Assistance Listing, Federal Agency, and Program Name - 93.600 Head Start
Federal Award Identification Number and Year - 238600, 248600
Pass through Entity - U.S. Department of Health and Human Services
Finding Type - Material weakness
Repeat Finding - No
Criteria - Under 34 CFR Section 299.2(b), the School District has to ensure that funds are used in compliance with regulatory provisions and spent only for reasonable and necessary costs of the program. The School District is required to have supporting documentation and approval of grant expenditures to ensure they are an allowable and supported cost under the grant requirements.
Condition - During allowability testing it was discovered the District has no formalized reviewed of expenditures charged to grant. This included expenditures related to payroll, nonpayroll and indirect costs.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Audit procedures designated testing 60 samples (payroll, nonpayroll) and there was no formalized review documented before they were charged to the grant and reimbursement was requested throughout the entire population tested.
Cause and Effect - Lack of controls and review surrounding expenditures charged to the grant could lead to improper expenditures being charged and noncompliance.
Recommendation - It is recommend that the District review its controls and processes in place to ensure that they are have proper controls in place over to review expenditures being charged to the grant to ensure they are allowable.
Views of Responsible Officials and Corrective Action Plan - This finding was due to the District having turnover among key personnel in the grants area, as well as non adherence to policies and procedures related to grant records, grant accounting, and year end close processes. The District will perform periodic grant reconciliations throughout the fiscal year to ensure that grant records tie to the general ledger. The District will also ensure policies and procedures are updated, staff is trained, and documented evidence of appropriate and allowable expenditures is maintained.
Assistance Listing, Federal Agency, and Program Name - 93.600 Head Start
Federal Award Identification Number and Year - 238600, 248600
Pass through Entity - U.S. Department of Health and Human Services
Finding Type - Material weakness
Repeat Finding - No
Criteria - The School District must submit the form SF 425 three times annually. They must submit a semi annual, annual and final report. Several reports were not filed timely. Additionally, there is no secondary review over reports before they are submitted.
The SF 429 which is required to be submitted annually and there is no secondary review over this report before submission.
Condition - Throughout the year, there was no control in place to ensure required reports were filed timely and in accordance with the grant agreement. The School District does not currently have a control in place where a review of inputs of the SF 425 and SF 429 reports could result in inaccurate reporting.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - It was noted that the School District filed their SF 425 late during the year and had no review over the SF 425 and SF 429 required reports.
Cause and Effect - The absence of a secondary review or timely filing of required reports could cause errors to occur in reporting or funding being adjusted due to noncompliance with the grant agreement and federal guidance.
Recommendation - The School District should implement a control where reports are reviewed, and approval is documented to ensure the submission is mechanically accurate and agrees to financial information and general ledger detail. In addition, the District should create a checklist to ensure they are filing their reports timely.
Views of Responsible Officials and Planned Corrective Actions - This finding was due to the District having turnover among key personnel in the grants area, as well as non adherence to policies and procedures related to grant records, grant accounting, and year end close processes. The District has developed policies and procedures specific to the Head Start program and has implemented a grant calendar to ensure that reporting deadlines are not missed going forward.
Assistance Listing, Federal Agency, and Program Name - 21.027 - COVID - 19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - SLFRP0126
Pass through Entity - U.S. Department of Treasury
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - 2 CFR 200.320 and 200.324 outlines the auditee responsibility to utilize the appropriate procurement method and comply with all related requirements of that selected procurement methodology. Also, 2 CFR 180.300 outlines the auditee responsibility related to suspension and debarment requirements for vendors with whom an entity contracts.
Condition - The School District did not have sufficient controls in place to ensure compliance with its procurement policy and that appropriate documentation is retained regarding the procurement methodology chosen and support for compliance with the suspension and debarment requirements.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the sample of 2 contracts procured this year that we selected for testing, 2 did not have the required support for the procurement method selected based on federal guidelines and the School District's procurement policy. Additionally, the 2 contracts selected for suspension and debarment testing did not have any documentation as it related to suspension and debarment.
Cause and Effect - The School District did not retain support to show it obtained price quotes, as required by the small purchases provision; had the appropriate rationale, as required by the noncompetitive solicitation provision; or had support for proposals submitted, as required by the purchases over $250,000 provision. Support was not retained for 2 of the 2 samples selected during procurement testing; therefore, procurement methodology was not supported. Additionally, none of the 2 samples selected for suspension and debarment testing had the required support retained.
Recommendation - We recommend the School District implement internal control procedures to ensure that procurement policy is followed and the proper documentation is kept in the procurement files to support any and all procurement decisions in accordance with the purchasing policy and federal regulations.
Views of Responsible Officials and Planned Corrective Actions - This finding was due to the District having turnover among key personnel in the grants area, as well as non adherence to policies and procedures related to grant records, grant accounting, and year end close processes. The District will work with the Materials and Procurement department to ensure policies and procedures are updated and staff is trained. Prior to awarding any contract, District staff will search the federal Excluded Parties List System to determine that the contractor is not suspended or debarred. Documentation of this search will be maintained in the grant procurement file.
