7 CFR § 210.8(a) states, "The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems."
7 CFR § 220.11(b) states in part, claims for reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the State Agency to provide the Reports of School Program Operations required under § 220.13(b)(2).
In Ohio, the Ohio Department of Education and Workforce (DEW) requires school districts to use the Claims Reporting and Reimbursement System (CRRS) to report meal data for reimbursement. The District uses a point-of-sale system that generates a CN-6 Report (Breakfast) and CN-7 Report (Lunch), which is used to compile the monthly reimbursement request submitted to DEW.
Due to insufficient controls over CN-6 and CN-7 reporting. related to breakfast and lunch meal counts, six of the 60 (10%) CN reports tested were inaccurate. This led to inaccuracies in meal counts reported in the CRRS system.
This weakness resulted in a loss of accountability over meal count reporting and could lead to a reduction or forfeiture of future funding for this program.
The District should develop control policies and procedures to ensure the number of meals served and reported to DEW agree to the respective daily meal count forms and the meals served / tabulated on the point-of-sale system CN-6 and CN-7 Reports. The procedures should include an independent review of the meal counts manually entered into the point-of-sale system, based upon the daily meal count forms, and the meal counts manually entered into CRRS, based upon the point-of-sale system CN-6 and CN-7 reports, by an employee not associated with the computer entry. These review procedures should be acknowledged by initials / signatures on the point-of-sale system reports and the CRRS Site Claim Reports. If there are errors or discrepancies between the point-of-sale reports and the amounts reported to DEW, the District should maintain supporting documentation to demonstrate the meals reported to DEW were accurate and complete.
7 CFR § 210.8(a) states, "The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems."
7 CFR § 220.11(b) states in part, claims for reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the State Agency to provide the Reports of School Program Operations required under § 220.13(b)(2).
In Ohio, the Ohio Department of Education and Workforce (DEW) requires school districts to use the Claims Reporting and Reimbursement System (CRRS) to report meal data for reimbursement. The District uses a point-of-sale system that generates a CN-6 Report (Breakfast) and CN-7 Report (Lunch), which is used to compile the monthly reimbursement request submitted to DEW.
Due to insufficient controls over CN-6 and CN-7 reporting. related to breakfast and lunch meal counts, six of the 60 (10%) CN reports tested were inaccurate. This led to inaccuracies in meal counts reported in the CRRS system.
This weakness resulted in a loss of accountability over meal count reporting and could lead to a reduction or forfeiture of future funding for this program.
The District should develop control policies and procedures to ensure the number of meals served and reported to DEW agree to the respective daily meal count forms and the meals served / tabulated on the point-of-sale system CN-6 and CN-7 Reports. The procedures should include an independent review of the meal counts manually entered into the point-of-sale system, based upon the daily meal count forms, and the meal counts manually entered into CRRS, based upon the point-of-sale system CN-6 and CN-7 reports, by an employee not associated with the computer entry. These review procedures should be acknowledged by initials / signatures on the point-of-sale system reports and the CRRS Site Claim Reports. If there are errors or discrepancies between the point-of-sale reports and the amounts reported to DEW, the District should maintain supporting documentation to demonstrate the meals reported to DEW were accurate and complete.
7 CFR § 210.8(a) states, "The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems."
7 CFR § 220.11(b) states in part, claims for reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the State Agency to provide the Reports of School Program Operations required under § 220.13(b)(2).
In Ohio, the Ohio Department of Education and Workforce (DEW) requires school districts to use the Claims Reporting and Reimbursement System (CRRS) to report meal data for reimbursement. The District uses a point-of-sale system that generates a CN-6 Report (Breakfast) and CN-7 Report (Lunch), which is used to compile the monthly reimbursement request submitted to DEW.
Due to insufficient controls over CN-6 and CN-7 reporting. related to breakfast and lunch meal counts, six of the 60 (10%) CN reports tested were inaccurate. This led to inaccuracies in meal counts reported in the CRRS system.
This weakness resulted in a loss of accountability over meal count reporting and could lead to a reduction or forfeiture of future funding for this program.
