Assistance Listing Number(s): 84.425V
Name of Federal Program or Cluster: COVID-19 Education Stabilization Fund (ESF), American Rescue
Plan – Emergency Assistance to Non-Public Schools (ARP EANS)
Name of Federal Agency: Department of Education
Federal Award Identification Number: S425V210042
Federal Award Date: February 26, 2021 and September 24, 2021
Name of Pass-through Entity: State of North Carolina
Pass-through Entity Identifying Number: 60-04 and 60-05
Award Period: July 1, 2022 through September 30, 2023 and July 1, 2022 through September 30, 2024
Criteria: Uniform Guidance 2 CFR 200.430 requires charges to federal awards for compensation must be
based on records that accurately reflect the work performed.
Condition: 2 out of a total of 11 employees’ compensation and benefits charged to the federal award for the
fiscal year were not supported by time and effort documentation. 13 out of the total 43 quarterly
compensation and benefits charged were greater than the amount supported by the time and effort
documentation. A total of $278,803 of personnel and fringe were charged to the federal award.
Cause: Budgeted amounts were used, but no system of review and adjustments to actual were performed.
A written policy and procedures over documenting time and effort was not designed and implemented.
Effect or Potential Effect: Unsupported compensation and benefits charged to the program may be
disallowed.
Questioned Costs: $21,249 for the compensation costs and related employee benefits charged for the 2
employees that were not supported by time and effort documentation. $20,472 for the 13 quarterly
compensation and related benefits that were greater than the time and effort documentation supported.
Context: For the audit all employees whose compensation and benefits were charged to the federal award
retroactively provided signed quarterly time and effort documentation. These documentations were
reviewed and approved by their supervisors. Auditor viewed all 11 employees quarterly time and effort
documentation. While there were 13 quarterly compensation and benefits charges that were greater than the amount supported, there were 14 quarterly compensation and benefits that were undercharged by
$35,871.
Repeat Finding: No
Recommendation: Time and effort documentation be documented per Uniform Guidance requirements and
used to review and adjust budgeted compensation and benefit costs charged to the award to be accurate,
allowable, and properly allocated. Written policies and procedures should be designed and implemented
for documentation of time and effort.
Views of Responsible Officials: The organization agrees with the finding.
Assistance Listing Number(s): 84.425V
Name of Federal Program or Cluster: COVID-19 Education Stabilization Fund (ESF), American Rescue
Plan – Emergency Assistance to Non-Public Schools (ARP EANS)
Name of Federal Agency: Department of Education
Federal Award Identification Number: S425V210042
Federal Award Date: February 26, 2021 and September 24, 2021
Name of Pass-through Entity: State of North Carolina
Pass-through Entity Identifying Number: 60-04 and 60-05
Award Period: July 1, 2022 through September 30, 2023 and July 1, 2022 through September 30, 2024
Criteria: Uniform Guidance 2 CFR 200.303(a) requires the non-federal entity to 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.
Condition: 54 of 60 disbursements sampled did not have documented internal control that supported
reasonable assurance of compliance with allowable activities and cost principles requirements.
Cause: A written policy and procedures over documenting internal control(s) over allowable activities and
cost principles was not designed and implemented.
Effect or Potential Effect: Costs charged to the federal award are more likely to be for unallowable activities
and not comply with allowable cost principles. These costs may be disallowed.
Context: Salesforce is used to document disbursements, but was not set up to document internal control
procedures.
Repeat Finding: No
Recommendation: All disbursements charged to the federal award should have documentation to support
internal controls performed for allowable activities and cost principles. Written policies and procedures
should be designed and implemented for documentation of internal controls performed for allowable
activities and cost principles.
Views of Responsible Officials: The organization agrees with the finding.
Assistance Listing Number(s): 84.425V
Name of Federal Program or Cluster: COVID-19 Education Stabilization Fund (ESF), American Rescue
Plan – Emergency Assistance to Non-Public Schools (ARP EANS)
Name of Federal Agency: Department of Education
Federal Award Identification Number: S425V210042
Federal Award Date: February 26, 2021 and September 24, 2021
Name of Pass-through Entity: State of North Carolina
Pass-through Entity Identifying Number: 60-04 and 60-05
Award Period: July 1, 2022 through September 30, 2023 and July 1, 2022 through September 30, 2024
Criteria: Uniform Guidance 2 CFR 200.303(a) requires the non-federal entity to 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.
