Finding No.: 2024-003 Federal Agency: U.S. Department of Agriculture AL Program: 10.555 Child Nutrition Cluster Federal Award No.: 7GU300GUB Area: Eligibility Questioned Costs: $0 Criteria: In accordance with the National School Lunch Act, state agencies are required to annually notify local educational agencies (LEAs) of district-wide eligibility for the community eligibility provision (CEP). By May 1 of each year, state agencies must publish lists of eligible and near- eligible LEAs and schools on their state agency websites. Condition: GDOE functions both as State Educational Agency (SEA) and LEA. As a state agency, it is required to fulfil the above criteria. As of December 4, 2025, the annual notification for School Year (SY) 2023-2024 and SY 2024-2025 was not published on GDOE’s website. Specifically, the lists of eligible and near-eligible LEAs and schools was not published on GDOE’s website. Furthermore, documentation of CEP approval was not provided. Cause: GDOE did not enforce controls over compliance with the applicable eligibility requirements relative to annual notifications and publications and retaining documentation of CEP approval. Effect: GDOE is in noncompliance with applicable eligibility requirements. No questioned cost is presented as non-compliance is related to a disclosure requirement and is not specific to a particular cost. Identified as a Repeat Finding: 2023-004 Recommendation: GDOE should establish and implement internal controls over compliance with applicable eligibility requirements. Responsible personnel should prepare and publish required notifications and retain documentation of CEP approval.
Finding No.: 2024-004 Federal Agency: U.S. Department of Agriculture AL Program: 10.555 Child Nutrition Cluster Federal Award No.: 7GU300GUB, 7GU320GU3, 237GUGU3N8903 Area: Reporting Questioned Costs: $0 Criteria: The School Food Authority (SFA) must submit SF-425 Federal Financial Report quarterly related to Supply Chain Assistance fund. Further, financial reports should be traceable to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Conditions: 1. The following quarterly SF-425 for Supply Chain Assistance fund were not prepared and submitted during fiscal year 2024: Award # Quarter Ended 7GU320GU3 December 31, 2023 7GU320GU3 March 31, 2024 7GU320GU3 June 30, 2024 237GUGU3N8903 September 30, 2023 237GUGU3N8903 December 31, 2023 237GUGU3N8903 March 31, 2024 237GUGU3N8903 June 30, 2024 Finding No.: 2024-004, continued Federal Agency: U.S. Department of Agriculture AL Program: 10.555 Child Nutrition Cluster Federal Award No.: 7GU300GUB, 7GU320GU3, 237GUGU3N8903 Area: Reporting Questioned Costs: $0 Conditions, continued: 2. We noted variances between the expenditures reported in Financial Status Report FNS 777 against the underlying accounting records as summarized below: STATUS OF FUNDS Reported during FY24 QTR 3 - (04/01/24 - 06/30/24) Total per Expenditure Details Over (Under) Reported variance PROGRAMS/FUNCTIONS/ACTIVITIES Net outlays previously reported $7,947,328 $9,014,236 ($1,066,908) Total outlays this report period 1,434,331 2,395,557 ( 961,226) Less: Program income credits - - - Net outlays this report period (Line b minus line c) 1,434,331 2,395,557 ( 961,226) Net outlays to date (Line a plus line d) 9,381,659 11,409,793 (2,028,134) Less: Non-Federal Share of outlays - - - Total Federal share of outlays (Line e minus line f) 9,381,659 11,409,793 (2,028,134) Total unliquidated obligations 3,811,238 5,355,508 (1,544,270) Less: Non-Federal Share of unliquidated obligations shown on line h - - - Federal share of unliquidated obligations 3,811,238 5,355,508 (1,544,270) Total Federal share of outlays and unliquidated obligations 13,192,897 16,765,301 (3,572,404) Total cumulative amount of Federal fund authorized 12,239,790 12,239,790 - Unobligated balance of Federal funds ($ 953,107) ($ 4,525,511) $ 3,572,404 3. Subawards are not reported in FSRS, as follows: Transactions Tested Subaward Not Reported Dollar Amount of Tested Transactions Subaward Not Reported 2 2 $609,093 $609,093 Finding No.: 2024-004, continued Federal Agency: U.S. Department of Agriculture AL Program: 10.555 Child Nutrition Cluster Federal Award No.: 7GU300GUB, 7GU320GU3, 237GUGU3N8903 Area: Reporting Questioned Costs: $0 Cause: GDOE lacks controls over compliance with applicable reporting requirements. Effect: GDOE is in noncompliance with applicable reporting requirements. No questioned cost is presented as the non-compliance was related to reporting requirements. Identified as a Repeat Finding: 2023-006 Recommendation: Responsible personnel should establish and implement controls over compliance with applicable reporting requirements relative to submitting quarterly SF-425, accurate reporting of FNS-777 and reporting subawards in FSRS.