The District should develop control policies and procedures to ensure the number of meals served and reported to DEW agree to the respective daily meal count forms and the meals served / tabulated on the point-of-sale system CN-6 and CN-7 Reports. The procedures should include an independent review of the meal counts manually entered into the point-of-sale system, based upon the daily meal count forms, and the meal counts manually entered into CRRS, based upon the point-of-sale system CN-6 and CN-7 reports, by an employee not associated with the computer entry. These review procedures should be acknowledged by initials / signatures on the point-of-sale system reports and the CRRS Site Claim Reports. If there are errors or discrepancies between the point-of-sale reports and the amounts reported to DEW, the District should maintain supporting documentation to demonstrate the meals reported to DEW were accurate and complete.
7 CFR § 210.8(a) states, "The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems."
7 CFR § 220.11(b) states in part, claims for reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the State Agency to provide the Reports of School Program Operations required under § 220.13(b)(2).
In Ohio, the Ohio Department of Education and Workforce (DEW) requires school districts to use the Claims Reporting and Reimbursement System (CRRS) to report meal data for reimbursement. The District uses a point-of-sale system that generates a CN-6 Report (Breakfast) and CN-7 Report (Lunch), which is used to compile the monthly reimbursement request submitted to DEW.
Due to insufficient controls over CN-6 and CN-7 reporting. related to breakfast and lunch meal counts, six of the 60 (10%) CN reports tested were inaccurate. This led to inaccuracies in meal counts reported in the CRRS system.
This weakness resulted in a loss of accountability over meal count reporting and could lead to a reduction or forfeiture of future funding for this program.
The District should develop control policies and procedures to ensure the number of meals served and reported to DEW agree to the respective daily meal count forms and the meals served / tabulated on the point-of-sale system CN-6 and CN-7 Reports. The procedures should include an independent review of the meal counts manually entered into the point-of-sale system, based upon the daily meal count forms, and the meal counts manually entered into CRRS, based upon the point-of-sale system CN-6 and CN-7 reports, by an employee not associated with the computer entry. These review procedures should be acknowledged by initials / signatures on the point-of-sale system reports and the CRRS Site Claim Reports. If there are errors or discrepancies between the point-of-sale reports and the amounts reported to DEW, the District should maintain supporting documentation to demonstrate the meals reported to DEW were accurate and complete.
7 CFR § 210.8(a) states, "The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems."
7 CFR § 220.11(b) states in part, claims for reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the State Agency to provide the Reports of School Program Operations required under § 220.13(b)(2).
In Ohio, the Ohio Department of Education and Workforce (DEW) requires school districts to use the Claims Reporting and Reimbursement System (CRRS) to report meal data for reimbursement. The District uses a point-of-sale system that generates a CN-6 Report (Breakfast) and CN-7 Report (Lunch), which is used to compile the monthly reimbursement request submitted to DEW.
Due to insufficient controls over CN-6 and CN-7 reporting. related to breakfast and lunch meal counts, six of the 60 (10%) CN reports tested were inaccurate. This led to inaccuracies in meal counts reported in the CRRS system.
This weakness resulted in a loss of accountability over meal count reporting and could lead to a reduction or forfeiture of future funding for this program.
The District should develop control policies and procedures to ensure the number of meals served and reported to DEW agree to the respective daily meal count forms and the meals served / tabulated on the point-of-sale system CN-6 and CN-7 Reports. The procedures should include an independent review of the meal counts manually entered into the point-of-sale system, based upon the daily meal count forms, and the meal counts manually entered into CRRS, based upon the point-of-sale system CN-6 and CN-7 reports, by an employee not associated with the computer entry. These review procedures should be acknowledged by initials / signatures on the point-of-sale system reports and the CRRS Site Claim Reports. If there are errors or discrepancies between the point-of-sale reports and the amounts reported to DEW, the District should maintain supporting documentation to demonstrate the meals reported to DEW were accurate and complete.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 3474.1 gives regulatory effect to the Office of Budget and Management Guidance in 2 CFR § 200.313(d) for the Department of Education, which states, in part, that a control system must be in place to ensure safeguards to prevent loss, damage, or theft of the equipment. It also requires that the recipient or subrecipient maintain property records that include a description of the asset, a serial number or other source of identification (including the FAIN), the source of funding for the property and other data to identify the equipment. Finally, it requires recipients or subrecipients to perform a physical inventory of property purchased with federal funds and reconcile the inventory results to the recipient or subrecipient’s property records at least once every two years.
