Audit 390904

2025-001. Matching, Level of Effort, Earmarking United States Department of Education, Passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027 Special Education Preschool Grants ALN: 84.173 Criteria: Funds provided to an LEA under IDEA, Part B must not be used to reduce the level of expenditures for the education of children with disabilities made by the LEA from local funds below the level of those expenditures for the preceding fiscal year, with exceptions as provided in 34 CFR sections 300.204 and 300.205. The District is required to complete a Maintenance of Effort Calculation (MOE) prior to awarding the grant using approved budgeted amounts to document its eligibility for its allocation of grant funds. A second MOE is prepared after the grant year is completed using the District’s audited amounts to document its actual compliance with the MOE. Condition: Upon review of the MOE, completed by the District to demonstrate the compliance requirement for the 2023-2024 grant program, it was noted that certain expenditures used in the MOE did not agree with the audited expenditure amounts. This resulted in an erroneous calculation indicating that the District had met the maintenance of effort requirement; however, the MOE completed using audited expenditure amounts would have indicated the District would not have met the MOE requirement without the District identifying allowable exceptions. Cause: Individuals responsible for completion of the MOE did not receive adequate training on the calculation, which resulted in incorrect amounts being used. Processes were not in place for someone independent of the preparation of the MOE to review the completed calculation prior to its submission to the New State Department of Education. Effect: An improperly completed MOE could result in the District receiving more federal awards than it would be entitled to. Questioned Costs: Dollar amount undetermined; correct calculation was not available. Identifcation of a Repeat Finding: This is not a repeat finding. Recommendation: The District should implement procedures to ensure the individuals responsible for preparing the MOE calculation are properly trained to ensure that the correct information is used. Additionally, the completed MOE calculation should be reviewed by an individual independent of the preparation process to verify the calculation is accurate. Views of Responsible Officials of the Auditee: Management agrees with this finding. The District provided additional training to the individuals responsible for completing the MOE to ensure they have an understanding of how to properly prepare the MOE. The District also worked with its outside consultant to ensure the revised MOE was properly completed. The revised MOE calculation was subsequently transmitted to the New York State Education Department.