Finding No.: 2024-005 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Grants to States Area: Equipment and Real Property Management Questioned Costs: $1,391 Criteria: FY2024 U.S. Department of Education Special Conditions, paragraph (5) states that “GDOE must ensure that all tangible personal property procured under Department grants is managed in accordance with the requirements of 2 CFR 200.313(a) and (c)-(e ) to ensure that such property is properly inventoried, maintained, and stored to prevent loss, damage, or theft of such property”. 2 CFR 200.313(d) states that regardless of whether equipment is acquired in part or its entirety under the Federal award, the recipient must manage equipment (including replacement equipment) utilizing procedures that meet the requirement of having a control system in place to ensure safeguards for preventing property loss, damage, or theft. Any loss, damage, or theft of equipment must be investigated. The recipient or subrecipient must notify the Federal agency or pass-through entity of any loss, damage, or theft of equipment that will have an impact on the program. Condition: For four (or 10%) of forty items totaling with a net book value of $545,378 subjected to equipment safeguarding test, items were tagged as “A” or active in the property record, however, they were not physically inspected as it was noted to be missing during the audit. Item # Federal Award # Asset # Description Net Book Value Questioned Cost 1 H027A120013 14101 Insprio Premium with ILapel $ - $ - 2 H027A180013 39573 RIFTON SMALL PACER GAIT TRAINER (RED) $ 58 58 3 H027A190013-19A 78062 OTICON XCEED PLAY 2 HEARING AID $ 313 313 4 H027X210013 98153 OTICON XCEED 1 HEARING AIDE $1,020 1,020 $1,391 Cause: Responsible personnel did not properly safeguard the assets and were not made aware that assets are lost, hence, information on the property records were outdated. Finding No.: 2024-005, continued Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Grants to States Area: Equipment and Real Property Management Questioned Costs: $1,391 Effect: GDOE is in noncompliance with applicable equipment and real property management requirements. Questioned costs of $1,391 was calculated based on the net book value of the equipment identified in the condition. Recommendation: Responsible personnel should enforce monitoring controls over compliance with applicable equipment and real property management requirements, specifically, ensuring safeguards for preventing property loss, damage, or theft.