Due to insufficient knowledge of and controls in place over the federal requirements related to equipment, the District could not provide evidence that a physical inventory over property purchased with Elementary and Secondary School Emergency Relief (ESSER) Fund (AL #84.425D) and American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Funds (AL #84.425U) had been taken and reconciled with property records in the required timeframe. In addition, 30 of the 60 property items selected for physical observation were not properly tagged and could not be verified with the District’s property listing provided by management. The District maintains a list of students for which laptops and hot spots are issued, but due to insufficient controls and procedures over the issuance of laptops provided to students we noted, in addition to the 30 errors mentioned above, the District could not provide the property selected for physical observation for 28 of the remaining 60 property items tested prior to the end of the audit.
Lack of controls over equipment management and failure to complete the required inventory could lead to misappropriation of District assets and potential questioned costs and non-compliance with federal requirements.
We recommend the District establish control procedures over the management of equipment. Controls would include proper tagging of assets and regularly scheduled inventory dates. In addition, the policy should include procedures to ensure District assets under the control of students are regularly inventoried and verified.
2 CFR § 3474.1 gives regulatory effect to the Office of Budget and Management Guidance in 2 CFR § 200.313(d) for the Department of Education, which states, in part, that a control system must be in place to ensure safeguards to prevent loss, damage, or theft of the equipment. It also requires that the recipient or subrecipient maintain property records that include a description of the asset, a serial number or other source of identification (including the FAIN), the source of funding for the property and other data to identify the equipment. Finally, it requires recipients or subrecipients to perform a physical inventory of property purchased with federal funds and reconcile the inventory results to the recipient or subrecipient’s property records at least once every two years.
Due to insufficient knowledge of and controls in place over the federal requirements related to equipment, the District could not provide evidence that a physical inventory over property purchased with Elementary and Secondary School Emergency Relief (ESSER) Fund (AL #84.425D) and American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Funds (AL #84.425U) had been taken and reconciled with property records in the required timeframe. In addition, 30 of the 60 property items selected for physical observation were not properly tagged and could not be verified with the District’s property listing provided by management. The District maintains a list of students for which laptops and hot spots are issued, but due to insufficient controls and procedures over the issuance of laptops provided to students we noted, in addition to the 30 errors mentioned above, the District could not provide the property selected for physical observation for 28 of the remaining 60 property items tested prior to the end of the audit.
Lack of controls over equipment management and failure to complete the required inventory could lead to misappropriation of District assets and potential questioned costs and non-compliance with federal requirements.
We recommend the District establish control procedures over the management of equipment. Controls would include proper tagging of assets and regularly scheduled inventory dates. In addition, the policy should include procedures to ensure District assets under the control of students are regularly inventoried and verified.
2 CFR § 3474.1 gives regulatory effect to the Office of Budget and Management Guidance in 2 CFR § 200.313(d) for the Department of Education, which states, in part, that a control system must be in place to ensure safeguards to prevent loss, damage, or theft of the equipment. It also requires that the recipient or subrecipient maintain property records that include a description of the asset, a serial number or other source of identification (including the FAIN), the source of funding for the property and other data to identify the equipment. Finally, it requires recipients or subrecipients to perform a physical inventory of property purchased with federal funds and reconcile the inventory results to the recipient or subrecipient’s property records at least once every two years.
Due to insufficient knowledge of and controls in place over the federal requirements related to equipment, the District could not provide evidence that a physical inventory over property purchased with Elementary and Secondary School Emergency Relief (ESSER) Fund (AL #84.425D) and American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Funds (AL #84.425U) had been taken and reconciled with property records in the required timeframe. In addition, 30 of the 60 property items selected for physical observation were not properly tagged and could not be verified with the District’s property listing provided by management. The District maintains a list of students for which laptops and hot spots are issued, but due to insufficient controls and procedures over the issuance of laptops provided to students we noted, in addition to the 30 errors mentioned above, the District could not provide the property selected for physical observation for 28 of the remaining 60 property items tested prior to the end of the audit.
Lack of controls over equipment management and failure to complete the required inventory could lead to misappropriation of District assets and potential questioned costs and non-compliance with federal requirements.
We recommend the District establish control procedures over the management of equipment. Controls would include proper tagging of assets and regularly scheduled inventory dates. In addition, the policy should include procedures to ensure District assets under the control of students are regularly inventoried and verified.