Condition: 2 out of 4 financial reports tested did not have an internal control documented that supported
reasonable assurance of compliance with reporting requirements.
Cause: A written policy and procedures over documenting internal control(s) over reporting was not
designed and implemented.
Effect or Potential Effect: Reports may be incomplete or inaccurate.
Repeat Finding: No
Recommendation: Internal control should be documented to ensure compliance with the reporting
compliance requirement. Documentation should include a signed certification by the preparer and a
reviewer that the requests for payment, written summaries of reporting-specific meetings with grantors, and
any other reporting activities are complete, accurate, and agree to supporting records of expenditures or
other accounting or database information. Written policies and procedures should be designed and
implemented for documentation of internal controls performed for reporting.
Views of Responsible Officials: The organization agrees with the finding.
Assistance Listing Number(s): 84.425V
Name of Federal Program or Cluster: COVID-19 Education Stabilization Fund (ESF), American Rescue
Plan – Emergency Assistance to Non-Public Schools (ARP EANS)
Name of Federal Agency: Department of Education
Federal Award Identification Number: S425V210042
Federal Award Date: February 26, 2021 and September 24, 2021
Name of Pass-through Entity: State of North Carolina
Pass-through Entity Identifying Number: 60-04 and 60-05
Award Period: July 1, 2022 through September 30, 2023 and July 1, 2022 through September 30, 2024
Criteria: Uniform Guidance 2 CFR 200.430 requires charges to federal awards for compensation must be
based on records that accurately reflect the work performed.
Condition: 2 out of a total of 11 employees’ compensation and benefits charged to the federal award for the
fiscal year were not supported by time and effort documentation. 13 out of the total 43 quarterly
compensation and benefits charged were greater than the amount supported by the time and effort
documentation. A total of $278,803 of personnel and fringe were charged to the federal award.
Cause: Budgeted amounts were used, but no system of review and adjustments to actual were performed.
A written policy and procedures over documenting time and effort was not designed and implemented.
Effect or Potential Effect: Unsupported compensation and benefits charged to the program may be
disallowed.
Questioned Costs: $21,249 for the compensation costs and related employee benefits charged for the 2
employees that were not supported by time and effort documentation. $20,472 for the 13 quarterly
compensation and related benefits that were greater than the time and effort documentation supported.
Context: For the audit all employees whose compensation and benefits were charged to the federal award
retroactively provided signed quarterly time and effort documentation. These documentations were
reviewed and approved by their supervisors. Auditor viewed all 11 employees quarterly time and effort
documentation. While there were 13 quarterly compensation and benefits charges that were greater than the amount supported, there were 14 quarterly compensation and benefits that were undercharged by
$35,871.
Repeat Finding: No
Recommendation: Time and effort documentation be documented per Uniform Guidance requirements and
used to review and adjust budgeted compensation and benefit costs charged to the award to be accurate,
allowable, and properly allocated. Written policies and procedures should be designed and implemented
for documentation of time and effort.
Views of Responsible Officials: The organization agrees with the finding.
Assistance Listing Number(s): 84.425V
Name of Federal Program or Cluster: COVID-19 Education Stabilization Fund (ESF), American Rescue
Plan – Emergency Assistance to Non-Public Schools (ARP EANS)
Name of Federal Agency: Department of Education
Federal Award Identification Number: S425V210042
Federal Award Date: February 26, 2021 and September 24, 2021
Name of Pass-through Entity: State of North Carolina
Pass-through Entity Identifying Number: 60-04 and 60-05
Award Period: July 1, 2022 through September 30, 2023 and July 1, 2022 through September 30, 2024
Criteria: Uniform Guidance 2 CFR 200.303(a) requires the non-federal entity to 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.
Condition: 54 of 60 disbursements sampled did not have documented internal control that supported
reasonable assurance of compliance with allowable activities and cost principles requirements.