Assistance Listing, Federal Agency, and Program Name - 93.600 Head Start
Federal Award Identification Number and Year - 238600, 248600
Pass through Entity - U.S. Department of Health and Human Services
Finding Type - Material weakness
Repeat Finding - No
Criteria - Under 34 CFR Section 299.2(b), the School District has to ensure that funds are used in compliance with regulatory provisions and spent only for reasonable and necessary costs of the program. The School District is required to have supporting documentation and approval of grant expenditures to ensure they are an allowable and supported cost under the grant requirements.
Condition - During allowability testing it was discovered the District has no formalized reviewed of expenditures charged to grant. This included expenditures related to payroll, nonpayroll and indirect costs.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Audit procedures designated testing 60 samples (payroll, nonpayroll) and there was no formalized review documented before they were charged to the grant and reimbursement was requested throughout the entire population tested.
Cause and Effect - Lack of controls and review surrounding expenditures charged to the grant could lead to improper expenditures being charged and noncompliance.
Recommendation - It is recommend that the District review its controls and processes in place to ensure that they are have proper controls in place over to review expenditures being charged to the grant to ensure they are allowable.
Views of Responsible Officials and Corrective Action Plan - This finding was due to the District having turnover among key personnel in the grants area, as well as non adherence to policies and procedures related to grant records, grant accounting, and year end close processes. The District will perform periodic grant reconciliations throughout the fiscal year to ensure that grant records tie to the general ledger. The District will also ensure policies and procedures are updated, staff is trained, and documented evidence of appropriate and allowable expenditures is maintained.
Assistance Listing, Federal Agency, and Program Name - 93.600 Head Start
Federal Award Identification Number and Year - 238600, 248600
Pass through Entity - U.S. Department of Health and Human Services
Finding Type - Material weakness
Repeat Finding - No
Criteria - The School District must submit the form SF 425 three times annually. They must submit a semi annual, annual and final report. Several reports were not filed timely. Additionally, there is no secondary review over reports before they are submitted.
The SF 429 which is required to be submitted annually and there is no secondary review over this report before submission.
Condition - Throughout the year, there was no control in place to ensure required reports were filed timely and in accordance with the grant agreement. The School District does not currently have a control in place where a review of inputs of the SF 425 and SF 429 reports could result in inaccurate reporting.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - It was noted that the School District filed their SF 425 late during the year and had no review over the SF 425 and SF 429 required reports.
Cause and Effect - The absence of a secondary review or timely filing of required reports could cause errors to occur in reporting or funding being adjusted due to noncompliance with the grant agreement and federal guidance.
Recommendation - The School District should implement a control where reports are reviewed, and approval is documented to ensure the submission is mechanically accurate and agrees to financial information and general ledger detail. In addition, the District should create a checklist to ensure they are filing their reports timely.
Views of Responsible Officials and Planned Corrective Actions - This finding was due to the District having turnover among key personnel in the grants area, as well as non adherence to policies and procedures related to grant records, grant accounting, and year end close processes. The District has developed policies and procedures specific to the Head Start program and has implemented a grant calendar to ensure that reporting deadlines are not missed going forward.
Assistance Listing, Federal Agency, and Program Name - 21.027 - COVID - 19 Coronavirus State and Local Fiscal Recovery Funds
Federal Award Identification Number and Year - SLFRP0126
Pass through Entity - U.S. Department of Treasury
Finding Type - Material weakness and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - 2 CFR 200.320 and 200.324 outlines the auditee responsibility to utilize the appropriate procurement method and comply with all related requirements of that selected procurement methodology. Also, 2 CFR 180.300 outlines the auditee responsibility related to suspension and debarment requirements for vendors with whom an entity contracts.
Condition - The School District did not have sufficient controls in place to ensure compliance with its procurement policy and that appropriate documentation is retained regarding the procurement methodology chosen and support for compliance with the suspension and debarment requirements.
Questioned Costs - None
Identification of How Questioned Costs Were Computed - N/A
Context - Of the sample of 2 contracts procured this year that we selected for testing, 2 did not have the required support for the procurement method selected based on federal guidelines and the School District's procurement policy. Additionally, the 2 contracts selected for suspension and debarment testing did not have any documentation as it related to suspension and debarment.
Cause and Effect - The School District did not retain support to show it obtained price quotes, as required by the small purchases provision; had the appropriate rationale, as required by the noncompetitive solicitation provision; or had support for proposals submitted, as required by the purchases over $250,000 provision. Support was not retained for 2 of the 2 samples selected during procurement testing; therefore, procurement methodology was not supported. Additionally, none of the 2 samples selected for suspension and debarment testing had the required support retained.
Recommendation - We recommend the School District implement internal control procedures to ensure that procurement policy is followed and the proper documentation is kept in the procurement files to support any and all procurement decisions in accordance with the purchasing policy and federal regulations.
Views of Responsible Officials and Planned Corrective Actions - This finding was due to the District having turnover among key personnel in the grants area, as well as non adherence to policies and procedures related to grant records, grant accounting, and year end close processes. The District will work with the Materials and Procurement department to ensure policies and procedures are updated and staff is trained. Prior to awarding any contract, District staff will search the federal Excluded Parties List System to determine that the contractor is not suspended or debarred. Documentation of this search will be maintained in the grant procurement file.