Finding 2023-001 - U.S. Department of Health and Human Services, Community Services Block Grant, Assistance Listing #93.569; U.S. Department of Housing and Urban Development, Housing Voucher Cluster, Assistance Listing #14.871/14.879 Statement of Condition: Internal control processes over financial accounting did not ensure that all transactions were properly recorded. Internal control processes over financial accounting did not ensure that key accounts were reconciled or reviewed on a periodic basis. Criteria: 2 CFR Part 200 Section 200.302 Financial Management states that the financial management system of each non-federal entity must provide accurate, current, and complete disclosure of the financial results of each Federal award in accordance with the reporting requirements. Additionally, 2 CFR Part 200 Section 200.303(a), Internal Controls, requires that non-federal entities must establish and maintain effective internal controls over the federal award that provides reasonable assurance that the non-federal entity is managing the award in compliance with federal statutes, regulations and the terms and conditions. Cause of Condition: Management oversight and lack of Finance Officer in place during period under audit. Effect of Condition: Noncompliance with HUD and Uniform Guidance requirements and the possibility of undetected material misstatements and/or undetected misappropriation of assets. Context: An understanding of processes and internal controls was performed with the Organization's management and tests were performed to determine if the processes and internal controls were implemented and effective. As part of this process we noted the following processes and internal controls were not effective and/or implemented. 1) Bank accounts were not reconciled during the year ending June 30, 2023. 2) Significant accounts were not reconciled. 3) Financial statements and/or reconciled financial information was not reviewed by management or the board of directors. While applying audit procedures, significant adjustments were identified as necessary to properly reflect the financial data in accordance with generally accepted accounting principles. Recommendation: We recommend management review/enhance its accounting and internal control procedures to ensure that all key accounts are reconciled and reviewed with supporting evidence of such review. Furthermore, we recommend that the Organization consider additional financial and accounting training. Questioned Costs: N/A Reporting Views of Responsible Officials: Management agrees with the finding and will review the accounting and financial procedures, system of internal controls and policies.
MATERIAL WEAKNESS 2023-002 WRITTEN FEDERAL PROCEDURES Federal Agency: Department of Agriculture, Department of Education Federal Program or Cluster: Child Nutrition Cluster Education Stabilization Fund Assistance Listing Number: 10.553, 10.555, 84.425D, 84.425U Federal Award Numbers and Years: Award Period 7/1/2022-6/30/23: K397 Award Period 3/13/20-9/30/22: S425D200013 Award Period 3/13/20-9/30/23: S425D210013 Award Period 6/24/2022-9/30/24: S425U210013 Questioned Costs: $0 Condition: The School's accounting and procedures manual did not include written policies or procedures that address all applicable compliance areas under the Uniform Guidance; for instance, allowable costs, procurement, equipment and real property and special tests and provisions. Criteria: The School must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in 2 CFR Section 200.302. Cause: The School was inattentive to all of the requirements in the Uniform Guidance. Effect: The absence of documented policies and procedures could result in noncompliance with the terms of federal awards. Recommendation: The School should document and adhere to written policies and procedures that reflect current OMB requirements under the Uniform Guidance. This accounting and procedures manual should be monitored and revised annually as necessary. Identification of repeat findings: This finding is a repeat finding previously included as finding number 2022-002 in the audit of the financial statements for the year ended June 30, 2022.
MATERIAL WEAKNESS 2023-002 WRITTEN FEDERAL PROCEDURES Federal Agency: Department of Agriculture, Department of Education Federal Program or Cluster: Child Nutrition Cluster Education Stabilization Fund Assistance Listing Number: 10.553, 10.555, 84.425D, 84.425U Federal Award Numbers and Years: Award Period 7/1/2022-6/30/23: K397 Award Period 3/13/20-9/30/22: S425D200013 Award Period 3/13/20-9/30/23: S425D210013 Award Period 6/24/2022-9/30/24: S425U210013 Questioned Costs: $0 Condition: The School's accounting and procedures manual did not include written policies or procedures that address all applicable compliance areas under the Uniform Guidance; for instance, allowable costs, procurement, equipment and real property and special tests and provisions. Criteria: The School must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in 2 CFR Section 200.302. Cause: The School was inattentive to all of the requirements in the Uniform Guidance. Effect: The absence of documented policies and procedures could result in noncompliance with the terms of federal awards. Recommendation: The School should document and adhere to written policies and procedures that reflect current OMB requirements under the Uniform Guidance. This accounting and procedures manual should be monitored and revised annually as necessary. Identification of repeat findings: This finding is a repeat finding previously included as finding number 2022-002 in the audit of the financial statements for the year ended June 30, 2022.
