Audit 9381

CRITERIA/SPECIFIC REQUIREMENT: The grant award agreement between the Regional Office of Education No. 39 (ROE) and Illinois State Board of Education requires the ROE to complete and submit expenditure reports quarterly and performance reports semi-annually. The quarterly expenditure reports are due 20 calendar days after the end of the reporting quarter while the semi-annual performance reports are due 30 calendar days after the reporting semi-annual period. The ROE is also required to submit an annual performance report describing how the ROE used the awarded funds during the performance period. The annual reports are due March 17, 2023. The Code of Federal Regulations (Code) (2 CFR. §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure compliance with grant reporting requirements. CONDITION: The ROE did not submit or timely submit the required reports to the Illinois State Board of Education in compliance with the grant award agreement. CONTEXT: During testing of the ROE’s compliance with the grant reporting requirements, we noted the following: • Thirty four of 38 (89%) quarterly expenditure reports were submitted 20 to 342 days late. • Three of 38 (8%) quarterly expenditure reports were not submitted. • Four of six (67%) semi-annual reports were not submitted. • One of six (17%) semi-annual report was submitted 158 days late. • Three of three (100%) annual reports were not submitted. EFFECT: Failure to meet grant reporting requirements is a noncompliance with the related grant agreement and could result in loss of grant funding in future years. CAUSE: ROE management indicated required reports were not submitted or timely submitted due to oversight and competing priorities. RECOMMENDATION: We recommend the ROE implement procedures to ensure adherence to the grant reporting requirements. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. Previous management did not monitor grant compliance.

CRITERIA/SPECIFIC REQUIREMENT: The Regional Office of Education No. 39 (ROE) procedure requires the Regional Superintendent or the Program Director to review and approve invoices and requisitions before forwarding to the business office for processing. The Code (2 CFR §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure expenditures under Federal awards are supported, reviewed, and approved. CONDITION: The ROE did not ensure costs or expenditures were adequately documented, reviewed, and approved to ensure allowability under the federal award. CONTEXT: During testing of 60 expenditures totaling $471,516, we noted eight (13%) expenditures were not signed by the Program Director or Regional Superintendent to indicate review and approval of the expenditures. EFFECT: Inadequate controls of expenditures may result in unallowable costs charged to the Federal award. CAUSE: Expenditures were not signed by the Regional Superintendent or Program Director due to oversight. RECOMMENDATION: We recommend the ROE ensures all expenditures are properly supported, reviewed, and approved prior to payment. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. However, according to the ROE Employee Handbook (Fiscal Policies, page 16), updated and implemented in March 2021, monthly bills such as rent, phone, etc. did not require a requisition and were signed by the Business Manager. Reoccurring payments were approved with the contract lease agreement based on budgeted amounts.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR § 200.332 (a)) requires the Regional Office of Education No. 39 (ROE) to ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s name and unique entity identifier, assistance listing number, federal award date, federal awarding agency, etc. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. The Code (2 CFR § 200.332 (f)) requires the ROE to verify every subrecipient is audited as required by Subpart F when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR § 200.501. The Code (2 CFR § 200.332 (d)) requires the ROE to monitor the activities of the subrecipient to ensure the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward, and that subaward performance goals are achieved. The Code (2 CFR §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over subrecipient monitoring. CONDITION: The ROE did not have adequate controls over subrecipient monitoring in compliance with the Code. CONTEXT: During our testing of four subrecipients, we noted the following: • The ROE did not communicate the required federal award information to all (100%) subrecipients to comply with federal statutes, regulations, and the terms and conditions at the start of the award. All the subaward agreements were signed and became effective after the start date of the grant. • The ROE did not verify whether subrecipients were required to be audited or not. • The ROE did not have written policies and procedures for subrecipient monitoring and could not provide evidence the ROE monitored its subrecipients during the audit period. EFFECT: Lack of controls over subrecipient monitoring may result in subrecipients not properly administering the federal programs in accordance with federal regulations. CAUSE: ROE management indicated this was due to oversight and staffing limitations. RECOMMENDATION: We recommend the ROE establish and implement procedures over subrecipient monitoring. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. The ROE did communicate federal award information to all subrecipients but failed to get the signature of Regional Office of Education No. 17 documenting their decline of the federal award and preference for ROE to manage the funds and services for their area.