Finding No.: 2024-006 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Grants to States Area: Period of Performance Questioned Costs: $39,665 Criteria: In accordance with applicable period of performance (POP) requirements, a non-federal entity may charge only allowable costs incurred during a federal award’s period of performance. Unless the federal awarding agency authorizes an extension, a non-federal entity must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award or in the approved extension. Furthermore, 2 CFR 200.303(a) states that the recipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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 COSO. Conditions: Of sixty items, aggregating $384,666 of $3,198,523 of expenditures subjected to period of performance test, deficiencies were noted, as follows: 1. For 4 items or (7%), GDOE charged costs to a federal award after the period of performance ended and liquidated obligations of a federal award after the approved liquidation end date: Federal Award No. Purchase Order/ Invoice No. Invoice Date POP End Date Liquidation End Date Liquidation Date Expenditures Questioned Costs H027A210013 20232230 08/27/2024 09/30/2023 01/28/2024 08/01/2025 3,240 3,240 H027A220013 20233151 01/28/2025 09/30/2024 01/28/2025 Not yet paid 17,953 17,953 H027A220013 20233151 01/28/2025 09/30/2024 01/28/2025 Not yet paid 10,636 10,636 H027A220013 20240021 04/29/2025 09/30/2024 01/28/2025 Not yet paid 7,408 7,408 $39,237 $39,237 Finding No.: 2024-006, continued Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Grants to States Area: Period of Performance Questioned Costs: $39,665 Conditions, continued: 2. For 1 item or (2%), compliance with period of performance of expenditure (PO# 20241462) amounting to $428 could not be determined as supporting documents such as an invoice or canceled check was not made available for examination. 3. There is no review in place to ensure that liquidation of the obligation occur within the allowable time period. Cause: GDOE did not enforce monitoring controls over compliance with applicable period of performance requirements relating to charging of costs to a federal award within the period of performance. Also, GDOE’s internal control policies and procedures in place are not suitably designed to ensure that liquidation of the obligation occurs within the allowable time period. Effect: GDOE is in noncompliance with applicable period of performance requirements. The reportable questioned cost is $39,665. Identified as a Repeat Finding: 2023-009 Recommendation: Responsible personnel should enforce monitoring controls over compliance with applicable period of performance requirements. Prior to charging costs to a federal award or liquidating obligations incurred under a federal award, responsible personnel should verify that the period of performance, including the liquidation end date, has not expired. Views of Responsible Officials: The Division of Special Education is currently reviewing the details of the finding in order to provide an adequate response and corrective action plan.
Finding No.: 2024-007 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Grants to States Federal Award No.: H027A220013, H027A230013 Area: Procurement and Suspension and Debarment Questioned Costs: $0 Criteria: 2 CFR 200.318(a) states the recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §§ 200.317 through 200.327. Accordingly, documented procedures must ensure consistency to standards in 2 CFR 200.324(a) which articulates that the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. Condition: GDOE does not have procurement policies that meet the requirements of 2 CFR 200.318(a) and 2 CFR 200.324(a). Specifically, GDOE lacks documented procedures to ensure compliance with procurement transactions under a Federal award or subaward, requiring the performance and retention of cost price analysis for procurement transactions above the simplified acquisition threshold. Cause: GDOE lacks adequate internal control over periodic review of procurement policies, specifically, ensuring all required key provisions from the Compliance Supplement are included in the procurement policies. Effect: GDOE is in noncompliance with applicable procurement and suspension and debarment requirements. No questioned cost is presented because our procedures did not identify procurement of goods or services that would have required a cost price analysis in the current fiscal year. Recommendation: GDOE should revisit its procurement policies and ensure all required provisions stated in the Compliance Supplement are covered.