MATERIAL WEAKNESS 2023-002 WRITTEN FEDERAL PROCEDURES Federal Agency: Department of Agriculture, Department of Education Federal Program or Cluster: Child Nutrition Cluster Education Stabilization Fund Assistance Listing Number: 10.553, 10.555, 84.425D, 84.425U Federal Award Numbers and Years: Award Period 7/1/2022-6/30/23: K397 Award Period 3/13/20-9/30/22: S425D200013 Award Period 3/13/20-9/30/23: S425D210013 Award Period 6/24/2022-9/30/24: S425U210013 Questioned Costs: $0 Condition: The School's accounting and procedures manual did not include written policies or procedures that address all applicable compliance areas under the Uniform Guidance; for instance, allowable costs, procurement, equipment and real property and special tests and provisions. Criteria: The School must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in 2 CFR Section 200.302. Cause: The School was inattentive to all of the requirements in the Uniform Guidance. Effect: The absence of documented policies and procedures could result in noncompliance with the terms of federal awards. Recommendation: The School should document and adhere to written policies and procedures that reflect current OMB requirements under the Uniform Guidance. This accounting and procedures manual should be monitored and revised annually as necessary. Identification of repeat findings: This finding is a repeat finding previously included as finding number 2022-002 in the audit of the financial statements for the year ended June 30, 2022.
MATERIAL WEAKNESS 2023-002 WRITTEN FEDERAL PROCEDURES Federal Agency: Department of Agriculture, Department of Education Federal Program or Cluster: Child Nutrition Cluster Education Stabilization Fund Assistance Listing Number: 10.553, 10.555, 84.425D, 84.425U Federal Award Numbers and Years: Award Period 7/1/2022-6/30/23: K397 Award Period 3/13/20-9/30/22: S425D200013 Award Period 3/13/20-9/30/23: S425D210013 Award Period 6/24/2022-9/30/24: S425U210013 Questioned Costs: $0 Condition: The School's accounting and procedures manual did not include written policies or procedures that address all applicable compliance areas under the Uniform Guidance; for instance, allowable costs, procurement, equipment and real property and special tests and provisions. Criteria: The School must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in 2 CFR Section 200.302. Cause: The School was inattentive to all of the requirements in the Uniform Guidance. Effect: The absence of documented policies and procedures could result in noncompliance with the terms of federal awards. Recommendation: The School should document and adhere to written policies and procedures that reflect current OMB requirements under the Uniform Guidance. This accounting and procedures manual should be monitored and revised annually as necessary. Identification of repeat findings: This finding is a repeat finding previously included as finding number 2022-002 in the audit of the financial statements for the year ended June 30, 2022.
MATERIAL WEAKNESS 2023-002 WRITTEN FEDERAL PROCEDURES Federal Agency: Department of Agriculture, Department of Education Federal Program or Cluster: Child Nutrition Cluster Education Stabilization Fund Assistance Listing Number: 10.553, 10.555, 84.425D, 84.425U Federal Award Numbers and Years: Award Period 7/1/2022-6/30/23: K397 Award Period 3/13/20-9/30/22: S425D200013 Award Period 3/13/20-9/30/23: S425D210013 Award Period 6/24/2022-9/30/24: S425U210013 Questioned Costs: $0 Condition: The School's accounting and procedures manual did not include written policies or procedures that address all applicable compliance areas under the Uniform Guidance; for instance, allowable costs, procurement, equipment and real property and special tests and provisions. Criteria: The School must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in 2 CFR Section 200.302. Cause: The School was inattentive to all of the requirements in the Uniform Guidance. Effect: The absence of documented policies and procedures could result in noncompliance with the terms of federal awards. Recommendation: The School should document and adhere to written policies and procedures that reflect current OMB requirements under the Uniform Guidance. This accounting and procedures manual should be monitored and revised annually as necessary. Identification of repeat findings: This finding is a repeat finding previously included as finding number 2022-002 in the audit of the financial statements for the year ended June 30, 2022.