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The grant award agreement between the Regional Office of Education No. 39 (ROE) and Illinois State Board of Education requires the ROE to complete and submit expenditure reports quarterly and performance reports semi-annually. The quarterly expenditure reports are due 20 calendar days after the end of the reporting quarter while the semi-annual performance reports are due 30 calendar days after the reporting semi-annual period. The ROE is also required to submit an annual performance report describing how the ROE used the awarded funds during the performance period. The annual reports are due March 17, 2023. The Code of Federal Regulations (Code) (2 CFR. §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure compliance with grant reporting requirements. CONDITION: The ROE did not submit or timely submit the required reports to the Illinois State Board of Education in compliance with the grant award agreement. CONTEXT: During testing of the ROE’s compliance with the grant reporting requirements, we noted the following: • Thirty four of 38 (89%) quarterly expenditure reports were submitted 20 to 342 days late. • Three of 38 (8%) quarterly expenditure reports were not submitted. • Four of six (67%) semi-annual reports were not submitted. • One of six (17%) semi-annual report was submitted 158 days late. • Three of three (100%) annual reports were not submitted. EFFECT: Failure to meet grant reporting requirements is a noncompliance with the related grant agreement and could result in loss of grant funding in future years. CAUSE: ROE management indicated required reports were not submitted or timely submitted due to oversight and competing priorities. RECOMMENDATION: We recommend the ROE implement procedures to ensure adherence to the grant reporting requirements. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. Previous management did not monitor grant compliance.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The grant award agreement between the Regional Office of Education No. 39 (ROE) and Illinois State Board of Education requires the ROE to complete and submit expenditure reports quarterly and performance reports semi-annually. The quarterly expenditure reports are due 20 calendar days after the end of the reporting quarter while the semi-annual performance reports are due 30 calendar days after the reporting semi-annual period. The ROE is also required to submit an annual performance report describing how the ROE used the awarded funds during the performance period. The annual reports are due March 17, 2023. The Code of Federal Regulations (Code) (2 CFR. §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure compliance with grant reporting requirements. CONDITION: The ROE did not submit or timely submit the required reports to the Illinois State Board of Education in compliance with the grant award agreement. CONTEXT: During testing of the ROE’s compliance with the grant reporting requirements, we noted the following: • Thirty four of 38 (89%) quarterly expenditure reports were submitted 20 to 342 days late. • Three of 38 (8%) quarterly expenditure reports were not submitted. • Four of six (67%) semi-annual reports were not submitted. • One of six (17%) semi-annual report was submitted 158 days late. • Three of three (100%) annual reports were not submitted. EFFECT: Failure to meet grant reporting requirements is a noncompliance with the related grant agreement and could result in loss of grant funding in future years. CAUSE: ROE management indicated required reports were not submitted or timely submitted due to oversight and competing priorities. RECOMMENDATION: We recommend the ROE implement procedures to ensure adherence to the grant reporting requirements. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. Previous management did not monitor grant compliance.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The grant award agreement between the Regional Office of Education No. 39 (ROE) and Illinois State Board of Education requires the ROE to complete and submit expenditure reports quarterly and performance reports semi-annually. The quarterly expenditure reports are due 20 calendar days after the end of the reporting quarter while the semi-annual performance reports are due 30 calendar days after the reporting semi-annual period. The ROE is also required to submit an annual performance report describing how the ROE used the awarded funds during the performance period. The annual reports are due March 17, 2023. The Code of Federal Regulations (Code) (2 CFR. §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure compliance with grant reporting requirements. CONDITION: The ROE did not submit or timely submit the required reports to the Illinois State Board of Education in compliance with the grant award agreement. CONTEXT: During testing of the ROE’s compliance with the grant reporting requirements, we noted the following: • Thirty four of 38 (89%) quarterly expenditure reports were submitted 20 to 342 days late. • Three of 38 (8%) quarterly expenditure reports were not submitted. • Four of six (67%) semi-annual reports were not submitted. • One of six (17%) semi-annual report was submitted 158 days late. • Three of three (100%) annual reports were not submitted. EFFECT: Failure to meet grant reporting requirements is a noncompliance with the related grant agreement and could result in loss of grant funding in future years. CAUSE: ROE management indicated required reports were not submitted or timely submitted due to oversight and competing priorities. RECOMMENDATION: We recommend the ROE implement procedures to ensure adherence to the grant reporting requirements. