Corrective Action Plans

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2023-002 Condition: Deficiencies Noted in Cash Disbursements Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will implement procedures and changes to ensure that this finding will be cleared by the subsequent fiscal year audit. Individual responsi...
2023-002 Condition: Deficiencies Noted in Cash Disbursements Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will implement procedures and changes to ensure that this finding will be cleared by the subsequent fiscal year audit. Individual responsible for correction: Mr. Damon Dunbar, Executive Director Timeframe: As of December 31, 2025
Finding 2023-002: Compliance Requirement: Allowable Cost/Cost Principles Material Weakness Assistance Living Number 93.224 Health Center Programs Grant Award Number H80CS00112 US Department of Health and Human Services Condition: A walkthrough of fourteen individuals was performed to review perso...
Finding 2023-002: Compliance Requirement: Allowable Cost/Cost Principles Material Weakness Assistance Living Number 93.224 Health Center Programs Grant Award Number H80CS00112 US Department of Health and Human Services Condition: A walkthrough of fourteen individuals was performed to review personnel files and payroll related to salary for the Organization. Of the fourteen files reviewed, two had no approved current pay rate documented, and the salary or hourly rate paid was not the rate contained in the file. Also, there was no timesheet provided to support the time charged to the federal grant for eleven of the fourteen individuals tested. Action Planned in Response to the Finding: All payroll activities are managed through ADP. The Human Resources team will familiarize themselves with time and effort reporting requirements and implement a standardized checklist for each personnel file. This checklist will serve as an internal control to ensure that each file is complete, reflects current pay rates, and accurately documents time allocated to grant activities. Additionally, the Finance team will take the following steps to strengthen compliance and accuracy in grant reporting: 1. Assign personnel whose responsibilities are 100% fully dedicated to specific grant activities. 2. Maintain a detailed allocation table tracking employee time and effort by individual grant. Official Responsible for Ensuring the CAP: Marilyn Powers-Campbell Planned Completion Date: December 2024
View Audit 354532 Questioned Costs: $1
We have executed strategic process improvements and personnel adjustments within the Finance function specifically designed to facilitate more efficient and timely completion of month-end, quarter-end, and year-end close procedures. These improvements include standardized workflows, clearly defined ...
We have executed strategic process improvements and personnel adjustments within the Finance function specifically designed to facilitate more efficient and timely completion of month-end, quarter-end, and year-end close procedures. These improvements include standardized workflows, clearly defined responsibilities, and process automation. Additionally, the finance team has committed to ensuring adequate time allocation for all audit activities. We have established a proactive planning framework that incorporates appropriate buffer periods to guarantee completion well in advance of regulatory deadlines. Furthermore, we commit to conducting all fieldwork within the initially scheduled timeframes to prevent timeline extensions.
The Finance Team has developed and deployed a comprehensive month-end close process that includes: • A detailed procedural checklist with clearly defined responsibilities • Specific deadlines for each critical task in the close sequence • Formal approval requirements at key control points • A target...
The Finance Team has developed and deployed a comprehensive month-end close process that includes: • A detailed procedural checklist with clearly defined responsibilities • Specific deadlines for each critical task in the close sequence • Formal approval requirements at key control points • A targeted completion timeline of 30 days post month-end To support this enhanced process, we have strategically increased resources within the finance function, including additional staff allocation to high-priority areas. Furthermore, we are conducting a thorough assessment of automation opportunities throughout our accounting workflow to improve efficiency, reduce manual processing, and accelerate the completion of key accounting tasks.
The Vice President of Administrative Services will seek to add staff to the finance department to support grant initiatives. During FY 24‐25 a grant policy will be developed and effort be made to communicate each grant initiative as it becomes available, to the Executive Council. This process and st...
The Vice President of Administrative Services will seek to add staff to the finance department to support grant initiatives. During FY 24‐25 a grant policy will be developed and effort be made to communicate each grant initiative as it becomes available, to the Executive Council. This process and staffing update will help the college provide more detail, accuracy and controls over grants. This will be accomplished by 8/31/24.
The County did experience issues with the reporting portal for these funds.  When we requested assistance, we received generic responses and little assistance from the Treasury.  It wasn’t until November 2024 that we were finally able to gain the assistance we needed to gain full access to the Treas...
