Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Finding 2023-001: Reporting Federal Programs: U.S. Department of Health and Human Services (HHS) ALN 93.600 Criteria: HHS requires that Educare submit certain programmatic and other reports in accordance with the schedules indicated in its grant agreements. The reports support the recipient's performance under the grant and document achievement of program goals and objectives (2 CFR §200.301(a)). Condition: During our audit, we noted that the Tangible Personal Property Report (SF-428) was not submitted within the deadlines outlined in the grant agreement. Cause: Educare has internal controls in place to identify reports and file them timely in accordance with the terms and conditions of its grant agreements. However, in relation to the SF-428 report, the internal controls were not operating effectively. Effect or Potential Effect: A required report was not identified and timely filed. Questioned Costs: None. Context: One report out of the sample of four reports tested was not identified and submitted on a timely basis. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Educare enhance internal controls to ensure the identification and timely submission of all required reports.
Finding 2023-001: Reporting Federal Programs: U.S. Department of Health and Human Services (HHS) ALN 93.600 Criteria: HHS requires that Educare submit certain programmatic and other reports in accordance with the schedules indicated in its grant agreements. The reports support the recipient's performance under the grant and document achievement of program goals and objectives (2 CFR §200.301(a)). Condition: During our audit, we noted that the Tangible Personal Property Report (SF-428) was not submitted within the deadlines outlined in the grant agreement. Cause: Educare has internal controls in place to identify reports and file them timely in accordance with the terms and conditions of its grant agreements. However, in relation to the SF-428 report, the internal controls were not operating effectively. Effect or Potential Effect: A required report was not identified and timely filed. Questioned Costs: None. Context: One report out of the sample of four reports tested was not identified and submitted on a timely basis. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Educare enhance internal controls to ensure the identification and timely submission of all required reports.
Finding 2023-001: Reporting Federal Programs: U.S. Department of Health and Human Services (HHS) ALN 93.600 Criteria: HHS requires that Educare submit certain programmatic and other reports in accordance with the schedules indicated in its grant agreements. The reports support the recipient's performance under the grant and document achievement of program goals and objectives (2 CFR §200.301(a)). Condition: During our audit, we noted that the Tangible Personal Property Report (SF-428) was not submitted within the deadlines outlined in the grant agreement. Cause: Educare has internal controls in place to identify reports and file them timely in accordance with the terms and conditions of its grant agreements. However, in relation to the SF-428 report, the internal controls were not operating effectively. Effect or Potential Effect: A required report was not identified and timely filed. Questioned Costs: None. Context: One report out of the sample of four reports tested was not identified and submitted on a timely basis. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend Educare enhance internal controls to ensure the identification and timely submission of all required reports.
Assistance Listings number and name: 10.691 Good Neighbor Authority Award numbers and year: 22-GN-11030400-027, January 14, 2022 through January 14, 2027 Federal agency: U.S. Department of Agriculture Compliance requirements: Reporting Questioned costs: None Condition—Contrary to federal regulations and the County’s federal award terms, the Flood Control Department (Department) failed to submit the required annual financial and performance reports for calendar year 2022 that were due on January 30, 2023. Effect—The Department not submitting the required financial and performance reports could potentially affect future federal funding and put the federal grantor at risk of not being able to carry out its oversight responsibilities and effectively evaluate the program’s success, and prevent and detect fraud. Cause—County management reported that the Department was aware of the program’s reporting requirements but had forgotten to complete them because the Department was focused on handling several natural disasters that were governor-declared emergencies. Further, the Department did not track its submission of reports so it was unaware that it had not submitted the missing reports. Criteria—Federal regulations and the County’s federal award terms require it to submit annual federal financial and performance reports to the U.S. Department of Agriculture no later than 30 days after calendar year-end that contain accurate, current, and complete information (2 CFR §§200.301 and 200.302). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The County should: 1. Require the Department to complete and submit all missing financial and performance reports to the federal agency as soon as possible. 2. Develop and implement revisions to its federal grant policies and procedures that require its departments to monitor and track when required reports are due and submitted to ensure they are completed and submitted on time. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
Assistance Listings numbers and names: 84.425D COVID-19 - Education Stabilization Fund—Elementary and Secondary School Emergency Relief (ESSER) Fund 84.425R COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS) Award numbers and years: S425D210038, March 13, 2020 through September 30, 2023; S425R210003, January 15, 2021 through September 30, 2024 Federal agency: U.S. Department of Education Compliance requirements: Reporting Questioned costs: Not applicable Condition—Contrary to federal regulations, the Department of Education (Department) reported inaccurate data for 4 local educational agencies (LEA) and 9 nonpublic schools on Annual Performance Reports (APR) submitted in fiscal year 2023. Specifically, the Department reported key line item information that did not agree to records and supporting documentation, as follows: • For 4 of 48 LEAs tested on the 2021 ESSER APR, certain key line items, including unique entity ID, total amount expended by activity, and allocation of ESSER resources within the LEA, did not agree to the LEAs’ files.1 • For 9 of 9 nonpublic schools tested on the 2022 CRRSA EANS APR, certain key line items, including reporting on State Education Agency obligations (including reimbursements) by allowable activity for CRRSA EANS and reporting on nonpublic schools receiving services or assistance under CRRSA EANS, did not agree to the schools’ files. The Department reported that this would likely be applicable to all 83 nonpublic schools the Department was required to report on. Effect—The Department’s reporting inaccurate program information results in the federal agency being unable to rely on the reports to effectively monitor the Department’s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the programs’ successes. The Department is also at risk that this finding applies to other federal programs it administers. Cause—The Department did not have written policies and procedures requiring a detailed, independent review of the APRs for accuracy prior to submission to the federal agency. Department staff reported to us that they were unaware these reports needed to be independently reviewed for accuracy prior to submitting them to the federal agency. Criteria—Federal regulations and the Department’s federal award terms require it to submit annual performance reports to the U.S. Department of Education containing accurate, current, and complete information (2 CFR §§200.301 and 200.302). Further, federal regulation also requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The Department should: 1. Report accurate data in the APRs that agree to records and supporting documentation contained in the LEAs’ or schools’ files, including reviewing, correcting, and/or resubmitting any inaccurately reported information. 