Audit 43510

2022-011: U.S. Department of Education Passed through Opportunity 180 Charter Schools, 84.282 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is the segregation of duties through a review and approval process. Condition: Costs charged to the program did not have evidence of review by an individual independent of the preparation of the allocation of costs to the program. Cause: The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented. Effect: Unallowable costs may be charged to the program and not detected by the School. Questioned Costs: None noted Context/Sampling: A non-statistical sample of 47 transactions out of a population of 79 was selected for testing. There was no evidence of review on 36 transactions tested. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to ensure review of costs charged to the program occurs and is documented. Views of Responsible Officials: Management agrees with this finding.

2022-012: U.S. Department of Education Passed through Opportunity 180 Charter Schools, 84.282 Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non-federal entity must use its own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: The School has policies and procedures which make reference to state regulation and law, but the policies have not been updated with sufficient clarity and detail to ensure compliance with federal law and standards. Cause: The School did not have adequate internal controls to review its policy and procedures to include federal procurement requirements. Effect: The School may follow its documented procurement policies and not identify non-compliance with federal procurement law in cases where federal procurement law is more restrictive. Questioned Costs: None noted Context/Sampling: The School?s procurement procedures were examined in their entirety. Repeat Finding from Prior Year: No Recommendation: We recommend the School review its procurement policy and include federal procurement requirements. Views of Responsible Officials: Management agrees with this finding.

2022-013: U.S. Department of Education Passed through Opportunity 180 Charter Schools, 84.282 Other Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires the School to prepare a Schedule of Expenditures of Federal Awards (SEFA). In addition, Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is the segregation of duties through a review and approval process of the SEFA. Condition: There was no evidence of review and approval on the preparation of the initial SEFA. Cause: The School did not have adequate internal controls to provide for the review of journal entries that allocate expenses to federal programs or the SEFA to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Misstatements on the SEFA could occur and not be detected by the School. Questioned Costs: None noted Context/Sampling: No sampling was used; all program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to provide for the review of journal entries that allocate expenses to federal programs and the SEFA to ensure total federal expenditures are appropriately reported on the SEFA. Views of Responsible Officials: Management agrees with this finding.

2022-011: U.S. Department of Education Passed through Opportunity 180 Charter Schools, 84.282 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is the segregation of duties through a review and approval process. Condition: Costs charged to the program did not have evidence of review by an individual independent of the preparation of the allocation of costs to the program. Cause: The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented. Effect: Unallowable costs may be charged to the program and not detected by the School. Questioned Costs: None noted Context/Sampling: A non-statistical sample of 47 transactions out of a population of 79 was selected for testing. There was no evidence of review on 36 transactions tested. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to ensure review of costs charged to the program occurs and is documented. Views of Responsible Officials: Management agrees with this finding.

2022-012: U.S. Department of Education Passed through Opportunity 180 Charter Schools, 84.282 Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires that a non-federal entity must use its own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procedures conform to applicable federal law and standards. Condition: The School has policies and procedures which make reference to state regulation and law, but the policies have not been updated with sufficient clarity and detail to ensure compliance with federal law and standards. Cause: The School did not have adequate internal controls to review its policy and procedures to include federal procurement requirements. Effect: The School may follow its documented procurement policies and not identify non-compliance with federal procurement law in cases where federal procurement law is more restrictive. Questioned Costs: None noted Context/Sampling: The School?s procurement procedures were examined in their entirety. Repeat Finding from Prior Year: No Recommendation: We recommend the School review its procurement policy and include federal procurement requirements. Views of Responsible Officials: Management agrees with this finding.

2022-013: U.S. Department of Education Passed through Opportunity 180 Charter Schools, 84.282 Other Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.282 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires the School to prepare a Schedule of Expenditures of Federal Awards (SEFA). In addition, Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is the segregation of duties through a review and approval process of the SEFA. Condition: There was no evidence of review and approval on the preparation of the initial SEFA. Cause: The School did not have adequate internal controls to provide for the review of journal entries that allocate expenses to federal programs or the SEFA to ensure total federal expenditures were appropriately reported on the SEFA. Effect: Misstatements on the SEFA could occur and not be detected by the School. Questioned Costs: None noted Context/Sampling: No sampling was used; all program expenditures on the SEFA were reconciled to supporting records. Repeat Finding from Prior Year: No Recommendation: We recommend the School enhance internal controls to provide for the review of journal entries that allocate expenses to federal programs and the SEFA to ensure total federal expenditures are appropriately reported on the SEFA. Views of Responsible Officials: Management agrees with this finding.