The County did experience issues with the reporting portal for these funds.  When we requested assistance, we received generic responses and little assistance from the Treasury.  It wasn’t until November 2024 that we were finally able to gain the assistance we needed to gain full access to the Treasury portal as well as some guidance on the reports.  On January 1, 2025, the Treasury provided guidance that is helpful to us in understanding the reporting requirements.  Now that we have the access and guidance we need, all reports will be submitted accurately and on time.
Emergency Solutions Grants Program – Assistance Listing No. 14.231 Recommendation: We recommend that the Agency reviews the controls in place to ensure that subrecipient payments are paid timely and within program requirements. Explanation of disagreement with audit finding: There is no disagreeme...
Emergency Solutions Grants Program – Assistance Listing No. 14.231 Recommendation: We recommend that the Agency reviews the controls in place to ensure that subrecipient payments are paid timely and within program requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To prevent a recurrence of the issue, we began implementing a corrective action plan. Specifically, we are enhancing our internal controls and began developing a comprehensive technical procedure manual that will serve as a detailed guide that provides a clear reference for finance and accounting staff to ensure consistency, compliance and efficiency in financial operations. Additionally, as SHRA is filling vacancies due to significant turnover across the entire Finance Department, specific training is provided to new employees in the following areas: • Building HOME • Capital Fund • CDBG • Continuum of Care • Developing a Cost Allocation Plan • Financial Management Part I and Part II (for CPD programs) • HCV Two Year Tool • IDIS • Mainstream Vouchers • Overview of Asset Management • PHA Financial Management Name(s) of the contact person(s) responsible for corrective action: Irene De Jong, DIRECTOR OF FINANCE Planned completion date for corrective action plan: December 31, 2025
Recommendation: We recommend that the Agency reviews the controls in place to ensure that payroll transactions are charged to the correct program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To prevent a recu...
Recommendation: We recommend that the Agency reviews the controls in place to ensure that payroll transactions are charged to the correct program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To prevent a recurrence of the issue, we began implementing a corrective action plan. The Agency hired a Payroll Analyst in January 2025, who will be tasked with reviewing payroll transactions and reports on a monthly/quarterly basis and ensuring that payroll charges are reflected in the correct program. Name(s) of the contact person(s) responsible for corrective action: Irene De Jong, DIRECTOR OF FINANCE Planned completion date for corrective action plan: December 31, 2025
View Audit 354004 Questioned Costs: $1
Grant a Gift Autism Foundation Corrective Action Plan Year Ended December 31, 2023 2023-002 U.S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number 21.027, Passed through the State of Nevada’s Department of Health and Human Services – In...
Grant a Gift Autism Foundation Corrective Action Plan Year Ended December 31, 2023 2023-002 U.S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number 21.027, Passed through the State of Nevada’s Department of Health and Human Services – Internal Control Systems over Compliance, Allowable Costs Criteria: As defined in 2 CFR 200.303, the auditee is required to maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions executed are in compliance with the terms and conditions of the federal award. Condition: During our audit, we were informed that the Organization did not maintain evidence of the review of the allocation of time spent on federal grants by employees. Cause: The internal control system over the assessment of the allocation of allowable payroll costs was not operating effectively. Context: Evidence of the internal controls over the review and allocation of payroll costs was not maintained. Effect: Lack of evidence of review of employee time spent working on federal grants for payroll costs reimbursed under the grants increases the risk that unallowable costs could be submitted for reimbursement. Recommendations: We recommend that management design and implement a system of internal controls whereby employees utilize a grant time tracking sheet reflecting the amount of employee time spent working towards each grant the Organization expends, that this sheet is reviewed by each employee’s supervisor, and that proper documentation is maintained. Views of Responsible Officials: Management will ensure evidence of supervisor approval is obtained and maintained by January 2024 Responsible official: Eric Hill Title: Director of Finance & HR
1. Improvement of Data Entry and Documentation Management: *The process for submitting, processing, and storing sliding fee applications will be reviewed and streamlined to ensure that all supporting income level documents are properly collected, verified, and stored at the time of application submi...
