presidentially Declared Disasters), is the only major program of the Academy for the year ended June 30, 2023.
Title: CATALOG OF FEDERAL DOMESTIC ASSISTANCE (CFDA) NUMBER Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Corporación Educativa Ramón Barquín d/b/a American Military Academy’s has elected not to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: N/A The CFDA Numbers included in this schedule were determined based on the Catalog of Federal Domestic Assistance Agency Program Index.
Title: SUBRECIPIENTS Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Corporación Educativa Ramón Barquín d/b/a American Military Academy’s has elected not to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: N/A The Project did not provide awards to any subrecipients

Finding Details

Finding 2023-001
Criteria: According to 2 CFR § 200.318, entities must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts. These standards must ensure that no employee, officer, or agent has a conflict of interest, real or apparent, in the procurement process. Condition: During our audit, we noted that Corporación Educativa Ramón Barquín d/b/a American Military Academy has an established conflict of interest policy which is enforced as stated, yet it does not have all the requirements established by 2 CFR § 200.318. The existing policy lacks the procedures for evaluation and management of conflicts, mitigation strategies, enforcement mechanisms, training and communication provision, and procedures for regular review and update. Cause: The absence of these elements in the conflict-of-interest policy appears to be due to the Academy’s commencing to work with federal funds as the Conflict of Interest Policy was updated for 2024 and now contains all the elements required. Effect: Without a compliant conflict of interest policy, there is an increased risk that procurement decisions may be influenced by undisclosed conflicts of interest, which could lead to non-compliance with federal regulations and potentially impair fair and open competition. Questioned costs: -0- Since during our procurement test no actual conflict of interest was identified and during our interviews employees were aware of a policy being in place, even if for audit purposes it did not contain all the elements required. Recommendation: We recommend that Corporación Educativa Ramón Barquín d/b/a American Military Academy revise its conflict-of-interest policy to include all elements required by 2 CFR § 200.318. Specifically, the policy should the procedures for evaluation and management of conflicts, mitigation strategies, enforcement mechanisms, training and communication provision, and procedures for regular review and update. Additionally, we recommend training for all employees involved in procurement activities on the revised policy to ensure understanding and compliance. Views of Responsible Officials and Planned Corrective Actions: Corporación Educativa Ramón Barquín d/b/a American Military Academy agrees with the finding. See Corrective Action plan for the Academy’s Comments and plan.
Finding 2023-001
Criteria: According to 2 CFR § 200.318, entities must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award, and administration of contracts. These standards must ensure that no employee, officer, or agent has a conflict of interest, real or apparent, in the procurement process. Condition: During our audit, we noted that Corporación Educativa Ramón Barquín d/b/a American Military Academy has an established conflict of interest policy which is enforced as stated, yet it does not have all the requirements established by 2 CFR § 200.318. The existing policy lacks the procedures for evaluation and management of conflicts, mitigation strategies, enforcement mechanisms, training and communication provision, and procedures for regular review and update. Cause: The absence of these elements in the conflict-of-interest policy appears to be due to the Academy’s commencing to work with federal funds as the Conflict of Interest Policy was updated for 2024 and now contains all the elements required. Effect: Without a compliant conflict of interest policy, there is an increased risk that procurement decisions may be influenced by undisclosed conflicts of interest, which could lead to non-compliance with federal regulations and potentially impair fair and open competition. Questioned costs: -0- Since during our procurement test no actual conflict of interest was identified and during our interviews employees were aware of a policy being in place, even if for audit purposes it did not contain all the elements required. Recommendation: We recommend that Corporación Educativa Ramón Barquín d/b/a American Military Academy revise its conflict-of-interest policy to include all elements required by 2 CFR § 200.318. Specifically, the policy should the procedures for evaluation and management of conflicts, mitigation strategies, enforcement mechanisms, training and communication provision, and procedures for regular review and update. Additionally, we recommend training for all employees involved in procurement activities on the revised policy to ensure understanding and compliance. Views of Responsible Officials and Planned Corrective Actions: Corporación Educativa Ramón Barquín d/b/a American Military Academy agrees with the finding. See Corrective Action plan for the Academy’s Comments and plan.