Audit 33665

FY End
2022-06-30
Total Expended
$11.37M
Findings
4
Programs
19
Year: 2022 Accepted: 2023-05-04

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
33340 2022-002 Material Weakness - N
33341 2022-002 Material Weakness - N
609782 2022-002 Material Weakness - N
609783 2022-002 Material Weakness - N

Contacts

Name Title Type
MLA1SCM2JK66 Diana Whitt Auditee
2162686587 Douglas Chamot Auditor
No contacts on file

Notes to SEFA

Title: NOTE A BASIS OF PRESENTATION Accounting Policies: Expenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. 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 award activity of the East Cleveland City School District (the Districts) under programs of the federal government for the year ended June 30, 2022. The information on this Schedule is prepared in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the District, it is not intended to and does not present the financial position, changes in net position, or cash flows of the District.
Title: NOTE D - CHILD NUTRITION CLUSTER Accounting Policies: Expenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The District commingles cash receipts from the U.S. Department of Agriculture with similar State grants. When reporting expenditures on this Schedule, the District assumes it expends federal monies first.
Title: NOTE E FOOD DONATION PROGRAM Accounting Policies: Expenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The District reports commodities consumed on the Schedule at the fair value. The District allocated donated food commodities to the respective programs that benefitted from the use of those donated food commodities.
Title: NOTE F - MATCHING REQUIREMENTS Accounting Policies: Expenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Certain Federal programs require the District to contribute non-Federal funds (matching funds) to support the Federally-funded programs. The District has met its matching requirements. The Schedule does not include the expenditure of non-Federal matching funds.
Title: NOTE G - TRANSFERS BETWEEN PROGRAM YEARS Accounting Policies: Expenditures reported on the Schedule are reported on the cash basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Federal regulations require schools to obligate certain federal awards by June 30. However, with ODEs consent, schools can transfer unobligated amounts to the subsequent fiscal years program. The District transferred the following amounts from 2022 to 2023 programs: Amt.Program Title AL Number TransferredTitle I Grants to Local Educational Agencies84.010$ 680,455Title I Expanding Opportunities for Every Child Grant 84.010 37,908Title I, Supplementary School Improvement84.01020,764Special Education Grants to States84.027 280,831Title II, Part A, Supporting Effective Instruction State Grants 84.367 130,645Student Support and Academic Enrichment Program 84.424 148,339

Finding Details

2 CFR ? 3474.1 provides that the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE. Appendix II to 2 CFR part 200, Paragraph D states that all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following: (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, ?Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction?). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. The District entered into a contract with SCG Fields LLC for upgrades to their Stadium. During fiscal year 2022, the District paid SCG Fields $1,290,226 with Elementary and Secondary School Emergency Relief (ESSER II) Fund (Assistance Listing #84.425A) monies. These expenditures included contractor labor charges for periods prior to June 30, 2022. However, due to the lack of formal controls and procedures, the District did not obtain the required weekly certified payroll information for this contractor. This weakness resulted in the District being non-compliant with the aforementioned federal codes and could result in future reductions or loss of federal funding. The District should ensure certified payroll reports are provided weekly by contractors. The District should obtain the necessary information from contractors to document compliance with program requirements and, if contractors fail to comply, the District has an obligation under Appendix II to 2 CFR part 200 to report all suspected or reported violations to the Federal awarding agency.
2 CFR ? 3474.1 provides that the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE. Appendix II to 2 CFR part 200, Paragraph D states that all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following: (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, ?Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction?). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. The District entered into a contract with SCG Fields LLC for upgrades to their Stadium. During fiscal year 2022, the District paid SCG Fields $1,290,226 with Elementary and Secondary School Emergency Relief (ESSER II) Fund (Assistance Listing #84.425A) monies. These expenditures included contractor labor charges for periods prior to June 30, 2022. However, due to the lack of formal controls and procedures, the District did not obtain the required weekly certified payroll information for this contractor. This weakness resulted in the District being non-compliant with the aforementioned federal codes and could result in future reductions or loss of federal funding. The District should ensure certified payroll reports are provided weekly by contractors. The District should obtain the necessary information from contractors to document compliance with program requirements and, if contractors fail to comply, the District has an obligation under Appendix II to 2 CFR part 200 to report all suspected or reported violations to the Federal awarding agency.
2 CFR ? 3474.1 provides that the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE. Appendix II to 2 CFR part 200, Paragraph D states that all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following: (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, ?Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction?). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. The District entered into a contract with SCG Fields LLC for upgrades to their Stadium. During fiscal year 2022, the District paid SCG Fields $1,290,226 with Elementary and Secondary School Emergency Relief (ESSER II) Fund (Assistance Listing #84.425A) monies. These expenditures included contractor labor charges for periods prior to June 30, 2022. However, due to the lack of formal controls and procedures, the District did not obtain the required weekly certified payroll information for this contractor. This weakness resulted in the District being non-compliant with the aforementioned federal codes and could result in future reductions or loss of federal funding. The District should ensure certified payroll reports are provided weekly by contractors. The District should obtain the necessary information from contractors to document compliance with program requirements and, if contractors fail to comply, the District has an obligation under Appendix II to 2 CFR part 200 to report all suspected or reported violations to the Federal awarding agency.
2 CFR ? 3474.1 provides that the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE. Appendix II to 2 CFR part 200, Paragraph D states that all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following: (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, ?Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction?). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. The District entered into a contract with SCG Fields LLC for upgrades to their Stadium. During fiscal year 2022, the District paid SCG Fields $1,290,226 with Elementary and Secondary School Emergency Relief (ESSER II) Fund (Assistance Listing #84.425A) monies. These expenditures included contractor labor charges for periods prior to June 30, 2022. However, due to the lack of formal controls and procedures, the District did not obtain the required weekly certified payroll information for this contractor. This weakness resulted in the District being non-compliant with the aforementioned federal codes and could result in future reductions or loss of federal funding. The District should ensure certified payroll reports are provided weekly by contractors. The District should obtain the necessary information from contractors to document compliance with program requirements and, if contractors fail to comply, the District has an obligation under Appendix II to 2 CFR part 200 to report all suspected or reported violations to the Federal awarding agency.