1. Improvement of Data Entry and Documentation Management: *The process for submitting, processing, and storing sliding fee applications will be reviewed and streamlined to ensure that all supporting income level documents are properly collected, verified, and stored at the time of application submission. *Employees involved in handling sliding fee applications and supporting documents will be provided with training on the importance of accurate documentation and the procedures for proper filing, both physically and electronically. 2. Implement Regular Monitoring and Auditing: *A regular internal review and audit process will be revisited to ensure that backup, storage, and retention practices are being followed. These audits will focus on verifying that all sliding fee applications and related documents are stored correctly and are retrievable as needed. *Any discrepancies or issues identified during audits will be addressed promptly, and corrective actions will be taken to ensure compliance with the established procedures. 3. Staff Training and Awareness: *Training sessions will be conducted for all relevant staff on the updated backup, storage, and retention procedures for sliding fee applications and income documentation. This training will emphasize the importance of maintaining accurate and accessible records to comply with regulatory and organizational standards. *Refresher training will be provided quarterly to ensure ongoing compliance and awareness.
1. Enhance Document Retention Procedures: *We will update our document retention policy to clearly define retention periods for payroll-related records, ensuring compliance with legal and regulatory requirements. This will include retaining all necessary documentation such as payroll reports, tax fi...
1. Enhance Document Retention Procedures: *We will update our document retention policy to clearly define retention periods for payroll-related records, ensuring compliance with legal and regulatory requirements. This will include retaining all necessary documentation such as payroll reports, tax filings, and third-party payroll contracts. *A secure, organized system will be implemented for storing payroll-related documents, whether physical or digital. This will include utilizing secure cloud storage or an enterprise document management system with restricted access controls. *We will conduct a quarterly review to ensure that documents are being retained for the appropriate time frame and securely disposed of when no longer required. 2. Implement Stronger Controls During Payroll Provider Transitions: *We will formalize and document the process for changing third-party payroll providers. This process will include detailed steps for due diligence, transition planning, data transfer procedures, and ensuring continuous payroll processing during the transition period. *A project team will be assigned for every payroll provider change to ensure proper planning, including backup and contingency plans, data verification, and communication with both internal and external stakeholders. *A comprehensive review of the transition will be conducted after each change, including a reconciliation of payroll records to ensure that all data is accurately transferred, and all systems are functioning properly. 3. Vendor Oversight and Service Level Agreements (SLAs): *We will ensure that future contracts with third-party payroll providers include clear Service Level Agreements (SLAs) outlining the provider's responsibilities in terms of document retention, data security, and transition procedures. This will ensure that providers maintain the necessary standards and practices for managing payroll-related documents.
View Audit 353876 Questioned Costs: $1
Condition: During the audit it was noted that there were twenty-three individuals who did not have documentation of the correct wage that was used on the grant expenditure report. The Club also does not keep any copies of the invoices to back up which expenses are allocated to the grant. Plan: The C...
Condition: During the audit it was noted that there were twenty-three individuals who did not have documentation of the correct wage that was used on the grant expenditure report. The Club also does not keep any copies of the invoices to back up which expenses are allocated to the grant. Plan: The Club plans to review the issue with its current procedures and revise them as necessary to provide better controls over grant expenditures. Anticipated Date of Completion: As soon as possible – before FY25 year end Name of Contact Person: Germain Castellanos, CEO Management Response: Since the audit, we have started to keep the documentation for each salary increase and review in the employee’s personnel files and the supplies that have been purchased.
Condition: During the audit it was noted that instances of wages submitted for reimbursement for two Club employees were more than gross wages that should have been assigned to the grant based on the amount of the paycheck and the percentage allocation. Plan: The Club plans to review the issue with ...
Condition: During the audit it was noted that instances of wages submitted for reimbursement for two Club employees were more than gross wages that should have been assigned to the grant based on the amount of the paycheck and the percentage allocation. Plan: The Club plans to review the issue with its current procedures and revise them as necessary to provide better controls over grant expenditures. Anticipated Date of Completion: As soon as possible – before FY25 year end Name of Contact Person: Germain Castellanos, CEO Management Response: Since the audit, we have evaluated our procedures related to grant reimbursement requests review and we are working on improving our current procedures.
