Audit 348296

Internal Control and Compliance over Level of Effort Identification of the Federal Program: Assistance Listing Number: 84.116z Assistance Listing Title: Fund for the Improvement of Postsecondary Education Federal Agency: Department of the Education Pass-Through Entity: None Federal Award Number and Award Year: P116Z220212 and 2022 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Grant Award Notification Section 5 – Key Personnel, the City is required to maintain level of effort of 10% devoting to the project by the Project Director. Condition: We noted that the City did not meet the requirements of level of effort based on the documents provided. Cause: There was turnover of the Project Director position and there is lack of transition and training on the program requirements. Effect or Potential Effect: Not meeting the requirements of level of effort lead to the U.S. Department of Education imposing sanctions on the City including withholding future apportionments. Questioned Costs: No questioned costs were reported. Context: See condition above for context of the finding. Identification as A Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City implement policies and procedures relating training and transition of program responsibilities in event of turnover to avoid not meeting program requirements. We also recommended the City develop a process and start tracking the time and effort of the new Project Director to ensure compliance with level of effort requirement. Views of Responsible Officials: Management concurs with the finding and agrees to implement necessary corrective procedures.

Internal Control and Compliance over Level of Effort Identification of the Federal Program: Assistance Listing Number: 84.116z Assistance Listing Title: Fund for the Improvement of Postsecondary Education Federal Agency: Department of the Education Pass-Through Entity: None Federal Award Number and Award Year: P116Z220212 and 2022 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Pursuant to the Grant Award Notification Section 5 – Key Personnel, the City is required to maintain level of effort of 10% devoting to the project by the Project Director. Condition: We noted that the City did not meet the requirements of level of effort based on the documents provided. Cause: There was turnover of the Project Director position and there is lack of transition and training on the program requirements. Effect or Potential Effect: Not meeting the requirements of level of effort lead to the U.S. Department of Education imposing sanctions on the City including withholding future apportionments. Questioned Costs: No questioned costs were reported. Context: See condition above for context of the finding. Identification as A Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City implement policies and procedures relating training and transition of program responsibilities in event of turnover to avoid not meeting program requirements. We also recommended the City develop a process and start tracking the time and effort of the new Project Director to ensure compliance with level of effort requirement. Views of Responsible Officials: Management concurs with the finding and agrees to implement necessary corrective procedures.