2 CFR § 3474.1 gives regulatory effect to the Office of Budget and Management Guidance in 2 CFR § 200.313(d) for the Department of Education, which states, in part, that a control system must be in place to ensure safeguards to prevent loss, damage, or theft of the equipment. It also requires that the recipient or subrecipient maintain property records that include a description of the asset, a serial number or other source of identification (including the FAIN), the source of funding for the property and other data to identify the equipment. Finally, it requires recipients or subrecipients to perform a physical inventory of property purchased with federal funds and reconcile the inventory results to the recipient or subrecipient’s property records at least once every two years.
Due to insufficient knowledge of and controls in place over the federal requirements related to equipment, the District could not provide evidence that a physical inventory over property purchased with Elementary and Secondary School Emergency Relief (ESSER) Fund (AL #84.425D) and American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Funds (AL #84.425U) had been taken and reconciled with property records in the required timeframe. In addition, 30 of the 60 property items selected for physical observation were not properly tagged and could not be verified with the District’s property listing provided by management. The District maintains a list of students for which laptops and hot spots are issued, but due to insufficient controls and procedures over the issuance of laptops provided to students we noted, in addition to the 30 errors mentioned above, the District could not provide the property selected for physical observation for 28 of the remaining 60 property items tested prior to the end of the audit.
Lack of controls over equipment management and failure to complete the required inventory could lead to misappropriation of District assets and potential questioned costs and non-compliance with federal requirements.
We recommend the District establish control procedures over the management of equipment. Controls would include proper tagging of assets and regularly scheduled inventory dates. In addition, the policy should include procedures to ensure District assets under the control of students are regularly inventoried and verified.
7 CFR § 210.8(a) states, "The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems."
7 CFR § 220.11(b) states in part, claims for reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the State Agency to provide the Reports of School Program Operations required under § 220.13(b)(2).
In Ohio, the Ohio Department of Education and Workforce (DEW) requires school districts to use the Claims Reporting and Reimbursement System (CRRS) to report meal data for reimbursement. The District uses a point-of-sale system that generates a CN-6 Report (Breakfast) and CN-7 Report (Lunch), which is used to compile the monthly reimbursement request submitted to DEW.
Due to insufficient controls over CN-6 and CN-7 reporting. related to breakfast and lunch meal counts, six of the 60 (10%) CN reports tested were inaccurate. This led to inaccuracies in meal counts reported in the CRRS system.
This weakness resulted in a loss of accountability over meal count reporting and could lead to a reduction or forfeiture of future funding for this program.
The District should develop control policies and procedures to ensure the number of meals served and reported to DEW agree to the respective daily meal count forms and the meals served / tabulated on the point-of-sale system CN-6 and CN-7 Reports. The procedures should include an independent review of the meal counts manually entered into the point-of-sale system, based upon the daily meal count forms, and the meal counts manually entered into CRRS, based upon the point-of-sale system CN-6 and CN-7 reports, by an employee not associated with the computer entry. These review procedures should be acknowledged by initials / signatures on the point-of-sale system reports and the CRRS Site Claim Reports. If there are errors or discrepancies between the point-of-sale reports and the amounts reported to DEW, the District should maintain supporting documentation to demonstrate the meals reported to DEW were accurate and complete.
7 CFR § 210.8(a) states, "The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems."
7 CFR § 220.11(b) states in part, claims for reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the State Agency to provide the Reports of School Program Operations required under § 220.13(b)(2).
In Ohio, the Ohio Department of Education and Workforce (DEW) requires school districts to use the Claims Reporting and Reimbursement System (CRRS) to report meal data for reimbursement. The District uses a point-of-sale system that generates a CN-6 Report (Breakfast) and CN-7 Report (Lunch), which is used to compile the monthly reimbursement request submitted to DEW.
Due to insufficient controls over CN-6 and CN-7 reporting. related to breakfast and lunch meal counts, six of the 60 (10%) CN reports tested were inaccurate. This led to inaccuracies in meal counts reported in the CRRS system.
This weakness resulted in a loss of accountability over meal count reporting and could lead to a reduction or forfeiture of future funding for this program.
