Criteria or specific requirement:
Compliance: 2 CFR §200.332(a) - Requirements for Pass-Through Entities states, in part, that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.
Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition:
The City did not furnish all required information to subrecipients at the time the subawards were issued.
Context:
The City failed to obtain the required Unique Entity Identifier (UEI) from one out of five subrecipients tested and the Federal Award Identification Number (FAIN) from five out of five subrecipients tested in accordance with proper subrecipient monitoring procedures.
Questioned costs:
None.
Cause:
The City did not establish effective internal controls and procedures over subrecipient monitoring.Effect:
Excluding required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about program-specific regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in subrecipients’ Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance.Recommendation:
The City should review and enhance its internal controls and procedures to ensure that all required information is included in subawards at the time of issuance and maintained in subsequent modifications.
Views of responsible officials:
The City agrees with this finding. See separate Corrective Action Plan related to this finding.
Criteria or specific requirement:
Per 2 CFR section 200.326, nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations.
Condition:
The contracts and subcontracts did not include the required prevailing wage rate provisions.
Context:
For all 11 contracts tested, prevailing wage rate clauses were missing in both the contracts or
subcontracts. However, the City did obtain certified weekly payrolls from all contractors tested.
Questioned costs:
Undetermined.
Cause:
The City failed to adhere to established internal controls over wage rate requirements and related
regulations.
Effect:
Excluding the required prevailing wage rate information in contracts and subcontracts may cause
vendors to be uninformed about specific program regulations that apply to the funds they receive.
Recommendation:
The City should review and enhance its policies and procedures to ensure that all required wage rate
provisions are consistently included in contracts and subcontracts.
Views of responsible officials:
The City agrees with this finding. See separate Corrective Action Plan related to this finding.
Criteria or specific requirement:
Per the Virginia Department of Education, the proportionate share set aside amount for each required school divisions must be expended during the grant period on the provision of special education and related services for the parentally-placed private school students with disabilities enrolled in private schools and homeschooled children located in the LEA. Funds not obligated or spent at the end of the first fiscal year of the grant must be carried forward for one additional year. Any unspent funds after the one year carry over period can be spent for the other special education and related services activities. The actual Proportionate Set Aside (PSA) amount for the grant is established based on data submitted during the PSA data collection in the fall and not preliminary amounts included in the annual plan.
Condition/Context:
The PSA calculation incorrectly reported the number of eligible children with disabilities in the Schools. This error occurred due to inadequate review before the Schools verified the calculation. The error resulted in a higher amount to be expended during the grant period on the provision of special education services than required; therefore, the Schools were still in compliance with the earmarking requirement, as they expended the higher amount.
Questioned costs:
None.
Cause:
The Schools lacked established internal controls to ensure a proper review and approval process for
the PSA calculation.
Effect:
Without proper internal controls, the Schools could approve an incorrect PSA calculation and potentially
fail to meet the earmarking requirements set for the by the Virginia Department of Education.
Recommendation:
We recommend that the Schools review and strengthen their policies and procedures to ensure the
proper review and approval of the PSA calculation before finalization.
Views of responsible officials:
The Schools agree with this finding. See separate Corrective Action Plan related to this finding.
Criteria or specific requirement:
Per the Virginia Department of Education, the proportionate share set aside amount for each required school divisions must be expended during the grant period on the provision of special education and related services for the parentally-placed private school students with disabilities enrolled in private schools and homeschooled children located in the LEA. Funds not obligated or spent at the end of the first fiscal year of the grant must be carried forward for one additional year. Any unspent funds after the one year carry over period can be spent for the other special education and related services activities. The actual Proportionate Set Aside (PSA) amount for the grant is established based on data submitted during the PSA data collection in the fall and not preliminary amounts included in the annual plan.
Condition/Context:
The PSA calculation incorrectly reported the number of eligible children with disabilities in the Schools. This error occurred due to inadequate review before the Schools verified the calculation. The error resulted in a higher amount to be expended during the grant period on the provision of special education services than required; therefore, the Schools were still in compliance with the earmarking requirement, as they expended the higher amount.
Questioned costs:
None.
Cause:
The Schools lacked established internal controls to ensure a proper review and approval process for
the PSA calculation.
Effect:
Without proper internal controls, the Schools could approve an incorrect PSA calculation and potentially
fail to meet the earmarking requirements set for the by the Virginia Department of Education.
Recommendation:
We recommend that the Schools review and strengthen their policies and procedures to ensure the
proper review and approval of the PSA calculation before finalization.
Views of responsible officials:
The Schools agree with this finding. See separate Corrective Action Plan related to this finding.
Criteria or specific requirement:
22 CFR sections 637.201, 637.205, 637.207 and 637.209: A Local Public Agency (LPA) must have a quality assurance program, approved by the Federal Highway Administration (FHWA), for construction projects on the National Highway System (NHS) to ensure that materials and workmanship conform to approved plans and specifications. Verification sampling must be performed by qualified personnel employed by the State Department of Transportation or its designated agent.
Condition/Context:
For one out of six construction projects tested, the City could not provide documentation that proper tests were performed in accordance with the quality assurance program and that verification sampling activities were performed by qualified testing personnel.
Questioned costs:
None.
Cause:
The City’s procedures and controls were insufficient to ensure that support for testing under the quality
assurance program was maintained and readily available for audit.
Effect:
Without proper testing in accordance with the quality assurance program, there is a risk materials and workmanship for construction projects on the NHS may not conform to approved plans and specifications.Recommendation:
We recommend that the City enhance its policies and procedures to ensure proper tests are conducted in accordance with the quality assurance program for construction projects on the NHS and is readily available for audit.