2. Develop and implement written policies and procedures to require a detailed, independent review of the APRs for accuracy prior to their submission to the federal agency. The State’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 The 2021 ESSER APR was due June 17, 2022; however, the Department received an extension for a submission deadline of September 9, 2022. Per the 2023 Compliance Supplement as of August 12, 2024, it is not necessary for auditors to test whether APRs were submitted in a timely manner because the federal agency is able to verify timeliness.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 200.208 states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreements for the Village of Lafayette Water Line Project (B-W-20-1AB-1), the Gomer Wastewater Collection System Project (B-W-1AB-3) and Village of Harrod Water Line Project (B-W-20-1AB-2), state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however, three out of six (fifty percent) Status Reports were submitted between three to six months late and for one out of six (sixteen percent) Status Reports the receipts and expenditures did not agree to the County records. Reporting errors could adversely affect future grant awards. A control system should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
Federal Programs: 93.110 Criteria: Grantor requires that the Center submit programmatic reports in accordance with the schedules indicated in its grant agreements. Internal controls should provide for these reports to report the measurement of the recipient's performance to show achievement of program goals and objectives, share lessons learned, improve program outcomes, and foster adoption of promising practices (2 CFR §200.301(a)). Condition: During our audit, we were notified by management that certain programmatic reports were not submitted within the deadlines outlined in the grant agreements. We also noted the Center did not have evidence that certain programmatic reports were submitted in accordance with specific grant terms. Cause: The Center did not have the proper internal controls in place to ensure proper management of the Federal award(s) in compliance with the terms and conditions of the Federal award(s). Effect or Potential Effect: The performance progress according to the Federal award(s) may not be monitored, thus having potential unallowable costs or unallowable activities. Questioned Costs: None. Context: Several programmatic reports tested were not submitted on a timely basis. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Center develop proper internal controls to ensure appropriate tracking of reporting deadlines for all Federal awards to ensure the preparation and timely submission of all reports required under its Federal awards' terms and conditions.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 200.208 states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreements for the Village of Lafayette Water Line Project (B-W-20-1AB-1), the Gomer Wastewater Collection System Project (B-W-1AB-3) and Village of Harrod Water Line Project (B-W-20-1AB-2), state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however, three out of six (fifty percent) Status Reports were submitted between three to six months late and for one out of six (sixteen percent) Status Reports the receipts and expenditures did not agree to the County records. Reporting errors could adversely affect future grant awards. A control system should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
Federal Programs: 93.110 Criteria: Grantor requires that the Center submit programmatic reports in accordance with the schedules indicated in its grant agreements. Internal controls should provide for these reports to report the measurement of the recipient's performance to show achievement of program goals and objectives, share lessons learned, improve program outcomes, and foster adoption of promising practices (2 CFR §200.301(a)). Condition: During our audit, we were notified by management that certain programmatic reports were not submitted within the deadlines outlined in the grant agreements. We also noted the Center did not have evidence that certain programmatic reports were submitted in accordance with specific grant terms. Cause: The Center did not have the proper internal controls in place to ensure proper management of the Federal award(s) in compliance with the terms and conditions of the Federal award(s). Effect or Potential Effect: The performance progress according to the Federal award(s) may not be monitored, thus having potential unallowable costs or unallowable activities. Questioned Costs: None. Context: Several programmatic reports tested were not submitted on a timely basis. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Center develop proper internal controls to ensure appropriate tracking of reporting deadlines for all Federal awards to ensure the preparation and timely submission of all reports required under its Federal awards' terms and conditions.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 C.F.R. § 200.328 which states, unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. 2 CFR § 2400.101 gives regulatory effect to the Department of Housing and Urban Development for 2 CFR § 200.208 which states, in part, that Federal awarding agencies are responsible for ensuring that specific Federal award conditions are consistent with the program design reflected in § 200.202 and include clear performance expectations of recipients as required in § 200.301. The Federal awarding agency or pass- through entity may adjust specific Federal award conditions as needed, in accordance with this section, based on an analysis of specified factors. Additional Federal award conditions may be added provided the applicant or non-Federal entity has been notified, and any additional requirements must be promptly removed once the conditions that prompted them have been satisfied. Additional Federal award conditions may include items such as additional, more detailed financial reports. The State of Ohio Community Development Block Grant (CDBG) Program Grant Agreement for McConnelsville NRG Sewer Facility Improvements (B-F-19-1CA-1) state that the grantee shall submit the required reports in an adequate and timely fashion. Granter shall provide a format for these reports and shall instruct Grantee on the proper completion of said reports. All report forms and requirements listed herein shall be provided by Granter, but shall not be construed to limit Granter in making additional and/or further requests, nor in the change or addition of detail to the items listed. The Grantee shall submit to Granter a Status Report within 30 days of the request by Granter. The County submitted Status Reports; however possibly due to the failure of an existing control(s), one out of one (one hundred percent) of Status Reports were submitted seven months late. Reporting errors could adversely affect future grant awards. An additional control(s) and/or procedure(s) should be implemented to help ensure required reports are accurately prepared and submitted in a timely manner.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.