The District should develop control policies and procedures to ensure the number of meals served and reported to DEW agree to the respective daily meal count forms and the meals served / tabulated on the point-of-sale system CN-6 and CN-7 Reports. The procedures should include an independent review of the meal counts manually entered into the point-of-sale system, based upon the daily meal count forms, and the meal counts manually entered into CRRS, based upon the point-of-sale system CN-6 and CN-7 reports, by an employee not associated with the computer entry. These review procedures should be acknowledged by initials / signatures on the point-of-sale system reports and the CRRS Site Claim Reports. If there are errors or discrepancies between the point-of-sale reports and the amounts reported to DEW, the District should maintain supporting documentation to demonstrate the meals reported to DEW were accurate and complete.
7 CFR § 210.8(a) states, "The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems."
7 CFR § 220.11(b) states in part, claims for reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the State Agency to provide the Reports of School Program Operations required under § 220.13(b)(2).
In Ohio, the Ohio Department of Education and Workforce (DEW) requires school districts to use the Claims Reporting and Reimbursement System (CRRS) to report meal data for reimbursement. The District uses a point-of-sale system that generates a CN-6 Report (Breakfast) and CN-7 Report (Lunch), which is used to compile the monthly reimbursement request submitted to DEW.
Due to insufficient controls over CN-6 and CN-7 reporting. related to breakfast and lunch meal counts, six of the 60 (10%) CN reports tested were inaccurate. This led to inaccuracies in meal counts reported in the CRRS system.
This weakness resulted in a loss of accountability over meal count reporting and could lead to a reduction or forfeiture of future funding for this program.
The District should develop control policies and procedures to ensure the number of meals served and reported to DEW agree to the respective daily meal count forms and the meals served / tabulated on the point-of-sale system CN-6 and CN-7 Reports. The procedures should include an independent review of the meal counts manually entered into the point-of-sale system, based upon the daily meal count forms, and the meal counts manually entered into CRRS, based upon the point-of-sale system CN-6 and CN-7 reports, by an employee not associated with the computer entry. These review procedures should be acknowledged by initials / signatures on the point-of-sale system reports and the CRRS Site Claim Reports. If there are errors or discrepancies between the point-of-sale reports and the amounts reported to DEW, the District should maintain supporting documentation to demonstrate the meals reported to DEW were accurate and complete.
7 CFR § 210.8(a) states, "The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems."
7 CFR § 220.11(b) states in part, claims for reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the State Agency to provide the Reports of School Program Operations required under § 220.13(b)(2).
In Ohio, the Ohio Department of Education and Workforce (DEW) requires school districts to use the Claims Reporting and Reimbursement System (CRRS) to report meal data for reimbursement. The District uses a point-of-sale system that generates a CN-6 Report (Breakfast) and CN-7 Report (Lunch), which is used to compile the monthly reimbursement request submitted to DEW.
Due to insufficient controls over CN-6 and CN-7 reporting. related to breakfast and lunch meal counts, six of the 60 (10%) CN reports tested were inaccurate. This led to inaccuracies in meal counts reported in the CRRS system.
This weakness resulted in a loss of accountability over meal count reporting and could lead to a reduction or forfeiture of future funding for this program.
The District should develop control policies and procedures to ensure the number of meals served and reported to DEW agree to the respective daily meal count forms and the meals served / tabulated on the point-of-sale system CN-6 and CN-7 Reports. The procedures should include an independent review of the meal counts manually entered into the point-of-sale system, based upon the daily meal count forms, and the meal counts manually entered into CRRS, based upon the point-of-sale system CN-6 and CN-7 reports, by an employee not associated with the computer entry. These review procedures should be acknowledged by initials / signatures on the point-of-sale system reports and the CRRS Site Claim Reports. If there are errors or discrepancies between the point-of-sale reports and the amounts reported to DEW, the District should maintain supporting documentation to demonstrate the meals reported to DEW were accurate and complete.
7 CFR § 210.8(a) states, "The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems."
7 CFR § 220.11(b) states in part, claims for reimbursement shall include data in sufficient detail to justify the reimbursement claimed and to enable the State Agency to provide the Reports of School Program Operations required under § 220.13(b)(2).
In Ohio, the Ohio Department of Education and Workforce (DEW) requires school districts to use the Claims Reporting and Reimbursement System (CRRS) to report meal data for reimbursement. The District uses a point-of-sale system that generates a CN-6 Report (Breakfast) and CN-7 Report (Lunch), which is used to compile the monthly reimbursement request submitted to DEW.