Finding No.: 2024-008 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grant to the Outlying Area Area: Cash Management Questioned Costs: $112,652 Criteria: FY2024 U.S. Department of Education Special Conditions, states that since GDOE is managing its Department funds independently without Third-Party Fiduciary Agent (TPFA) oversight, GDOE must continue to fulfill the responsibilities that were previously performed by the TPFA. Responsibilities performed by TPFA per FY2023 U.S. Department of Education Special Conditions, Responsibilities and Requirements of the TPFA, states that “the Agent must pay vendors for the delivered goods or services and must, to the extent possible, disburse funds to the vendors on the same day the funds are deposited.” Condition: For forty-two (or 13%) of three hundred seventeen items, aggregating $8,989,530 of $28,876,832 in total cash draws, vendor was not paid either on the same day or within 24 hours after fund has been received, as follows: Item # Federal Award # Cash Draw Log # Check # Bank Clearance Date (Receipt of Fund) Check Date (Payment to Vendor) Questioned Cost 1 S403A220002 DOEAM093 711239 06/10/2024 06/12/2024 $ 31,137 2 S403A220002 DOEAM092 711238 06/10/2024 06/12/2024 6,832 3 S403A220002 DOEAM092 711238 06/10/2024 06/12/2024 6,832 4 S403A220002 DOEAM089 171717 06/10/2024 06/12/2024 3,468 5 S403A220002 DOEAM089 171717 06/10/2024 06/12/2024 3,468 6 S403A220002 DOEAM089 171717 06/10/2024 06/12/2024 3,468 7 S403A220002 DOEAM089 171717 06/10/2024 06/12/2024 3,468 8 S403A220002 DOEAM089 171719 06/10/2024 06/12/2024 1,258 9 S403A220002 DOEAM089 711234 06/10/2024 06/12/2024 1,080 10 S403A220002 DOEAM089 711231 06/10/2024 06/12/2024 899 11 S403A220002 DOEAM089 711234 06/10/2024 06/12/2024 705 12 S403A220002 DOEAM089 711233 06/10/2024 06/12/2024 525 13 S403A220002 DOEAM089 711234 06/10/2024 06/12/2024 480 14 S403A220002 DOEAM089 711234 06/10/2024 06/12/2024 330 15 S403A220002 DOEAM089 171718 06/10/2024 06/12/2024 324 16 S403A220002 DOEAM089 711234 06/10/2024 06/12/2024 255 17 S403A220002 DOEAM093 171721 06/10/2024 06/12/2024 185 18 S403A220002 DOEAM093 171721 06/10/2024 06/12/2024 41 19 S403A220002 DOEAM156 712181 10/01/2024 10/03/2024 24,520 Finding No.: 2024-008, continued Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grant to the Outlying Area Area: Cash Management Questioned Costs: $112,652 Condition, continued: Item # Federal Award # Cash Draw Log # Check # Bank Clearance Date (Receipt of Fund) Check Date (Payment to Vendor) Questioned Cost 20 S403A220002 / S403A230002 DOEAM156 172632 10/01/2024 10/03/2024 7,535 21 S403A220002 / S403A230002 DOEAM156 172633 10/01/2024 10/03/2024 2,790 22 S403A220002 / S403A230002 DOEAM156 712178 10/01/2024 10/03/2024 2,160 23 S403A220002 / S403A230002 DOEAM156 712178 10/01/2024 10/03/2024 1,440 24 S403A220002 / S403A230002 DOEAM156 172632 10/01/2024 10/03/2024 1,370 25 S403A220002 / S403A230002 DOEAM156 172632 10/01/2024 10/03/2024 1,370 26 S403A220002 / S403A230002 DOEAM156 712181 10/01/2024 10/03/2024 1,280 27 S403A220002 / S403A230002 DOEAM156 172632 10/01/2024 10/03/2024 1,270 28 S403A220002 / S403A230002 DOEAM156 712181 10/01/2024 10/03/2024 1,159 29 S403A220002 / S403A230002 DOEAM156 712178 10/01/2024 10/03/2024 792 30 S403A220002 / S403A230002 DOEAM156 712178 10/01/2024 10/03/2024 630 31 S403A220002 / S403A230002 DOEAM156 712167 10/01/2024 10/03/2024 523 32 S403A220002 / S403A230002 DOEAM156 712182 10/01/2024 10/03/2024 159 33 S403A220002 / S403A230002 DOEAM156 712174 10/01/2024 10/03/2024 140 34 S403A220002 / S403A230002 DOEAM156 172631 10/01/2024 10/03/2024 139 35 S403A220002 / S403A230002 DOEAM156 712178 10/01/2024 10/03/2024 120 36 S403A220002 / S403A230002 DOEAM156 712183 10/01/2024 10/03/2024 105 37 S403A220002 / S403A230002 DOEAM156 712170 10/01/2024 10/03/2024 96 38 S403A220002 / S403A230002 DOEAM156 172634 10/01/2024 10/03/2024 96 39 S403A220002 / S403A230002 DOEAM156 712180 10/01/2024 10/03/2024 62 40 S403A220002 / S403A230002 DOEAM156 712178 10/01/2024 10/03/2024 60 41 S403A220002 / S403A230002 DOEAM156 712169 10/01/2024 10/03/2024 54 42 S403A220002 / S403A230002 DOEAM156 712175 10/01/2024 10/03/2024 27 $112,652 Cause: GDOE lacks established internal control policies and procedures to disburse funds received from US Department of Education to the vendors on the same day the funds are deposited. The current Standard Operating Procedures (SOPs) do not effectively incorporate transitioned roles