Cause: A written policy and procedures over documenting internal control(s) over allowable activities and
cost principles was not designed and implemented.
Effect or Potential Effect: Costs charged to the federal award are more likely to be for unallowable activities
and not comply with allowable cost principles. These costs may be disallowed.
Context: Salesforce is used to document disbursements, but was not set up to document internal control
procedures.
Repeat Finding: No
Recommendation: All disbursements charged to the federal award should have documentation to support
internal controls performed for allowable activities and cost principles. Written policies and procedures
should be designed and implemented for documentation of internal controls performed for allowable
activities and cost principles.
Views of Responsible Officials: The organization agrees with the finding.
Assistance Listing Number(s): 84.425V
Name of Federal Program or Cluster: COVID-19 Education Stabilization Fund (ESF), American Rescue
Plan – Emergency Assistance to Non-Public Schools (ARP EANS)
Name of Federal Agency: Department of Education
Federal Award Identification Number: S425V210042
Federal Award Date: February 26, 2021 and September 24, 2021
Name of Pass-through Entity: State of North Carolina
Pass-through Entity Identifying Number: 60-04 and 60-05
Award Period: July 1, 2022 through September 30, 2023 and July 1, 2022 through September 30, 2024
Criteria: Uniform Guidance 2 CFR 200.303(a) requires the non-federal entity to 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.
Condition: 2 out of 4 financial reports tested did not have an internal control documented that supported
reasonable assurance of compliance with reporting requirements.
Cause: A written policy and procedures over documenting internal control(s) over reporting was not
designed and implemented.
Effect or Potential Effect: Reports may be incomplete or inaccurate.
Repeat Finding: No
Recommendation: Internal control should be documented to ensure compliance with the reporting
compliance requirement. Documentation should include a signed certification by the preparer and a
reviewer that the requests for payment, written summaries of reporting-specific meetings with grantors, and
any other reporting activities are complete, accurate, and agree to supporting records of expenditures or
other accounting or database information. Written policies and procedures should be designed and
implemented for documentation of internal controls performed for reporting.
Views of Responsible Officials: The organization agrees with the finding.
Assistance Listing Number(s): 84.425V
Name of Federal Program or Cluster: COVID-19 Education Stabilization Fund (ESF), American Rescue
Plan – Emergency Assistance to Non-Public Schools (ARP EANS)
Name of Federal Agency: Department of Education
Federal Award Identification Number: S425V210042
Federal Award Date: February 26, 2021 and September 24, 2021
Name of Pass-through Entity: State of North Carolina
Pass-through Entity Identifying Number: 60-04 and 60-05
Award Period: July 1, 2022 through September 30, 2023 and July 1, 2022 through September 30, 2024
Criteria: Uniform Guidance 2 CFR 200.430 requires charges to federal awards for compensation must be
based on records that accurately reflect the work performed.
Condition: 2 out of a total of 11 employees’ compensation and benefits charged to the federal award for the
fiscal year were not supported by time and effort documentation. 13 out of the total 43 quarterly
compensation and benefits charged were greater than the amount supported by the time and effort
documentation. A total of $278,803 of personnel and fringe were charged to the federal award.
Cause: Budgeted amounts were used, but no system of review and adjustments to actual were performed.
A written policy and procedures over documenting time and effort was not designed and implemented.
Effect or Potential Effect: Unsupported compensation and benefits charged to the program may be
disallowed.
Questioned Costs: $21,249 for the compensation costs and related employee benefits charged for the 2
employees that were not supported by time and effort documentation. $20,472 for the 13 quarterly
compensation and related benefits that were greater than the time and effort documentation supported.
Context: For the audit all employees whose compensation and benefits were charged to the federal award
retroactively provided signed quarterly time and effort documentation. These documentations were
reviewed and approved by their supervisors. Auditor viewed all 11 employees quarterly time and effort
documentation. While there were 13 quarterly compensation and benefits charges that were greater than the amount supported, there were 14 quarterly compensation and benefits that were undercharged by
$35,871.
Repeat Finding: No
Recommendation: Time and effort documentation be documented per Uniform Guidance requirements and
used to review and adjust budgeted compensation and benefit costs charged to the award to be accurate,
allowable, and properly allocated. Written policies and procedures should be designed and implemented
for documentation of time and effort.