MATERIAL WEAKNESS 2023-002 WRITTEN FEDERAL PROCEDURES Federal Agency: Department of Agriculture, Department of Education Federal Program or Cluster: Child Nutrition Cluster Education Stabilization Fund Assistance Listing Number: 10.553, 10.555, 84.425D, 84.425U Federal Award Numbers and Years: Award Period 7/1/2022-6/30/23: K397 Award Period 3/13/20-9/30/22: S425D200013 Award Period 3/13/20-9/30/23: S425D210013 Award Period 6/24/2022-9/30/24: S425U210013 Questioned Costs: $0 Condition: The School's accounting and procedures manual did not include written policies or procedures that address all applicable compliance areas under the Uniform Guidance; for instance, allowable costs, procurement, equipment and real property and special tests and provisions. Criteria: The School must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in 2 CFR Section 200.302. Cause: The School was inattentive to all of the requirements in the Uniform Guidance. Effect: The absence of documented policies and procedures could result in noncompliance with the terms of federal awards. Recommendation: The School should document and adhere to written policies and procedures that reflect current OMB requirements under the Uniform Guidance. This accounting and procedures manual should be monitored and revised annually as necessary. Identification of repeat findings: This finding is a repeat finding previously included as finding number 2022-002 in the audit of the financial statements for the year ended June 30, 2022.
MATERIAL WEAKNESS 2023-002 WRITTEN FEDERAL PROCEDURES Federal Agency: Department of Agriculture, Department of Education Federal Program or Cluster: Child Nutrition Cluster Education Stabilization Fund Assistance Listing Number: 10.553, 10.555, 84.425D, 84.425U Federal Award Numbers and Years: Award Period 7/1/2022-6/30/23: K397 Award Period 3/13/20-9/30/22: S425D200013 Award Period 3/13/20-9/30/23: S425D210013 Award Period 6/24/2022-9/30/24: S425U210013 Questioned Costs: $0 Condition: The School's accounting and procedures manual did not include written policies or procedures that address all applicable compliance areas under the Uniform Guidance; for instance, allowable costs, procurement, equipment and real property and special tests and provisions. Criteria: The School must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in 2 CFR Section 200.302. Cause: The School was inattentive to all of the requirements in the Uniform Guidance. Effect: The absence of documented policies and procedures could result in noncompliance with the terms of federal awards. Recommendation: The School should document and adhere to written policies and procedures that reflect current OMB requirements under the Uniform Guidance. This accounting and procedures manual should be monitored and revised annually as necessary. Identification of repeat findings: This finding is a repeat finding previously included as finding number 2022-002 in the audit of the financial statements for the year ended June 30, 2022.
MATERIAL WEAKNESS 2023-002 WRITTEN FEDERAL PROCEDURES Federal Agency: Department of Agriculture, Department of Education Federal Program or Cluster: Child Nutrition Cluster Education Stabilization Fund Assistance Listing Number: 10.553, 10.555, 84.425D, 84.425U Federal Award Numbers and Years: Award Period 7/1/2022-6/30/23: K397 Award Period 3/13/20-9/30/22: S425D200013 Award Period 3/13/20-9/30/23: S425D210013 Award Period 6/24/2022-9/30/24: S425U210013 Questioned Costs: $0 Condition: The School's accounting and procedures manual did not include written policies or procedures that address all applicable compliance areas under the Uniform Guidance; for instance, allowable costs, procurement, equipment and real property and special tests and provisions. Criteria: The School must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in 2 CFR Section 200.302. Cause: The School was inattentive to all of the requirements in the Uniform Guidance. Effect: The absence of documented policies and procedures could result in noncompliance with the terms of federal awards. Recommendation: The School should document and adhere to written policies and procedures that reflect current OMB requirements under the Uniform Guidance. This accounting and procedures manual should be monitored and revised annually as necessary. Identification of repeat findings: This finding is a repeat finding previously included as finding number 2022-002 in the audit of the financial statements for the year ended June 30, 2022.
MATERIAL WEAKNESS 2023-002 WRITTEN FEDERAL PROCEDURES Federal Agency: Department of Agriculture, Department of Education Federal Program or Cluster: Child Nutrition Cluster Education Stabilization Fund Assistance Listing Number: 10.553, 10.555, 84.425D, 84.425U Federal Award Numbers and Years: Award Period 7/1/2022-6/30/23: K397 Award Period 3/13/20-9/30/22: S425D200013 Award Period 3/13/20-9/30/23: S425D210013 Award Period 6/24/2022-9/30/24: S425U210013 Questioned Costs: $0 Condition: The School's accounting and procedures manual did not include written policies or procedures that address all applicable compliance areas under the Uniform Guidance; for instance, allowable costs, procurement, equipment and real property and special tests and provisions. Criteria: The School must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in 2 CFR Section 200.302. Cause: The School was inattentive to all of the requirements in the Uniform Guidance. Effect: The absence of documented policies and procedures could result in noncompliance with the terms of federal awards. Recommendation: The School should document and adhere to written policies and procedures that reflect current OMB requirements under the Uniform Guidance. This accounting and procedures manual should be monitored and revised annually as necessary. Identification of repeat findings: This finding is a repeat finding previously included as finding number 2022-002 in the audit of the financial statements for the year ended June 30, 2022.