and responsibilities of the Third Party Fiduciary Agent (TPFA) for accountability to the specific conditions set by the US Department of Education, wherein management was not aware of this requirement. Finding No.: 2024-008, continued Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grant to the Outlying Area Area: Cash Management Questioned Costs: $112,652 Effect: GDOE is in noncompliance with applicable cash management requirements. The reportable questioned cost is $112,652. Recommendation: GDOE should establish internal control policies and procedures over compliance with applicable cash management requirements, specifically, disbursing funds to the vendors on the same day the funds are deposited.
Finding No.: 2024-009 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grant to the Outlying Area Area: Procurement and Suspension and Debarment Questioned Costs: $6,918 Criteria: 2 CFR 200.319 states that: (a) All procurement transactions under the Federal award must be conducted in a manner that provides full and open competition and is consistent with the standards of this section and 2 CFR 200.320. (c) (6) Examples of situations that may restrict competition include specifying only a “brand name” product instead of allowing “an equal” product to be offered and describing the performance or other relevant requirements of the procurement. (d) (2) The recipient or subrecipient must have written procedures for procurement transactions. These procedures must ensure that all solicitations incorporate a clear and accurate description of the technical requirements for the property, equipment, or service being procured. The description may include a statement of the qualitative nature of the property, equipment, or service to be procured. When necessary, the description must provide minimum essential characteristics and standards to which the property, equipment, or service must conform. Detailed product specifications should be avoided if at all possible. When it is impractical or uneconomical to clearly and accurately describe the technical requirements, a “brand name or equivalent” description of features may be used to provide procurement requirements. The specific features of the named brand must be clearly stated. 2 CFR 200.324(a) states that recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. Finding No.: 2024-009, continued Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grant to the Outlying Area Area: Procurement and Suspension and Debarment Questioned Costs: $6,918 Conditions: 1. Of thirty-nine items, aggregating $426,960 of $9,005,697 of expenditures subjected to procurement test, deficiencies were noted, as follows: a. For 1 item (or 3%), procurement did not provide full and open competition in the solicitation process. The request for quotation specified particular model, including a requirement for a specific “brand name” product instead of allowing “an equal” product to be offered. Item # Federal Award No. Purchase Order Expenditures Questioned Costs 1 S403A220002 20240435 $12,447 $6,918 2. GDOE does not have procurement policies that meet the requirements of 2 CFR 200.318(a) and 2 CFR 200.324(a). Specifically, GDOE lacks documented procedures to ensure compliance with procurement transactions under a Federal award or subaward, requiring the performance and retention of cost price analysis for procurement transactions above the simplified acquisition threshold. Cause: GDOE did not enforce monitoring controls over compliance with applicable procurement requirements. Also, GDOE lacks adequate internal controls over periodic review of procurement policies, specifically, ensuring all required key provisions from the Compliance Supplement are included in the procurement policies. Effect: GDOE is in noncompliance with applicable procurement and suspension and debarment requirements. The reportable questioned cost is $6,918. Also, we did not identify procurement of goods or services that would have required a cost price analysis. Finding No.: 2024-009, continued Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grant to the Outlying Area Area: Procurement and Suspension and Debarment Questioned Costs: $6,918 Recommendation: Responsible personnel should enforce monitoring controls over compliance with applicable procurement requirements. Also, GDOE should revisit its procurement policies and ensure all required provisions stated in the Compliance Supplement are covered.