Views of Responsible Officials: The organization agrees with the finding.
Assistance Listing Number(s): 84.425V
Name of Federal Program or Cluster: COVID-19 Education Stabilization Fund (ESF), American Rescue
Plan – Emergency Assistance to Non-Public Schools (ARP EANS)
Name of Federal Agency: Department of Education
Federal Award Identification Number: S425V210042
Federal Award Date: February 26, 2021 and September 24, 2021
Name of Pass-through Entity: State of North Carolina
Pass-through Entity Identifying Number: 60-04 and 60-05
Award Period: July 1, 2022 through September 30, 2023 and July 1, 2022 through September 30, 2024
Criteria: Uniform Guidance 2 CFR 200.303(a) requires the non-federal entity to 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.
Condition: 54 of 60 disbursements sampled did not have documented internal control that supported
reasonable assurance of compliance with allowable activities and cost principles requirements.
Cause: A written policy and procedures over documenting internal control(s) over allowable activities and
cost principles was not designed and implemented.
Effect or Potential Effect: Costs charged to the federal award are more likely to be for unallowable activities
and not comply with allowable cost principles. These costs may be disallowed.
Context: Salesforce is used to document disbursements, but was not set up to document internal control
procedures.
Repeat Finding: No
Recommendation: All disbursements charged to the federal award should have documentation to support
internal controls performed for allowable activities and cost principles. Written policies and procedures
should be designed and implemented for documentation of internal controls performed for allowable
activities and cost principles.
Views of Responsible Officials: The organization agrees with the finding.
Assistance Listing Number(s): 84.425V
Name of Federal Program or Cluster: COVID-19 Education Stabilization Fund (ESF), American Rescue
Plan – Emergency Assistance to Non-Public Schools (ARP EANS)
Name of Federal Agency: Department of Education
Federal Award Identification Number: S425V210042
Federal Award Date: February 26, 2021 and September 24, 2021
Name of Pass-through Entity: State of North Carolina
Pass-through Entity Identifying Number: 60-04 and 60-05
Award Period: July 1, 2022 through September 30, 2023 and July 1, 2022 through September 30, 2024
Criteria: Uniform Guidance 2 CFR 200.303(a) requires the non-federal entity to 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.
Condition: 2 out of 4 financial reports tested did not have an internal control documented that supported
reasonable assurance of compliance with reporting requirements.
Cause: A written policy and procedures over documenting internal control(s) over reporting was not
designed and implemented.
Effect or Potential Effect: Reports may be incomplete or inaccurate.
Repeat Finding: No
Recommendation: Internal control should be documented to ensure compliance with the reporting
compliance requirement. Documentation should include a signed certification by the preparer and a
reviewer that the requests for payment, written summaries of reporting-specific meetings with grantors, and
any other reporting activities are complete, accurate, and agree to supporting records of expenditures or
other accounting or database information. Written policies and procedures should be designed and
implemented for documentation of internal controls performed for reporting.
Views of Responsible Officials: The organization agrees with the finding.
Assistance Listing Number(s): 84.425V
Name of Federal Program or Cluster: COVID-19 Education Stabilization Fund (ESF), American Rescue
Plan – Emergency Assistance to Non-Public Schools (ARP EANS)
Name of Federal Agency: Department of Education
Federal Award Identification Number: S425V210042
Federal Award Date: February 26, 2021 and September 24, 2021
Name of Pass-through Entity: State of North Carolina
Pass-through Entity Identifying Number: 60-04 and 60-05
Award Period: July 1, 2022 through September 30, 2023 and July 1, 2022 through September 30, 2024
Criteria: Uniform Guidance 2 CFR 200.430 requires charges to federal awards for compensation must be
based on records that accurately reflect the work performed.
Condition: 2 out of a total of 11 employees’ compensation and benefits charged to the federal award for the
fiscal year were not supported by time and effort documentation. 13 out of the total 43 quarterly
compensation and benefits charged were greater than the amount supported by the time and effort
documentation. A total of $278,803 of personnel and fringe were charged to the federal award.