MATERIAL WEAKNESS 2023-002 WRITTEN FEDERAL PROCEDURES Federal Agency: Department of Agriculture, Department of Education Federal Program or Cluster: Child Nutrition Cluster Education Stabilization Fund Assistance Listing Number: 10.553, 10.555, 84.425D, 84.425U Federal Award Numbers and Years: Award Period 7/1/2022-6/30/23: K397 Award Period 3/13/20-9/30/22: S425D200013 Award Period 3/13/20-9/30/23: S425D210013 Award Period 6/24/2022-9/30/24: S425U210013 Questioned Costs: $0 Condition: The School's accounting and procedures manual did not include written policies or procedures that address all applicable compliance areas under the Uniform Guidance; for instance, allowable costs, procurement, equipment and real property and special tests and provisions. Criteria: The School must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in 2 CFR Section 200.302. Cause: The School was inattentive to all of the requirements in the Uniform Guidance. Effect: The absence of documented policies and procedures could result in noncompliance with the terms of federal awards. Recommendation: The School should document and adhere to written policies and procedures that reflect current OMB requirements under the Uniform Guidance. This accounting and procedures manual should be monitored and revised annually as necessary. Identification of repeat findings: This finding is a repeat finding previously included as finding number 2022-002 in the audit of the financial statements for the year ended June 30, 2022.
MATERIAL WEAKNESS 2023-002 WRITTEN FEDERAL PROCEDURES Federal Agency: Department of Agriculture, Department of Education Federal Program or Cluster: Child Nutrition Cluster Education Stabilization Fund Assistance Listing Number: 10.553, 10.555, 84.425D, 84.425U Federal Award Numbers and Years: Award Period 7/1/2022-6/30/23: K397 Award Period 3/13/20-9/30/22: S425D200013 Award Period 3/13/20-9/30/23: S425D210013 Award Period 6/24/2022-9/30/24: S425U210013 Questioned Costs: $0 Condition: The School's accounting and procedures manual did not include written policies or procedures that address all applicable compliance areas under the Uniform Guidance; for instance, allowable costs, procurement, equipment and real property and special tests and provisions. Criteria: The School must establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award as stated in 2 CFR Section 200.302. Cause: The School was inattentive to all of the requirements in the Uniform Guidance. Effect: The absence of documented policies and procedures could result in noncompliance with the terms of federal awards. Recommendation: The School should document and adhere to written policies and procedures that reflect current OMB requirements under the Uniform Guidance. This accounting and procedures manual should be monitored and revised annually as necessary. Identification of repeat findings: This finding is a repeat finding previously included as finding number 2022-002 in the audit of the financial statements for the year ended June 30, 2022.
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.
2023-014 Inability to Test Compliance and Adequacy of Federal Grant Expenditures (Material Weakness) Federal Agency: All Compliance Requirement: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Uniform Guidance (2 CFR 200.302(b)(3)) requires recipients of federal funds to maintain records that adequately identify the source and application of funds and ensure compliance with program requirements. Condition: We are unable to test compliance with federal program requirements due to pervasive discrepancies in the School District’s accounting for federal grants. Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be supported or reconciled to the School District’s financial records. Cause: Inadequate grant accounting procedures and internal controls over federal program expenditures. Effect: We are unable to determine compliance with federal program requirements or assess the allowability of expenditures. A disclaimer of opinion was issued for compliance with major program requirements. Questioned Costs: Unable to determine. We cannot quantify questioned costs because no testing could be performed, and the scope limitation affects all reported federal expenditures. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement procedures to ensure grant expenditures are properly accounted for and supported by sufficient documentation. The School District should develop internal controls to ensure accurate and complete reporting on the SEFA. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-014 Inability to Test Compliance and Adequacy of Federal Grant Expenditures (Material Weakness) Federal Agency: All Compliance Requirement: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Uniform Guidance (2 CFR 200.302(b)(3)) requires recipients of federal funds to maintain records that adequately identify the source and application of funds and ensure compliance with program requirements. Condition: We are unable to test compliance with federal program requirements due to pervasive discrepancies in the School District’s accounting for federal grants. Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be supported or reconciled to the School District’s financial records. Cause: Inadequate grant accounting procedures and internal controls over federal program expenditures. Effect: We are unable to determine compliance with federal program requirements or assess the allowability of expenditures. A disclaimer of opinion was issued for compliance with major program requirements. Questioned Costs: Unable to determine. We cannot quantify questioned costs because no testing could be performed, and the scope limitation affects all reported federal expenditures. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement procedures to ensure grant expenditures are properly accounted for and supported by sufficient documentation. The School District should develop internal controls to ensure accurate and complete reporting on the SEFA. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-014 Inability to Test Compliance and Adequacy of Federal Grant Expenditures (Material Weakness) Federal Agency: All Compliance Requirement: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Uniform Guidance (2 CFR 200.302(b)(3)) requires recipients of federal funds to maintain records that adequately identify the source and application of funds and ensure compliance with program requirements. Condition: We are unable to test compliance with federal program requirements due to pervasive discrepancies in the School District’s accounting for federal grants. Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be supported or reconciled to the School District’s financial records. Cause: Inadequate grant accounting procedures and internal controls over federal program expenditures. Effect: We are unable to determine compliance with federal program requirements or assess the allowability of expenditures. A disclaimer of opinion was issued for compliance with major program requirements. Questioned Costs: Unable to determine. We cannot quantify questioned costs because no testing could be performed, and the scope limitation affects all reported federal expenditures. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement procedures to ensure grant expenditures are properly accounted for and supported by sufficient documentation. The School District should develop internal controls to ensure accurate and complete reporting on the SEFA. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-014 Inability to Test Compliance and Adequacy of Federal Grant Expenditures (Material Weakness) Federal Agency: All Compliance Requirement: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Uniform Guidance (2 CFR 200.302(b)(3)) requires recipients of federal funds to maintain records that adequately identify the source and application of funds and ensure compliance with program requirements. Condition: We are unable to test compliance with federal program requirements due to pervasive discrepancies in the School District’s accounting for federal grants. Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be supported or reconciled to the School District’s financial records. Cause: Inadequate grant accounting procedures and internal controls over federal program expenditures. Effect: We are unable to determine compliance with federal program requirements or assess the allowability of expenditures. A disclaimer of opinion was issued for compliance with major program requirements. Questioned Costs: Unable to determine. We cannot quantify questioned costs because no testing could be performed, and the scope limitation affects all reported federal expenditures. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement procedures to ensure grant expenditures are properly accounted for and supported by sufficient documentation. The School District should develop internal controls to ensure accurate and complete reporting on the SEFA. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-014 Inability to Test Compliance and Adequacy of Federal Grant Expenditures (Material Weakness) Federal Agency: All Compliance Requirement: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Uniform Guidance (2 CFR 200.302(b)(3)) requires recipients of federal funds to maintain records that adequately identify the source and application of funds and ensure compliance with program requirements. Condition: We are unable to test compliance with federal program requirements due to pervasive discrepancies in the School District’s accounting for federal grants. Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be supported or reconciled to the School District’s financial records. Cause: Inadequate grant accounting procedures and internal controls over federal program expenditures. Effect: We are unable to determine compliance with federal program requirements or assess the allowability of expenditures. A disclaimer of opinion was issued for compliance with major program requirements. Questioned Costs: Unable to determine. We cannot quantify questioned costs because no testing could be performed, and the scope limitation affects all reported federal expenditures. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement procedures to ensure grant expenditures are properly accounted for and supported by sufficient documentation. The School District should develop internal controls to ensure accurate and complete reporting on the SEFA. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-014 Inability to Test Compliance and Adequacy of Federal Grant Expenditures (Material Weakness) Federal Agency: All Compliance Requirement: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Uniform Guidance (2 CFR 200.302(b)(3)) requires recipients of federal funds to maintain records that adequately identify the source and application of funds and ensure compliance with program requirements. Condition: We are unable to test compliance with federal program requirements due to pervasive discrepancies in the School District’s accounting for federal grants. Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be supported or reconciled to the School District’s financial records. Cause: Inadequate grant accounting procedures and internal controls over federal program expenditures. Effect: We are unable to determine compliance with federal program requirements or assess the allowability of expenditures. A disclaimer of opinion was issued for compliance with major program requirements. Questioned Costs: Unable to determine. We cannot quantify questioned costs because no testing could be performed, and the scope limitation affects all reported federal expenditures. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement procedures to ensure grant expenditures are properly accounted for and supported by sufficient documentation. The School District should develop internal controls to ensure accurate and complete reporting on the SEFA. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-014 Inability to Test Compliance and Adequacy of Federal Grant Expenditures (Material Weakness) Federal Agency: All Compliance Requirement: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Uniform Guidance (2 CFR 200.302(b)(3)) requires recipients of federal funds to maintain records that adequately identify the source and application of funds and ensure compliance with program requirements. Condition: We are unable to test compliance with federal program requirements due to pervasive discrepancies in the School District’s accounting for federal grants. Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be supported or reconciled to the School District’s financial records. Cause: Inadequate grant accounting procedures and internal controls over federal program expenditures. Effect: We are unable to determine compliance with federal program requirements or assess the allowability of expenditures. A disclaimer of opinion was issued for compliance with major program requirements. Questioned Costs: Unable to determine. We cannot quantify questioned costs because no testing could be performed, and the scope limitation affects all reported federal expenditures. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement procedures to ensure grant expenditures are properly accounted for and supported by sufficient documentation. The School District should develop internal controls to ensure accurate and complete reporting on the SEFA. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-014 Inability to Test Compliance and Adequacy of Federal Grant Expenditures (Material Weakness) Federal Agency: All Compliance Requirement: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Uniform Guidance (2 CFR 200.302(b)(3)) requires recipients of federal funds to maintain records that adequately identify the source and application of funds and ensure compliance with program requirements. Condition: We are unable to test compliance with federal program requirements due to pervasive discrepancies in the School District’s accounting for federal grants. Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be supported or reconciled to the School District’s financial records. Cause: Inadequate grant accounting procedures and internal controls over federal program expenditures. Effect: We are unable to determine compliance with federal program requirements or assess the allowability of expenditures. A disclaimer of opinion was issued for compliance with major program requirements. Questioned Costs: Unable to determine. We cannot quantify questioned costs because no testing could be performed, and the scope limitation affects all reported federal expenditures. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement procedures to ensure grant expenditures are properly accounted for and supported by sufficient documentation. The School District should develop internal controls to ensure accurate and complete reporting on the SEFA. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-014 Inability to Test Compliance and Adequacy of Federal Grant Expenditures (Material Weakness) Federal Agency: All Compliance Requirement: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Uniform Guidance (2 CFR 200.302(b)(3)) requires recipients of federal funds to maintain records that adequately identify the source and application of funds and ensure compliance with program requirements. Condition: We are unable to test compliance with federal program requirements due to pervasive discrepancies in the School District’s accounting for federal grants. Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be supported or reconciled to the School District’s financial records. Cause: Inadequate grant accounting procedures and internal controls over federal program expenditures. Effect: We are unable to determine compliance with federal program requirements or assess the allowability of expenditures. A disclaimer of opinion was issued for compliance with major program requirements. Questioned Costs: Unable to determine. We cannot quantify questioned costs because no testing could be performed, and the scope limitation affects all reported federal expenditures. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement procedures to ensure grant expenditures are properly accounted for and supported by sufficient documentation. The School District should develop internal controls to ensure accurate and complete reporting on the SEFA. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-014 Inability to Test Compliance and Adequacy of Federal Grant Expenditures (Material Weakness) Federal Agency: All Compliance Requirement: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Uniform Guidance (2 CFR 200.302(b)(3)) requires recipients of federal funds to maintain records that adequately identify the source and application of funds and ensure compliance with program requirements. Condition: We are unable to test compliance with federal program requirements due to pervasive discrepancies in the School District’s accounting for federal grants. Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be supported or reconciled to the School District’s financial records. Cause: Inadequate grant accounting procedures and internal controls over federal program expenditures. Effect: We are unable to determine compliance with federal program requirements or assess the allowability of expenditures. A disclaimer of opinion was issued for compliance with major program requirements. Questioned Costs: Unable to determine. We cannot quantify questioned costs because no testing could be performed, and the scope limitation affects all reported federal expenditures. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement procedures to ensure grant expenditures are properly accounted for and supported by sufficient documentation. The School District should develop internal controls to ensure accurate and complete reporting on the SEFA. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-014 Inability to Test Compliance and Adequacy of Federal Grant Expenditures (Material Weakness) Federal Agency: All Compliance Requirement: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Uniform Guidance (2 CFR 200.302(b)(3)) requires recipients of federal funds to maintain records that adequately identify the source and application of funds and ensure compliance with program requirements. Condition: We are unable to test compliance with federal program requirements due to pervasive discrepancies in the School District’s accounting for federal grants. Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be supported or reconciled to the School District’s financial records. Cause: Inadequate grant accounting procedures and internal controls over federal program expenditures. Effect: We are unable to determine compliance with federal program requirements or assess the allowability of expenditures. A disclaimer of opinion was issued for compliance with major program requirements. Questioned Costs: Unable to determine. We cannot quantify questioned costs because no testing could be performed, and the scope limitation affects all reported federal expenditures. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement procedures to ensure grant expenditures are properly accounted for and supported by sufficient documentation. The School District should develop internal controls to ensure accurate and complete reporting on the SEFA. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-014 Inability to Test Compliance and Adequacy of Federal Grant Expenditures (Material Weakness) Federal Agency: All Compliance Requirement: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Uniform Guidance (2 CFR 200.302(b)(3)) requires recipients of federal funds to maintain records that adequately identify the source and application of funds and ensure compliance with program requirements. Condition: We are unable to test compliance with federal program requirements due to pervasive discrepancies in the School District’s accounting for federal grants. Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be supported or reconciled to the School District’s financial records. Cause: Inadequate grant accounting procedures and internal controls over federal program expenditures. Effect: We are unable to determine compliance with federal program requirements or assess the allowability of expenditures. A disclaimer of opinion was issued for compliance with major program requirements. Questioned Costs: Unable to determine. We cannot quantify questioned costs because no testing could be performed, and the scope limitation affects all reported federal expenditures. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement procedures to ensure grant expenditures are properly accounted for and supported by sufficient documentation. The School District should develop internal controls to ensure accurate and complete reporting on the SEFA. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2023-014 Inability to Test Compliance and Adequacy of Federal Grant Expenditures (Material Weakness) Federal Agency: All Compliance Requirement: All Type of Finding: Internal Control over Compliance – Material Weakness Material Noncompliance Criteria or Specific Requirement: Uniform Guidance (2 CFR 200.302(b)(3)) requires recipients of federal funds to maintain records that adequately identify the source and application of funds and ensure compliance with program requirements. Condition: We are unable to test compliance with federal program requirements due to pervasive discrepancies in the School District’s accounting for federal grants. Expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) could not be supported or reconciled to the School District’s financial records. Cause: Inadequate grant accounting procedures and internal controls over federal program expenditures. Effect: We are unable to determine compliance with federal program requirements or assess the allowability of expenditures. A disclaimer of opinion was issued for compliance with major program requirements. Questioned Costs: Unable to determine. We cannot quantify questioned costs because no testing could be performed, and the scope limitation affects all reported federal expenditures. Identification as Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the School District implement procedures to ensure grant expenditures are properly accounted for and supported by sufficient documentation. The School District should develop internal controls to ensure accurate and complete reporting on the SEFA. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
FA 2023-001 Improve Controls over Financial Reporting Compliance Requirement: Reporting Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Award Number: S010A210010-21A (Year: 2022), S010A220010 (Year: 2023) Questioned Costs: None Identified Description: The School District did not file accurate completion reports for Title I Grants to Local Educational Agencies program. Background Information: The Georgia Department of Education (GaDOE) requires the School District to submit a completion report by October 30 after the 15-month period of performance associated with the Title I Grants to Local Educational Agencies (Title I) program ends. These completion reports are filed through the Grants Application section of the MyGaDOE webportal and reflect budgeted and actual expenditure information for the Title I program for the reporting period. If the total expenditures reflected on the completion report are more than the Title I program funds received by the School District for the grant period, a DE-0147 – Request for Reimbursement of Monthly Cash Disbursements will be automatically generated and the additional funds due to the School District will be disbursed appropriately. Conversely, if the total funds received for the grant period exceed the total expenditures reflected on the completion report, the Grants Application will prompt the School District to enter a check number for the required refund of excess funds drawn down. Therefore, it is imperative that completion reports are filed by the School District in an accurate and timely manner. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.302(a) state in part that “the non-Federal entity’s financial management systems must… be sufficient to permit the preparation of reports required by general and program-specific terms and conditions.” In addition, provisions included in the Uniform Guidance, Section 200.302(b)(2) state in part that the non-federal entity’s financial management system must provide for “accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements.” Condition: A review of the School District’s accounting records and the completion reports related to the Title I program revealed the following deficiencies: 1. The Title I-A, Improving the Academic Achievement of the Disadvantaged completion report for the period July 1, 2022 through June 30, 2023 was under reported by $79,636. 2. The Title I-A, Improving the Academic Achievement of the Disadvantaged completion report for the period July 1, 2023 through September 30, 2023 was over reported by $390. 3. The Title I-A, School Improvement completion report for the period July 1, 2022 through June 30, 2023 was under reported by $4,571. 4. The Title I-A, School Improvement completion report for the period July 1, 2023 through September 30, 2023 was under reported by $32. Cause: Due to high turnover within the School District finance department and lack of strong procedures and controls, the School District had a deficiency in oversight of federal programs and reviews. Effect: The School District was not in compliance with the Uniform Guidance and GaDOE guidance. Failure to accurately report federal award expenditures through the completion report process could lead to the filing of DE-0147 reimbursement requests with GaDOE that do not support actual expenditures. Therefore, the School District may obtain more or less federal funding than they were eligible to receive. Recommendation: The School District should establish procedures to ensure that completion reports submitted to GaDOE are supported by the accounting records and reimbursement requests are prepared based upon actual expenditures incurred. In addition, management should develop and implement a monitoring process to ensure that control procedures are being followed. Views of Responsible Officials: We concur with this finding.