Finding No.: 2024-010 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund ED Subprogram: 84.425X American Rescue Plan – Outlying Areas State Educational Agency (ARP-OA-SEA) Federal Award No.: S425X210003 Area: Equipment and Real Property Management Questioned Costs: $1,842 Criteria: FY2024 U.S. Department of Education Special Conditions, paragraph (5) states that “GDOE must ensure that all tangible personal property procured under Department grants is managed in accordance with the requirements of 2 CFR 200.313(a) and (c)-(e ) to ensure that such property is properly inventoried, maintained, and stored to prevent loss, damage, or theft of such property”. 2 CFR 200.313(d) states that regardless of whether equipment is acquired in part or its entirety under the Federal award, the recipient must manage equipment (including replacement equipment) utilizing procedures that meet the requirement of having property records that include a description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use and condition of the property, and any disposition data including the date of disposal and sale price of the property. Condition: For one (or 3%) of forty items, aggregating $84,774 of $5,480,631 in total cost of assets subjected to equipment acquisition test, cost of asset was incorrectly recorded in the property records. Asset # Description Cost per Property Record Cost per Invoice Variance Questioned Cost 99813 APPLE A2696 10.9" IPAD $1,842 $533 $1,309 $1,842 Finding No.: 2024-010, continued Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund ED Subprogram: 84.425X American Rescue Plan – Outlying Areas State Educational Agency (ARP-OA-SEA) Federal Award No.: S425X210003 Area: Equipment and Real Property Management Questioned Costs: $1,842 Cause: Responsible personnel did not properly record the cost of the asset in the property records. Effect: GDOE is in noncompliance with applicable equipment and real property management requirements. Questioned cost is calculated as the value of the asset that was accumulated in the equipment listing and recorded as expenditure in the current fiscal year. Recommendation: Responsible personnel should ensure that asset information are accurately captured in the property records.
Finding No.: 2024-011 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund ED Subprogram: 84.425X American Rescue Plan – Outlying Areas State Educational Agency (ARP-OA-SEA) Federal Award No.: S425X210003 Area: Matching, Level of Effort, Earmarking Questioned Costs: $825,567 Criteria: In accordance to the ARP-OA SEA Grant Conditions for Part A: Programmatic, Fiscal and Reporting Assurances to ARP-OA SEA Guam Department of Education, the Outlying Area State Educational Agencies (SEAs) must reserve not less than 20 percent of their ARP-OA SEA allocation to carry out, directly or through subgrants or contracts, activities to address the academic impact of lost instructional time by supporting the implementation of evidence-based interventions. As issued in the Frequently Asked Questions for Outlying Areas Education Stabilization Fund and American Rescue Plan Programs for State Educational Agencies & Outlying Areas Education Stabilization Fund Governors Program issued by the U.S. Department of Education dated November 2021, answer A-4 states the following: Use of ARP-OA SEA Funds to Address the Academic Impact of Lost Instructional Time. The SEA will use not less than 20 percent of its ARP-OA SEA allocation to carry out, directly or through subgrants to LEAs or through contracts, activities to address the academic impact of lost instructional time through the implementation of evidence-based interventions, such as summer learning or summer enrichment, extended day, comprehensive afterschool programs, or extended school year programs, and ensure that such interventions respond to students’ social, emotional, mental health, and academic needs and address the disproportionate impact of COVID-19 on underrepresented student subgroups (each major racial