Due to insufficient controls over CN-6 and CN-7 reporting. related to breakfast and lunch meal counts, six of the 60 (10%) CN reports tested were inaccurate. This led to inaccuracies in meal counts reported in the CRRS system.
This weakness resulted in a loss of accountability over meal count reporting and could lead to a reduction or forfeiture of future funding for this program.
The District should develop control policies and procedures to ensure the number of meals served and reported to DEW agree to the respective daily meal count forms and the meals served / tabulated on the point-of-sale system CN-6 and CN-7 Reports. The procedures should include an independent review of the meal counts manually entered into the point-of-sale system, based upon the daily meal count forms, and the meal counts manually entered into CRRS, based upon the point-of-sale system CN-6 and CN-7 reports, by an employee not associated with the computer entry. These review procedures should be acknowledged by initials / signatures on the point-of-sale system reports and the CRRS Site Claim Reports. If there are errors or discrepancies between the point-of-sale reports and the amounts reported to DEW, the District should maintain supporting documentation to demonstrate the meals reported to DEW were accurate and complete.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 200.430(g) states in part, “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed and be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Furthermore, Cleveland Municipal School District has adopted a Time and Effort Reporting policy that requires that all federal compensation charges be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated in accordance with 2 CFR § 200.430.
In order to address the requirements in their policy and federal regulations, the District established a control procedure in which the Cost Center Manager or higher grant manager is required to certify an employee's charge to a federal grant within the Workday accounting system.
Due to insufficient staffing and knowledge of the District policy and federal regulation, 28 of 40 (70%) tested employee compensation charges to the Child Nutrition Cluster and 31 of 40 (78%) charges to the Education Stabilization Grant were certified more than six months from the original pay date.
This weakness could lead to a loss of accountability over Federal Time and Effort Reporting and could result in a loss or reduction of funding and potential questioned costs, related to these grants
The District should establish procedures to ensure that employee compensation charges, to a federal grant, are timely reviewed for accuracy, allowability and proper allocation. Further, the District should update the existing policy to require the time and effort certifications to be completed within two months of the transaction date.
2 CFR § 3474.1 gives regulatory effect to the Office of Budget and Management Guidance in 2 CFR § 200.313(d) for the Department of Education, which states, in part, that a control system must be in place to ensure safeguards to prevent loss, damage, or theft of the equipment. It also requires that the recipient or subrecipient maintain property records that include a description of the asset, a serial number or other source of identification (including the FAIN), the source of funding for the property and other data to identify the equipment. Finally, it requires recipients or subrecipients to perform a physical inventory of property purchased with federal funds and reconcile the inventory results to the recipient or subrecipient’s property records at least once every two years.
Due to insufficient knowledge of and controls in place over the federal requirements related to equipment, the District could not provide evidence that a physical inventory over property purchased with Elementary and Secondary School Emergency Relief (ESSER) Fund (AL #84.425D) and American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Funds (AL #84.425U) had been taken and reconciled with property records in the required timeframe. In addition, 30 of the 60 property items selected for physical observation were not properly tagged and could not be verified with the District’s property listing provided by management. The District maintains a list of students for which laptops and hot spots are issued, but due to insufficient controls and procedures over the issuance of laptops provided to students we noted, in addition to the 30 errors mentioned above, the District could not provide the property selected for physical observation for 28 of the remaining 60 property items tested prior to the end of the audit.
Lack of controls over equipment management and failure to complete the required inventory could lead to misappropriation of District assets and potential questioned costs and non-compliance with federal requirements.
We recommend the District establish control procedures over the management of equipment. Controls would include proper tagging of assets and regularly scheduled inventory dates. In addition, the policy should include procedures to ensure District assets under the control of students are regularly inventoried and verified.
2 CFR § 3474.1 gives regulatory effect to the Office of Budget and Management Guidance in 2 CFR § 200.313(d) for the Department of Education, which states, in part, that a control system must be in place to ensure safeguards to prevent loss, damage, or theft of the equipment. It also requires that the recipient or subrecipient maintain property records that include a description of the asset, a serial number or other source of identification (including the FAIN), the source of funding for the property and other data to identify the equipment. Finally, it requires recipients or subrecipients to perform a physical inventory of property purchased with federal funds and reconcile the inventory results to the recipient or subrecipient’s property records at least once every two years.