View Audit 353845 Questioned Costs: $1
The University will review and enhance its procedures and internal controls to monitor or ensure the completeness and accuracy of all federal grants, to ensure they are separately recorded within the general ledger and all expenditures and activities are processed in accordance with applicable feder...
The University will review and enhance its procedures and internal controls to monitor or ensure the completeness and accuracy of all federal grants, to ensure they are separately recorded within the general ledger and all expenditures and activities are processed in accordance with applicable federal guidelines. The campus will implement effort reporting procedures for the SNAP Cluster program that include accounting for all employee activities for the program and the University implement appropriate controls to ensure costs charges to the SNAP program are based on actual costs incurred and are properly determined and calculated based upon the Uniform Guidance allowable cost criteria.
View Audit 353823 Questioned Costs: $1
Finding 555146 (2023-003)
Significant Deficiency 2023
Views of Responsible Officials: SAMU has finalized comprehensive Logistics and procurement policy that covers the credit cards policy and the respective treatment and control for approvals. A comprehensive corrective action plan has been greed it addresses: 1. Establishment of a documented review pr...
Views of Responsible Officials: SAMU has finalized comprehensive Logistics and procurement policy that covers the credit cards policy and the respective treatment and control for approvals. A comprehensive corrective action plan has been greed it addresses: 1. Establishment of a documented review process with clear timelines 2. Training program for staff on federal cost principles and internal procedures 3. Regular monitoring and internal audit procedures By implementing these measures, SAMU emphasizes the importance of strengthened internal controls, ensure compliance with federal regulations, and mitigate the risk of charging unallowable costs to federal awards.
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Bart Cook,...
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Bart Cook, Executive Director, is responsible for implementing this corrective action by September 30, 2024.
View Audit 353750 Questioned Costs: $1
Finding 555110 (2023-001)
Material Weakness 2023
Effective October 1, 2023, management implemented extensive accounting and documentation controls to ensure full accounting and reporting compliance on direct costs incurred for all federal grants and expenditures. These controls are reviewed and monitored for compliance by management on a periodic ...
Effective October 1, 2023, management implemented extensive accounting and documentation controls to ensure full accounting and reporting compliance on direct costs incurred for all federal grants and expenditures. These controls are reviewed and monitored for compliance by management on a periodic basis during the year.
View Audit 353705 Questioned Costs: $1
2023-001 Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: Metropolitan Transportation Commission Award Year: 2023 Grant Award Number: MTC/STP Agreement Compliance Requirements: Other - Title 2 ...
2023-001 Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: Metropolitan Transportation Commission Award Year: 2023 Grant Award Number: MTC/STP Agreement Compliance Requirements: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b)- Schedule of expenditures of Federal awards Recommendation: VTA should establish policies and implement internal controls to ensure all federal expenditures are accurately identified on the Schedule of Expenditures of Federal Awards (SEFA). Corrective Action: VTA will reinforce its system of internal control in communicating timely the Catalog of Federal Domestic Assistance (CFDA) number to the department preparing the SEFA. CFDA of direct and pass-through grants will be obtained from the Federal Transit Administration (FTA) and related grantors, respectively. If the CFDA number of a grant is not available at the time of preparation of SEFA, this will be identified accordingly. Responsible Party: The Fiscal Resources Manager and the Transportation Planners, Grants Implementation Date: March 31, 2025
Finding 554897 (2023-005)
Material Weakness 2023
Finding Number: 2023-005 Activities Allowed or Unallowed; Allowable Costs/Cost Principles (Material Weakness) Programs: Unaccompanied Alien Children Program ALN#93.676 Contract#: 90ZU0323 & 90ZU0548 Contract Period: 07/01/22 - 06/30/23 Planned Corrective Action: The auditors noted that management’...