Cause: Budgeted amounts were used, but no system of review and adjustments to actual were performed.
A written policy and procedures over documenting time and effort was not designed and implemented.
Effect or Potential Effect: Unsupported compensation and benefits charged to the program may be
disallowed.
Questioned Costs: $21,249 for the compensation costs and related employee benefits charged for the 2
employees that were not supported by time and effort documentation. $20,472 for the 13 quarterly
compensation and related benefits that were greater than the time and effort documentation supported.
Context: For the audit all employees whose compensation and benefits were charged to the federal award
retroactively provided signed quarterly time and effort documentation. These documentations were
reviewed and approved by their supervisors. Auditor viewed all 11 employees quarterly time and effort
documentation. While there were 13 quarterly compensation and benefits charges that were greater than the amount supported, there were 14 quarterly compensation and benefits that were undercharged by
$35,871.
Repeat Finding: No
Recommendation: Time and effort documentation be documented per Uniform Guidance requirements and
used to review and adjust budgeted compensation and benefit costs charged to the award to be accurate,
allowable, and properly allocated. Written policies and procedures should be designed and implemented
for documentation of time and effort.
Views of Responsible Officials: The organization agrees with the finding.
Assistance Listing Number(s): 84.425V
Name of Federal Program or Cluster: COVID-19 Education Stabilization Fund (ESF), American Rescue
Plan – Emergency Assistance to Non-Public Schools (ARP EANS)
Name of Federal Agency: Department of Education
Federal Award Identification Number: S425V210042
Federal Award Date: February 26, 2021 and September 24, 2021
Name of Pass-through Entity: State of North Carolina
Pass-through Entity Identifying Number: 60-04 and 60-05
Award Period: July 1, 2022 through September 30, 2023 and July 1, 2022 through September 30, 2024
Criteria: Uniform Guidance 2 CFR 200.303(a) requires the non-federal entity to 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.
Condition: 54 of 60 disbursements sampled did not have documented internal control that supported
reasonable assurance of compliance with allowable activities and cost principles requirements.
Cause: A written policy and procedures over documenting internal control(s) over allowable activities and
cost principles was not designed and implemented.
Effect or Potential Effect: Costs charged to the federal award are more likely to be for unallowable activities
and not comply with allowable cost principles. These costs may be disallowed.
Context: Salesforce is used to document disbursements, but was not set up to document internal control
procedures.
Repeat Finding: No
Recommendation: All disbursements charged to the federal award should have documentation to support
internal controls performed for allowable activities and cost principles. Written policies and procedures
should be designed and implemented for documentation of internal controls performed for allowable
activities and cost principles.
Views of Responsible Officials: The organization agrees with the finding.
Assistance Listing Number(s): 84.425V
Name of Federal Program or Cluster: COVID-19 Education Stabilization Fund (ESF), American Rescue
Plan – Emergency Assistance to Non-Public Schools (ARP EANS)
Name of Federal Agency: Department of Education
Federal Award Identification Number: S425V210042
Federal Award Date: February 26, 2021 and September 24, 2021
Name of Pass-through Entity: State of North Carolina
Pass-through Entity Identifying Number: 60-04 and 60-05
Award Period: July 1, 2022 through September 30, 2023 and July 1, 2022 through September 30, 2024
Criteria: Uniform Guidance 2 CFR 200.303(a) requires the non-federal entity to 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.
Condition: 2 out of 4 financial reports tested did not have an internal control documented that supported
reasonable assurance of compliance with reporting requirements.
Cause: A written policy and procedures over documenting internal control(s) over reporting was not
designed and implemented.
Effect or Potential Effect: Reports may be incomplete or inaccurate.
Repeat Finding: No
Recommendation: Internal control should be documented to ensure compliance with the reporting
compliance requirement. Documentation should include a signed certification by the preparer and a
reviewer that the requests for payment, written summaries of reporting-specific meetings with grantors, and
any other reporting activities are complete, accurate, and agree to supporting records of expenditures or
other accounting or database information. Written policies and procedures should be designed and
implemented for documentation of internal controls performed for reporting.
Views of Responsible Officials: The organization agrees with the finding.