Views of responsible officials:
The City agrees with this finding. See separate Corrective Action Plan related to this finding
Criteria or specific requirement:
Compliance: 2 CFR §200.332(a) - Requirements for Pass-Through Entities states, in part, that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.
Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition:
The City did not furnish all required information to subrecipients at the time the subawards were issued.
Context:
The City failed to obtain the required Unique Entity Identifier (UEI) from one out of five subrecipients tested and the Federal Award Identification Number (FAIN) from five out of five subrecipients tested in accordance with proper subrecipient monitoring procedures.
Questioned costs:
None.
Cause:
The City did not establish effective internal controls and procedures over subrecipient monitoring.Effect:
Excluding required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about program-specific regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in subrecipients’ Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance.Recommendation:
The City should review and enhance its internal controls and procedures to ensure that all required information is included in subawards at the time of issuance and maintained in subsequent modifications.
Views of responsible officials:
The City agrees with this finding. See separate Corrective Action Plan related to this finding.
Criteria or specific requirement:
Per 2 CFR section 200.326, nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations.
Condition:
The contracts and subcontracts did not include the required prevailing wage rate provisions.
Context:
For all 11 contracts tested, prevailing wage rate clauses were missing in both the contracts or
subcontracts. However, the City did obtain certified weekly payrolls from all contractors tested.
Questioned costs:
Undetermined.
Cause:
The City failed to adhere to established internal controls over wage rate requirements and related
regulations.
Effect:
Excluding the required prevailing wage rate information in contracts and subcontracts may cause
vendors to be uninformed about specific program regulations that apply to the funds they receive.
Recommendation:
The City should review and enhance its policies and procedures to ensure that all required wage rate
provisions are consistently included in contracts and subcontracts.
Views of responsible officials:
The City agrees with this finding. See separate Corrective Action Plan related to this finding.
Criteria or specific requirement:
Per the Virginia Department of Education, the proportionate share set aside amount for each required school divisions must be expended during the grant period on the provision of special education and related services for the parentally-placed private school students with disabilities enrolled in private schools and homeschooled children located in the LEA. Funds not obligated or spent at the end of the first fiscal year of the grant must be carried forward for one additional year. Any unspent funds after the one year carry over period can be spent for the other special education and related services activities. The actual Proportionate Set Aside (PSA) amount for the grant is established based on data submitted during the PSA data collection in the fall and not preliminary amounts included in the annual plan.
Condition/Context:
The PSA calculation incorrectly reported the number of eligible children with disabilities in the Schools. This error occurred due to inadequate review before the Schools verified the calculation. The error resulted in a higher amount to be expended during the grant period on the provision of special education services than required; therefore, the Schools were still in compliance with the earmarking requirement, as they expended the higher amount.
Questioned costs:
None.
Cause:
The Schools lacked established internal controls to ensure a proper review and approval process for
the PSA calculation.
Effect:
Without proper internal controls, the Schools could approve an incorrect PSA calculation and potentially
fail to meet the earmarking requirements set for the by the Virginia Department of Education.
Recommendation:
We recommend that the Schools review and strengthen their policies and procedures to ensure the
proper review and approval of the PSA calculation before finalization.
Views of responsible officials:
The Schools agree with this finding. See separate Corrective Action Plan related to this finding.
Criteria or specific requirement:
Per the Virginia Department of Education, the proportionate share set aside amount for each required school divisions must be expended during the grant period on the provision of special education and related services for the parentally-placed private school students with disabilities enrolled in private schools and homeschooled children located in the LEA. Funds not obligated or spent at the end of the first fiscal year of the grant must be carried forward for one additional year. Any unspent funds after the one year carry over period can be spent for the other special education and related services activities. The actual Proportionate Set Aside (PSA) amount for the grant is established based on data submitted during the PSA data collection in the fall and not preliminary amounts included in the annual plan.
Condition/Context:
The PSA calculation incorrectly reported the number of eligible children with disabilities in the Schools. This error occurred due to inadequate review before the Schools verified the calculation. The error resulted in a higher amount to be expended during the grant period on the provision of special education services than required; therefore, the Schools were still in compliance with the earmarking requirement, as they expended the higher amount.
Questioned costs:
None.
Cause:
The Schools lacked established internal controls to ensure a proper review and approval process for
the PSA calculation.
Effect:
Without proper internal controls, the Schools could approve an incorrect PSA calculation and potentially
fail to meet the earmarking requirements set for the by the Virginia Department of Education.
Recommendation:
We recommend that the Schools review and strengthen their policies and procedures to ensure the
proper review and approval of the PSA calculation before finalization.
Views of responsible officials:
The Schools agree with this finding. See separate Corrective Action Plan related to this finding.
Criteria or specific requirement:
22 CFR sections 637.201, 637.205, 637.207 and 637.209: A Local Public Agency (LPA) must have a quality assurance program, approved by the Federal Highway Administration (FHWA), for construction projects on the National Highway System (NHS) to ensure that materials and workmanship conform to approved plans and specifications. Verification sampling must be performed by qualified personnel employed by the State Department of Transportation or its designated agent.
Condition/Context:
For one out of six construction projects tested, the City could not provide documentation that proper tests were performed in accordance with the quality assurance program and that verification sampling activities were performed by qualified testing personnel.
Questioned costs:
None.
Cause:
The City’s procedures and controls were insufficient to ensure that support for testing under the quality
assurance program was maintained and readily available for audit.
Effect:
Without proper testing in accordance with the quality assurance program, there is a risk materials and workmanship for construction projects on the NHS may not conform to approved plans and specifications.Recommendation:
We recommend that the City enhance its policies and procedures to ensure proper tests are conducted in accordance with the quality assurance program for construction projects on the NHS and is readily available for audit.
Views of responsible officials:
The City agrees with this finding. See separate Corrective Action Plan related to this finding