and ethnic group, economically disadvantaged students, children with disabilities, English learners, gender, migrant students), students experiencing homelessness, and children and youth in foster care, including by providing additional support to LEAs, as applicable, to fully address such impacts. Finding No.: 2024-011, continued Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund ED Subprogram: 84.425X American Rescue Plan – Outlying Areas State Educational Agency (ARP-OA-SEA) Federal Award No.: S425X210003 Area: Matching, Level of Effort, Earmarking Questioned Costs: $825,567 Criteria, continued: C-2. How may an Outlying Area use ESF-SEA, ESF-Governor, and ARP-OA SEA funds to support students who have lost instructional time due to the COVID-19 pandemic? states the following: ESF-SEA, ESF-Governor, and ARP-OA SEA funds may be used to provide a variety of activities and supports to help improve the achievement of students to address the impact of lost instructional time due to the COVID-19 pandemic. For example, funds may be used for costs associated with evidence-based approaches to accelerating learning, high-dose tutoring, leveraging technology to provide embedded assessment and differentiated instruction, diagnostic and curriculum-embedded assessments, and extending the school day or year to provide additional time for student learning, enrichment, and support. These costs may include supplementing the salaries of educators and other qualified personnel to perform additional services. ESF-SEA, ESF-Governor, and ARP-OA SEA funds may be used to support the costs associated with hiring additional teachers and teacher aides to provide intensive support to students. These funds may further be used to provide professional development to educators on research-based strategies for meeting students’ academic, social, emotional, mental health, and college, career, and future readiness needs, including strategies to accelerate learning without remediation or tracking. Conditions: 1. For thirty-eight (or 95%) of forty items, aggregating $829,862 of $55,435,193 in total expenditures used in earmarking calculation, deficiencies were noted, as follows: Item # PO/ Other Reference Description Expense Amount Questioned Cost 1 ARP PP23 REGULAR SALARIES $ 10,884 $ 10,884 2 ARP PP23 REGULAR SALARIES 5,457 5,457 3 ARP PP23 BENEFITS 9,034 9,034 4 ARP PP23 REGULAR SALARIES 48,336 48,336 5 ARP PP22 BENEFITS 50,687 50,687 Finding No.: 2024-011, continued Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund ED Subprogram: 84.425X American Rescue Plan – Outlying Areas State Educational Agency (ARP-OA-SEA) Federal Award No.: S425X210003 Area: Matching, Level of Effort, Earmarking Questioned Costs: $825,567 Conditions, continued: Item # PO/ Other Reference Description Expense Amount Questioned Cost 6 ARP PP21 BENEFITS 29,593 29,593 7 ARP PP21 REGULAR SALARIES 95,785 95,785 8 ARP PP19 REGULAR SALARIES 12,955 12,955 9 ARP PP17 REGULAR SALARIES 70,074 70,074 10 ARP PP17 BENEFITS 1,152 1,152 11 ARP PP16 BENEFITS 1,226 1,226 12 ARP PP16 BENEFITS 56,740 56,740 13 ARP PP16 BENEFITS 1,132 1,132 14 ARP PP16 BENEFITS 9,973 9,973 15 ARP PP16 BENEFITS 12,100 12,100 16 ARP PP15 REGULAR SALARIES 1,794 1,794 17 ARP PP15 REGULAR SALARIES 103,677 103,677 18 ARP PP15 REGULAR SALARIES 61,981 61,981 19 ARP PP14 REGULAR SALARIES 135,654 135,654 20 ARP PP14 REGULAR SALARIES 3,209 3,209 21 ARP PP13 BENEFITS 1,262 1,262 22 ARP PP13 BENEFITS 15,804 15,804 23 ARP PP13 REGULAR SALARIES 70,081 70,081 24 ARP PP13 PART-TIME 219 219 25 SPC BENEFITS 429 429 26 20240437 INSTRUCTIONAL 2,180 2,180 27 20241145 INSTRUCTIONAL 20 20 28 20240997 LIBRARY MATERIALS 940 940 29 20241458 INSTRUCTIONAL 6,481 6,481 30 20241425 LIBRARY MATERIALS 98 98 31 20241428 LIBRARY MATERIALS 72 72 32 20240756 INSTRUCTIONAL 226 226 33 20240824 INSTRUCTIONAL 2,894 2,894 34 20232899 ADMIN OFFICE SUPPLIES 64 64 35 20231916 SUPPLIES 44 44 36 20240723 INSTRUCTIONAL 130 130 37 20240410 INSTRUCTIONAL 2,564 2,564 38 20240377 INSTRUCTIONAL 