Finding Number: 2023-005 Activities Allowed or Unallowed; Allowable Costs/Cost Principles (Material Weakness) Programs: Unaccompanied Alien Children Program ALN#93.676 Contract#: 90ZU0323 & 90ZU0548 Contract Period: 07/01/22 - 06/30/23 Planned Corrective Action: The auditors noted that management’s method for allocating shared personnel costs was performed after the close of the fiscal year, rather than through timely allocations made throughout the year. Additionally, during testing of 60 payroll samples, the auditors were unable to obtain sufficient documentation to support the approved pay rates for two employees. Beginning in FY 2025, personnel costs are being manually recorded to the correct cost centers in Serenic Navigator each month. A parallel review of employee setups in ADP, our payroll system, led to the reassignment of staff to appropriate cost centers as needed. Going forward, ADP cost center assignments will be reviewed monthly to reflect any departmental changes. These steps are expected to reduce manual adjustments, improve the accuracy of interim financials, and ensure more precise federal and program drawdowns. With respect to the two instances where documentation supporting employee pay rate approvals could not be located, management acknowledges the oversight. These cases appear to be isolated. To address this, we have implemented a more formalized process for documenting and storing all personnel actions, including pay rate approvals. All compensation-related approvals are now required to be documented in writing and retained in a centralized digital personnel file accessible to HR and Finance. These corrective actions are intended to strengthen internal controls over payroll and personnel cost allocations and ensure full compliance with federal and organizational requirements going forward. Person Responsible: The Executive Director and Chief Financial Officer Completion Date: April 30, 2025
Finding 554895 (2023-003)
Material Weakness 2023
Finding Number: 2023-003 Allowable Costs; Cash Management (Material Weakness) Programs: Unaccompanied Alien Children Program ALN#93.676 Contract#: 90ZU0323 & 90ZU0548 Contract Period: 07/01/22 - 06/30/23 Planned Corrective Action: The auditors noted that certain payroll expenses and other than ...
Finding Number: 2023-003 Allowable Costs; Cash Management (Material Weakness) Programs: Unaccompanied Alien Children Program ALN#93.676 Contract#: 90ZU0323 & 90ZU0548 Contract Period: 07/01/22 - 06/30/23 Planned Corrective Action: The auditors noted that certain payroll expenses and other than personnel service (OTPS) expenses are not being charged directly or allocated to the correct cost center in the accounting system monthly. Therefore, the amounts being drawn down during any given month may not be fully supported until the year-end when a reallocation of costs by function occurs. Beginning in FY 2025, personnel costs are being manually recorded to the correct cost centers in Serenic Navigator each month. A parallel review of employee setups in ADP, our payroll system, led to the reassignment of staff to appropriate cost centers as needed. Going forward, ADP cost center assignments will be reviewed monthly to reflect any departmental changes. These steps are expected to reduce manual adjustments, improve the accuracy of interim financials, and ensure more precise federal and program drawdowns. Additionally, OTPS expenses have been charged directly or allocated to the appropriate cost centers on a monthly basis since the start of FY 2025. Person Responsible: The Executive Director and Chief Financial Officer Completion Date: April 30, 2025
Finding 554893 (2023-001)
Material Weakness 2023
Finding Number: 2023-001 Cost Allocations – (Material Weakness) Planned Corrective Action: The auditors noted that payroll and the related personnel costs are not being charged directly or allocated to the correct cost center in the Serenic Navigator accounting system monthly. The Finance team perf...
Finding Number: 2023-001 Cost Allocations – (Material Weakness) Planned Corrective Action: The auditors noted that payroll and the related personnel costs are not being charged directly or allocated to the correct cost center in the Serenic Navigator accounting system monthly. The Finance team performed manual calculations of all allocations in Excel at the end of the fiscal year to update the allocations. Beginning in FY 2025, personnel costs are being manually recorded to the correct cost centers in Serenic Navigator each month. A parallel review of employee setups in ADP, our payroll system, led to the reassignment of staff to appropriate cost centers as needed. Going forward, ADP cost center assignments will be reviewed monthly to reflect any departmental changes. These steps are expected to reduce manual adjustments, improve the accuracy of interim financials, and ensure more precise federal and program drawdowns. Person Responsible: The Executive Director and Chief Financial Officer Completion Date: April 30, 2025
Financial Statement Finding: 2023-007 Noncompliance with Uniform Guidance Late Filing of Single Audit Reporting Package Criteria: Under the Single Audit Act of 1996 and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements f...
