2024-001 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: District of Columbia Office of the State Superintendent of Education Award Period: May 25, 2022 - September 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have documentation supporting the internal controls for the approval of personnel costs charged to federal programs for the time and effort employees spend working on the respective programs of the Organization. Condition: During our testing of payroll transactions for the major federal program, we were unable review the internal control of approved timesheets for any part time employees and seasonal employees with payroll periods selected for testing through September 2024. Questioned costs: None Context: During our testing of payroll transactions for the major federal program, we were unable review the internal control of approved timesheets for any part time employees and seasonal employees with payroll periods selected for testing through September 2024. The Organization changed payroll service providers in September 2024 and could no longer access the timesheets requested. Cause: The Organization changed payroll providers in September 2024 and no longer have access to obtain information from the previous payroll provider. Effect: If the organization does not have adequate controls in place and documented, it could result in employees being funded with federal awards in which they did not actually perform work. SPRINGBOARD COLLABORATIVE SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED DECEMBER 31, 2024 (28) Repeat Finding: N/A: Not a repeat finding. Recommendation: The Organization should ensure when there are changes in the Organizations service providers, there are procedures in place to ensure all necessary documentation is retained to support the controls in place for federal spending. Views of responsible officials: Please refer to Springboard Collaborative’s Corrective Action Plan.
2024-002 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: District of Columbia Office of the State Superintendent of Education Award Period: May 25, 2022 - September 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: According to the funding agency's guidelines, all financial and performance reports must be reviewed and approved by the designated authority before submission. This ensures accuracy, compliance, and accountability. Condition: During our testing, we noted that financial and performance reports submitted to the funding agency lacked the required approval prior to submission to the funding agency. Specifically, there was no evidence of review or authorization by the designated authority. Questioned costs: None Context: During our testing, we noted there was a lack of approval prior to submission to the funding agency for five financial and three performance reports tested during the audit. Cause: The lack of approval appears to be due to inadequate internal controls and oversight within the reporting process. There may be a lack of awareness or understanding of the approval requirements among staff responsible for report preparation. Effect: Without proper documentation of approval, there is a risk of non-compliance with the funding agency's guidelines. This could lead to potential issues such as delays in funding, questioning of the report's validity, and a lack of accountability for the information provided in the reports. SPRINGBOARD COLLABORATIVE SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED DECEMBER 31, 2024 (29) Repeat Finding: N/A: Not a repeat finding Recommendation: We recommend that the organization implement a formal review and approval process for all financial and performance reports submitted to the funding agency. This process should include clear guidelines and training for staff to ensure that all reports are reviewed and approved by the designated authority before submission. Additionally, regular audits should be conducted to verify compliance with the documentation requirements. Views of responsible officials: Please refer to Springboard Collaborative’s Corrective Action Plan.
2024-003 Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: District of Columbia Office of the State Superintendent of Education Award Period: May 25, 2022 - September 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: According to the Uniform Guidance (2 CFR Part 200), non-federal entities are required to establish and maintain effective internal controls over the procurement process. This includes having a documented procurement policy that ensures compliance with federal regulations, promotes fair competition, and prevents conflicts of interest. Condition: During our review, we noted that the organization does not have a documented procurement policy in place. This absence of a formal policy means that procurement activities are not guided by standardized procedures or controls. Questioned costs: None Context: The organization receives federal funding and is therefore subject to the requirements of the Uniform Guidance. A procurement policy is essential to ensure that all procurement activities are conducted in a manner that is consistent with federal regulations and best practices. Cause: The lack of a procurement policy appears to be due to oversight and a lack of awareness of the requirements under the Uniform Guidance. There may also be resource constraints that have prevented the development and implementation of such a policy. SPRINGBOARD COLLABORATIVE SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED DECEMBER 31, 2024 (30) Effect: The absence of a procurement policy increases the risk of noncompliance with federal regulations, potential financial mismanagement, and conflicts of interest. It also undermines the integrity and transparency of the procurement process, which could lead to unfavorable audit findings and potential loss of funding. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend that the organization develop and implement a comprehensive procurement policy that aligns with the Uniform Guidance. This policy should include clear procedures for procurement planning, solicitation, evaluation, and contract management; provisions to ensure fair competition and prevent conflicts of interest; training for staff on the procurement policy and federal requirements; and regular reviews and updates to the policy to ensure ongoing compliance. Views of responsible officials: Please refer to Springboard Collaborative’s Corrective Action Plan.