616 616 $825,567 $825,567 Finding No.: 2024-011, continued Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund ED Subprogram: 84.425X American Rescue Plan – Outlying Areas State Educational Agency (ARP-OA-SEA) Federal Award No.: S425X210003 Area: Matching, Level of Effort, Earmarking Questioned Costs: $825,567 Conditions, continued: Item #s 1 through 24 relate to the $51 million instructor’s payroll expenses who have undergone training to implement accelerated learning in the classroom. There is no sufficient supporting documentation or evidence that the cost meets the activities stated in the criteria. Item #s 25 through 38 relate to benefit, supplies or tools that assist teachers and instructional support staff with daily classroom instructions and library services. There is no sufficient supporting documentation or evidence that the cost meets the activities stated in the criteria. 2. GDOE did not meet the minimum 20% earmarking requirement of $57,388,125, after considering the effect of the condition #1 above. Cause: GDOE incorrectly concluded that the regular salaries and wages of teachers that underwent training to implement accelerated learning in classrooms during regular hours as evidenced-based interventions to address the lost instructional time. Additionally, GDOE did not provide clear evidence that the non-payroll expenditures for supplies, tools, and materials purchased were aligned with an approved evidence-based intervention, including clear linkage to program objectives, intervention models, or measurable instructional outcomes. Effect: GDOE is in noncompliance with applicable earmarking requirement. The reportable questioned cost is $825,567 based on the transactions examined in verifying the costs attributed to the earmarking requirement. At the error rate identified of 99.5% (known questioned cost divided by total cost of samples tested), we project that total qualified expenditures incurred by GDOE that meet the earmarking requirement is approximately $302 thousand which is deficient by approximately $57.09 million based on 20% of the grant of approximately $287 million. Finding No.: 2024-011, continued Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund ED Subprogram: 84.425X American Rescue Plan – Outlying Areas State Educational Agency (ARP-OA-SEA) Federal Award No.: S425X210003 Area: Matching, Level of Effort, Earmarking Questioned Costs: $825,567 Recommendation: Responsible personnel should verify that expenditures used in earmarking calculation meet the activities stated in the criteria. Furthermore, sufficient supporting documentation or evidence should be maintained to support that costs meet the activities stated in the criteria.
Finding No.: 2024-012 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund ED Subprogram: 84.425A Education Stabilization Fund – State Educational Agency (Outlying Areas) Federal Award No.: S425A210003 Area: Special Tests and Provisions - Wage Rate Requirements Questioned Costs: $45,750 Criteria: 29 CFR sections 5.5 and 5.6 requires nonfederal entities to include in their construction contracts subject to the Wage Rate Requirements (the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition: For 1 (or 33%) of the 3 construction contracts subjected to the Wage Rate Requirements test, there was no executed construction contract between GDOE and the contractor, consequently, certified payrolls were not submitted to GDOE. Total expenditure charged to the program related to the construction project with the contractor (vendor ID 80757) is $45,750. Cause: GDOE incorrectly utilized the small purchase procurement upon solicitation (i.e., regular purchase order, instead of executing a contract). Effect: GDOE is in noncompliance with applicable special tests and provisions - wage rate requirements. The reportable questioned cost is $45,750. Recommendation: Responsible personnel should enforce monitoring controls over compliance with applicable special tests and provisions - wage rate requirements.