Financial Statement Finding: 2023-007 Noncompliance with Uniform Guidance Late Filing of Single Audit Reporting Package Criteria: Under the Single Audit Act of 1996 and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), §200.512, Report Submission, the Single audit reporting package is required to be filed within the earlier of 30 calendar days after receipt of the auditors' report, or 9 months after the end of the audit period. Cause/Condition: Staffing shortages caused the delays in financial reporting. This deadline was not met on a timely basis for the year ended December 31, 2023. Effect: As a result, the entity is not incompliance with §200.512 of the Uniform Guidance. Recommendation: We recommend the requirements of §200.512 of the Uniform guidance be adhered to by striving to have all information required for the audit available on a timely basis. This will help to ensure timely audit report issuance and compliance with the filing deadline. Response: The City is still facing staffing shortages and is working to get the subsequent financial statements completed. It is expected the 2024 reporting package will be filed on time. Corrective Action Plan: The City has hired a full complement of staff in the Finance department, and anticipates timely filings going forward. Anticipated Completed Date: September 30, 2025. Responsible Contact Person: Elizabeth Greenwood, Director of Administration & Finance
The Department will enforce policies and procedures to ensure that the calculated rates are in agreement with the approved indirect cost rate.
The Department will enforce policies and procedures to ensure that the calculated rates are in agreement with the approved indirect cost rate.
View Audit 353088 Questioned Costs: $1
Material Weakness in Compliance and Internal Control over Compliance Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding ...
Material Weakness in Compliance and Internal Control over Compliance Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets. There is no disagreement with the audit finding. Action taken in response to finding: ICEDC appreciates CLA’s recommendation to enhance processes concerning the retention of documentary evidence of approvals and importance of maintaining strong oversight of expenditures, especially when handling federal funds. ICEDC will place greater emphasis on obtaining and retaining documentation of approvals related to the expenditure of funds. This documentation will serve as proof of oversight, ensuring compliance with federal regulations and enhancing transparency in fund management. A formal review and approval process will be established for the Executive Director's (ED’s) timesheets. This process will involve periodic reviews by a designated authority and documentation will be retained to maintain a clear audit trail. Name(s) of the contact person(s) responsible for corrective action: Kristina Hines Planned completion date for corrective action plan: 8/31/2025
View Audit 353072 Questioned Costs: $1
Federal Program Education Stabilization Fund - Passed through the Pennsylvania Department of Education COVID-19 - Elementary and Secondary School Emergency Relief Fund (ARP ESSER) ALN 84.425U; Contract #223-21-0141; Grant Period 03/13/20 - 09/30/24 COVID-19 - ARP ESSER Learning Loss Set Aside ALN 84...
Federal Program Education Stabilization Fund - Passed through the Pennsylvania Department of Education COVID-19 - Elementary and Secondary School Emergency Relief Fund (ARP ESSER) ALN 84.425U; Contract #223-21-0141; Grant Period 03/13/20 - 09/30/24 COVID-19 - ARP ESSER Learning Loss Set Aside ALN 84.425U; Contract #225-21-0141; Grant Period 03/13/20 - 09/30/24 Criteria In accordance with Uniform Guidance Post Federal Award Requirements, the District 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. Condition The District did not maintain effective internal controls over the Federal awards. Two invoices were coded to the grants that were paid without documented approval. Cause The District did not follow documented internal control procedures which require all disbursements to have an approved purchase order or invoice signed by an administrator. Effect By paying invoices coded to Federal grants without approval, the District is not verifying the allowability of invoices. This increases the risk that unallowable activities and costs can be charged to the Federal grants and go undetected. Questioned Costs None. Context The Education Stabilization Fund grant nonpayroll costs were made up of 23 invoices. We tested three individually significant and five sampled invoices. Of the five sampled invoices, we found that two invoices were paid without approval. However, no discrepancies were identified in the allowability of the invoices. Repeat Finding No. Recommendation We recommend the District follow documented internal control procedures requiring all disbursements have an approved purchase order or signed invoice. This will ensure that invoices coded to Federal grants are reviewed for allowability before they are applied to the grants. Management Response This has been rectified. The district had a vacancy in the Federal Program Coordinator. Either the new Federal program Coordinator or the Business Administrator will approve and initial the invoices prior to payment.
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