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. Previous management did not monitor grant compliance.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The Regional Office of Education No. 39 (ROE) procedure requires the Regional Superintendent or the Program Director to review and approve invoices and requisitions before forwarding to the business office for processing. The Code (2 CFR §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure expenditures under Federal awards are supported, reviewed, and approved. CONDITION: The ROE did not ensure costs or expenditures were adequately documented, reviewed, and approved to ensure allowability under the federal award. CONTEXT: During testing of 60 expenditures totaling $471,516, we noted eight (13%) expenditures were not signed by the Program Director or Regional Superintendent to indicate review and approval of the expenditures. EFFECT: Inadequate controls of expenditures may result in unallowable costs charged to the Federal award. CAUSE: Expenditures were not signed by the Regional Superintendent or Program Director due to oversight. RECOMMENDATION: We recommend the ROE ensures all expenditures are properly supported, reviewed, and approved prior to payment. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. However, according to the ROE Employee Handbook (Fiscal Policies, page 16), updated and implemented in March 2021, monthly bills such as rent, phone, etc. did not require a requisition and were signed by the Business Manager. Reoccurring payments were approved with the contract lease agreement based on budgeted amounts.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The grant award agreement between the Regional Office of Education No. 39 (ROE) and Illinois State Board of Education requires the ROE to complete and submit expenditure reports quarterly and performance reports semi-annually. The quarterly expenditure reports are due 20 calendar days after the end of the reporting quarter while the semi-annual performance reports are due 30 calendar days after the reporting semi-annual period. The ROE is also required to submit an annual performance report describing how the ROE used the awarded funds during the performance period. The annual reports are due March 17, 2023. The Code of Federal Regulations (Code) (2 CFR. §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure compliance with grant reporting requirements. CONDITION: The ROE did not submit or timely submit the required reports to the Illinois State Board of Education in compliance with the grant award agreement. CONTEXT: During testing of the ROE’s compliance with the grant reporting requirements, we noted the following: • Thirty four of 38 (89%) quarterly expenditure reports were submitted 20 to 342 days late. • Three of 38 (8%) quarterly expenditure reports were not submitted. • Four of six (67%) semi-annual reports were not submitted. • One of six (17%) semi-annual report was submitted 158 days late. • Three of three (100%) annual reports were not submitted. EFFECT: Failure to meet grant reporting requirements is a noncompliance with the related grant agreement and could result in loss of grant funding in future years. CAUSE: ROE management indicated required reports were not submitted or timely submitted due to oversight and competing priorities. RECOMMENDATION: We recommend the ROE implement procedures to ensure adherence to the grant reporting requirements. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. Previous management did not monitor grant compliance.

CRITERIA/SPECIFIC REQUIREMENT: The Regional Office of Education No. 39 (ROE) procedure requires the Regional Superintendent or the Program Director to review and approve invoices and requisitions before forwarding to the business office for processing. The Code (2 CFR §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure expenditures under Federal awards are supported, reviewed, and approved. CONDITION: The ROE did not ensure costs or expenditures were adequately documented, reviewed, and approved to ensure allowability under the federal award. CONTEXT: During testing of 60 expenditures totaling $471,516, we noted eight (13%) expenditures were not signed by the Program Director or Regional Superintendent to indicate review and approval of the expenditures. EFFECT: Inadequate controls of expenditures may result in unallowable costs charged to the Federal award. CAUSE: Expenditures were not signed by the Regional Superintendent or Program Director due to oversight. RECOMMENDATION: We recommend the ROE ensures all expenditures are properly supported, reviewed, and approved prior to payment. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. However, according to the ROE Employee Handbook (Fiscal Policies, page 16), updated and implemented in March 2021, monthly bills such as rent, phone, etc. did not require a requisition and were signed by the Business Manager. Reoccurring payments were approved with the contract lease agreement based on budgeted amounts.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR § 200.332 (a)) requires the Regional Office of Education No. 39 (ROE) to ensure that every subaward is clearly identified to the subrecipient as a subaward and include information to comply with federal statutes, regulations, and the terms and conditions of the award. The required information includes the subrecipient’s name and unique entity identifier, assistance listing number, federal award date, federal awarding agency, etc. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award. The Code (2 CFR § 200.332 (f)) requires the ROE to verify every subrecipient is audited as required by Subpart F when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR § 200.501. The Code (2 CFR § 200.332 (d)) requires the ROE to monitor the activities of the subrecipient to ensure the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward, and that subaward performance goals are achieved. The Code (2 CFR §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over subrecipient monitoring. CONDITION: The ROE did not have adequate controls over subrecipient monitoring in compliance with the Code. CONTEXT: During our testing of four subrecipients, we noted the following: • The ROE did not communicate the required federal award information to all (100%) subrecipients to comply with federal statutes, regulations, and the terms and conditions at the start of the award. All the subaward agreements were signed and became effective after the start date of the grant. • The ROE did not verify whether subrecipients were required to be audited or not. • The ROE did not have written policies and procedures for subrecipient monitoring and could not provide evidence the ROE monitored its subrecipients during the audit period. EFFECT: Lack of controls over subrecipient monitoring may result in subrecipients not properly administering the federal programs in accordance with federal regulations. CAUSE: ROE management indicated this was due to oversight and staffing limitations. RECOMMENDATION: We recommend the ROE establish and implement procedures over subrecipient monitoring. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. The ROE did communicate federal award information to all subrecipients but failed to get the signature of Regional Office of Education No. 17 documenting their decline of the federal award and preference for ROE to manage the funds and services for their area.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The grant award agreement between the Regional Office of Education No. 39 (ROE) and Illinois State Board of Education requires the ROE to complete and submit expenditure reports quarterly and performance reports semi-annually. The quarterly expenditure reports are due 20 calendar days after the end of the reporting quarter while the semi-annual performance reports are due 30 calendar days after the reporting semi-annual period. The ROE is also required to submit an annual performance report describing how the ROE used the awarded funds during the performance period. The annual reports are due March 17, 2023. The Code of Federal Regulations (Code) (2 CFR. §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure compliance with grant reporting requirements. CONDITION: The ROE did not submit or timely submit the required reports to the Illinois State Board of Education in compliance with the grant award agreement. CONTEXT: During testing of the ROE’s compliance with the grant reporting requirements, we noted the following: • Thirty four of 38 (89%) quarterly expenditure reports were submitted 20 to 342 days late. • Three of 38 (8%) quarterly expenditure reports were not submitted. • Four of six (67%) semi-annual reports were not submitted. • One of six (17%) semi-annual report was submitted 158 days late. • Three of three (100%) annual reports were not submitted. EFFECT: Failure to meet grant reporting requirements is a noncompliance with the related grant agreement and could result in loss of grant funding in future years. CAUSE: ROE management indicated required reports were not submitted or timely submitted due to oversight and competing priorities. RECOMMENDATION: We recommend the ROE implement procedures to ensure adherence to the grant reporting requirements. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. Previous management did not monitor grant compliance.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The grant award agreement between the Regional Office of Education No. 39 (ROE) and Illinois State Board of Education requires the ROE to complete and submit expenditure reports quarterly and performance reports semi-annually. The quarterly expenditure reports are due 20 calendar days after the end of the reporting quarter while the semi-annual performance reports are due 30 calendar days after the reporting semi-annual period. The ROE is also required to submit an annual performance report describing how the ROE used the awarded funds during the performance period. The annual reports are due March 17, 2023. The Code of Federal Regulations (Code) (2 CFR. §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure compliance with grant reporting requirements. CONDITION: The ROE did not submit or timely submit the required reports to the Illinois State Board of Education in compliance with the grant award agreement. CONTEXT: During testing of the ROE’s compliance with the grant reporting requirements, we noted the following: • Thirty four of 38 (89%) quarterly expenditure reports were submitted 20 to 342 days late. • Three of 38 (8%) quarterly expenditure reports were not submitted. • Four of six (67%) semi-annual reports were not submitted. • One of six (17%) semi-annual report was submitted 158 days late. • Three of three (100%) annual reports were not submitted. EFFECT: Failure to meet grant reporting requirements is a noncompliance with the related grant agreement and could result in loss of grant funding in future years. CAUSE: ROE management indicated required reports were not submitted or timely submitted due to oversight and competing priorities. RECOMMENDATION: We recommend the ROE implement procedures to ensure adherence to the grant reporting requirements. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. Previous management did not monitor grant compliance.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The grant award agreement between the Regional Office of Education No. 39 (ROE) and Illinois State Board of Education requires the ROE to complete and submit expenditure reports quarterly and performance reports semi-annually. The quarterly expenditure reports are due 20 calendar days after the end of the reporting quarter while the semi-annual performance reports are due 30 calendar days after the reporting semi-annual period. The ROE is also required to submit an annual performance report describing how the ROE used the awarded funds during the performance period. The annual reports are due March 17, 2023. The Code of Federal Regulations (Code) (2 CFR. §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure compliance with grant reporting requirements. CONDITION: The ROE did not submit or timely submit the required reports to the Illinois State Board of Education in compliance with the grant award agreement. CONTEXT: During testing of the ROE’s compliance with the grant reporting requirements, we noted the following: • Thirty four of 38 (89%) quarterly expenditure reports were submitted 20 to 342 days late. • Three of 38 (8%) quarterly expenditure reports were not submitted. • Four of six (67%) semi-annual reports were not submitted. • One of six (17%) semi-annual report was submitted 158 days late. • Three of three (100%) annual reports were not submitted. EFFECT: Failure to meet grant reporting requirements is a noncompliance with the related grant agreement and could result in loss of grant funding in future years. CAUSE: ROE management indicated required reports were not submitted or timely submitted due to oversight and competing priorities. RECOMMENDATION: We recommend the ROE implement procedures to ensure adherence to the grant reporting requirements. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. Previous management did not monitor grant compliance.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The Regional Office of Education No. 39 (ROE) procedure requires the Regional Superintendent or the Program Director to review and approve invoices and requisitions before forwarding to the business office for processing. The Code (2 CFR §200.303 (a)) requires the ROE to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure expenditures under Federal awards are supported, reviewed, and approved. CONDITION: The ROE did not ensure costs or expenditures were adequately documented, reviewed, and approved to ensure allowability under the federal award. CONTEXT: During testing of 60 expenditures totaling $471,516, we noted eight (13%) expenditures were not signed by the Program Director or Regional Superintendent to indicate review and approval of the expenditures. EFFECT: Inadequate controls of expenditures may result in unallowable costs charged to the Federal award. CAUSE: Expenditures were not signed by the Regional Superintendent or Program Director due to oversight. RECOMMENDATION: We recommend the ROE ensures all expenditures are properly supported, reviewed, and approved prior to payment. MANAGEMENT’S RESPONSE: The ROE agrees with this finding. However, according to the ROE Employee Handbook (Fiscal Policies, page 16), updated and implemented in March 2021, monthly bills such as rent, phone, etc. did not require a requisition and were signed by the Business Manager. Reoccurring payments were approved with the contract lease agreement based on budgeted amounts.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.

CRITERIA/SPECIFIC REQUIREMENT: The Code of Federal Regulations (Code) (2 CFR §200.510 (b)), establishes criteria and requirements related to the preparation of the schedule of expenditures of federal awards.   The Code (2 CFR §200.303 (a)) requires Regional Office of Education No. 39 (ROE) to establish and maintain effective internal control over the federal award to provide reasonable assurance the ROE is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures over preparation of the schedule of expenditures of federal awards. CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. CONTEXT: During our review of the SEFA, we noted the following: • Program title descriptions were incorrect, and COVID-19-related grants were not properly identified in the program title. • Assistance listing numbers and pass-through grant numbers were incorrectly listed. • Federal expenditures did not match the expenditures in the general ledger. • Subrecipient expenditures were inappropriately reported on grants that did not actually have subrecipients: • The Education Stabilization Fund was not specifically categorized in the SEFA and the total federal awards expended for the program was not reported. The ROE subsequently revised its SEFA to correct these errors. EFFECT: Failure to report an accurate SEFA affects the required audit coverage to meet federal requirements and can delay an audit beyond the reporting deadline. CAUSE: Management indicated the errors on the SEFA was due to oversight. RECOMMENDATION: The ROE should establish and implement internal controls over preparation of the SEFA to ensure accurate reporting. MANAGEMENT’S RESPONSE: The ROE agrees with this finding.