Due to insufficient knowledge of and controls in place over the federal requirements related to equipment, the District could not provide evidence that a physical inventory over property purchased with Elementary and Secondary School Emergency Relief (ESSER) Fund (AL #84.425D) and American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Funds (AL #84.425U) had been taken and reconciled with property records in the required timeframe. In addition, 30 of the 60 property items selected for physical observation were not properly tagged and could not be verified with the District’s property listing provided by management. The District maintains a list of students for which laptops and hot spots are issued, but due to insufficient controls and procedures over the issuance of laptops provided to students we noted, in addition to the 30 errors mentioned above, the District could not provide the property selected for physical observation for 28 of the remaining 60 property items tested prior to the end of the audit.
Lack of controls over equipment management and failure to complete the required inventory could lead to misappropriation of District assets and potential questioned costs and non-compliance with federal requirements.
We recommend the District establish control procedures over the management of equipment. Controls would include proper tagging of assets and regularly scheduled inventory dates. In addition, the policy should include procedures to ensure District assets under the control of students are regularly inventoried and verified.
2 CFR § 3474.1 gives regulatory effect to the Office of Budget and Management Guidance in 2 CFR § 200.313(d) for the Department of Education, which states, in part, that a control system must be in place to ensure safeguards to prevent loss, damage, or theft of the equipment. It also requires that the recipient or subrecipient maintain property records that include a description of the asset, a serial number or other source of identification (including the FAIN), the source of funding for the property and other data to identify the equipment. Finally, it requires recipients or subrecipients to perform a physical inventory of property purchased with federal funds and reconcile the inventory results to the recipient or subrecipient’s property records at least once every two years.
Due to insufficient knowledge of and controls in place over the federal requirements related to equipment, the District could not provide evidence that a physical inventory over property purchased with Elementary and Secondary School Emergency Relief (ESSER) Fund (AL #84.425D) and American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Funds (AL #84.425U) had been taken and reconciled with property records in the required timeframe. In addition, 30 of the 60 property items selected for physical observation were not properly tagged and could not be verified with the District’s property listing provided by management. The District maintains a list of students for which laptops and hot spots are issued, but due to insufficient controls and procedures over the issuance of laptops provided to students we noted, in addition to the 30 errors mentioned above, the District could not provide the property selected for physical observation for 28 of the remaining 60 property items tested prior to the end of the audit.
Lack of controls over equipment management and failure to complete the required inventory could lead to misappropriation of District assets and potential questioned costs and non-compliance with federal requirements.
We recommend the District establish control procedures over the management of equipment. Controls would include proper tagging of assets and regularly scheduled inventory dates. In addition, the policy should include procedures to ensure District assets under the control of students are regularly inventoried and verified.
2 CFR § 3474.1 gives regulatory effect to the Office of Budget and Management Guidance in 2 CFR § 200.313(d) for the Department of Education, which states, in part, that a control system must be in place to ensure safeguards to prevent loss, damage, or theft of the equipment. It also requires that the recipient or subrecipient maintain property records that include a description of the asset, a serial number or other source of identification (including the FAIN), the source of funding for the property and other data to identify the equipment. Finally, it requires recipients or subrecipients to perform a physical inventory of property purchased with federal funds and reconcile the inventory results to the recipient or subrecipient’s property records at least once every two years.
Due to insufficient knowledge of and controls in place over the federal requirements related to equipment, the District could not provide evidence that a physical inventory over property purchased with Elementary and Secondary School Emergency Relief (ESSER) Fund (AL #84.425D) and American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Funds (AL #84.425U) had been taken and reconciled with property records in the required timeframe. In addition, 30 of the 60 property items selected for physical observation were not properly tagged and could not be verified with the District’s property listing provided by management. The District maintains a list of students for which laptops and hot spots are issued, but due to insufficient controls and procedures over the issuance of laptops provided to students we noted, in addition to the 30 errors mentioned above, the District could not provide the property selected for physical observation for 28 of the remaining 60 property items tested prior to the end of the audit.
Lack of controls over equipment management and failure to complete the required inventory could lead to misappropriation of District assets and potential questioned costs and non-compliance with federal requirements.
We recommend the District establish control procedures over the management of equipment. Controls would include proper tagging of assets and regularly scheduled inventory dates. In addition, the policy should include procedures to ensure District assets under the control of students are regularly inventoried and verified.