Significant Deficiency – Internal Control over Compliance – ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS/COST PRINCIPLES ALN 84.010 Title I, Part A, Basic grants Low-Income and Neglected United States Department of Education Passed through State of Illinois Department of Education Type of finding: Significant deficiency in internal controls over compliance. Criteria: In accordance with 2 CFR Part 200.303(a), the School must establish, document, and maintain effective internal control over Federal awards that provide reasonable assurance that the recipient of subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, 2 CFR 200.508(d) requires that the auditee ‘provide the auditor access to personnel, accounts, books, records, supporting documentation, and any other information needed for the auditor to perform the audit required by this part.’ Condition: The School was unable to provide supporting time and effort certification for 6 of the 40 samples tested due to data access restrictions in Chicago Public Schools (CPS) federal claim system. The existing CPS Federal Funds platform (Oracle) produces Time & Effort Attestation reports according to the month when reimbursement claims are submitted, not the actual period the work was completed, which leads to a compliance gap. Cause: The School did not maintain certain time and effort documentation for Title I employees within its own records, but instead relied on the records provided by the CPS system. The School was unable to access the CPS documentation for certain time periods charged to the program during the audit of the program. Questioned Costs: None. Effect: 6 of 40 samples tested did not have time and effort certification on file. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School revise and implement controls to ensure consistent maintenance of all supporting documentation needed for audit. Management Response: See corrective action plan on page 28.