FA 2023-001 Improve Controls over Financial Reporting Compliance Requirement: Reporting Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Award Number: S010A210010-21A (Year: 2022), S010A220010 (Year: 2023) Questioned Costs: None Identified Description: The School District did not file accurate completion reports for Title I Grants to Local Educational Agencies program. Background Information: The Georgia Department of Education (GaDOE) requires the School District to submit a completion report by October 30 after the 15-month period of performance associated with the Title I Grants to Local Educational Agencies (Title I) program ends. These completion reports are filed through the Grants Application section of the MyGaDOE webportal and reflect budgeted and actual expenditure information for the Title I program for the reporting period. If the total expenditures reflected on the completion report are more than the Title I program funds received by the School District for the grant period, a DE-0147 – Request for Reimbursement of Monthly Cash Disbursements will be automatically generated and the additional funds due to the School District will be disbursed appropriately. Conversely, if the total funds received for the grant period exceed the total expenditures reflected on the completion report, the Grants Application will prompt the School District to enter a check number for the required refund of excess funds drawn down. Therefore, it is imperative that completion reports are filed by the School District in an accurate and timely manner. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.302(a) state in part that “the non-Federal entity’s financial management systems must… be sufficient to permit the preparation of reports required by general and program-specific terms and conditions.” In addition, provisions included in the Uniform Guidance, Section 200.302(b)(2) state in part that the non-federal entity’s financial management system must provide for “accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements.” Condition: A review of the School District’s accounting records and the completion reports related to the Title I program revealed the following deficiencies: 1. The Title I-A, Improving the Academic Achievement of the Disadvantaged completion report for the period July 1, 2022 through June 30, 2023 was under reported by $79,636. 2. The Title I-A, Improving the Academic Achievement of the Disadvantaged completion report for the period July 1, 2023 through September 30, 2023 was over reported by $390. 3. The Title I-A, School Improvement completion report for the period July 1, 2022 through June 30, 2023 was under reported by $4,571. 4. The Title I-A, School Improvement completion report for the period July 1, 2023 through September 30, 2023 was under reported by $32. Cause: Due to high turnover within the School District finance department and lack of strong procedures and controls, the School District had a deficiency in oversight of federal programs and reviews. Effect: The School District was not in compliance with the Uniform Guidance and GaDOE guidance. Failure to accurately report federal award expenditures through the completion report process could lead to the filing of DE-0147 reimbursement requests with GaDOE that do not support actual expenditures. Therefore, the School District may obtain more or less federal funding than they were eligible to receive. Recommendation: The School District should establish procedures to ensure that completion reports submitted to GaDOE are supported by the accounting records and reimbursement requests are prepared based upon actual expenditures incurred. In addition, management should develop and implement a monitoring process to ensure that control procedures are being followed. Views of Responsible Officials: We concur with this finding.
FA 2023-003 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: COVID-19 – 84.425U – American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425U210012 (Year: 2021) Questioned Costs: None Identified Description: The School District made cash drawdowns in excess of immediate cash needs for the Elementary and Secondary School Emergency Relief Fund program. Background Information: The School District may request Elementary and Secondary Emergency Relief (ESSER) Fund program funds from the Georgia Department of Education (GaDOE) once per month. GaDOE requires the School District to submit DE-0147 – Requests for Reimbursement of Monthly Cash Disbursements through the Grants Accounting Online Reporting System to receive program funds. When a DE-0147 request is submitted and approved, the funds are typically disbursed to the School District through an electronic payment process the next week. The School District submitted DE-0147 requests to receive a total of $3,636,320 in ESSER funds from GaDOE during the fiscal year under review. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance Section 200.305(b) state that “For non-Federal entities other than states, payment methods must minimize the time elapsing between the transfer of funds…the pass-through entity and the disbursement by the non-Federal entity.” In addition, the Uniform Guidance Section 200.302(b)(6) requires the entity to develop written cash management procedures. Condition: A review of all cash drawdowns and disbursements related to the ESSER program was performed to determine if any excessive cash balances were maintained during the fiscal year under review. Cash balances in excess of program materiality were maintained for the ESSER program for 37 days. Additionally, it was noted that the School District did not have appropriate internal controls in place over the cash drawdown process. Cause: In discussing this issue with the School District, they indicated that the lack of review of federal grants resulted in excess cash drawdown requests. Effect: The School District was not in compliance with the Uniform Guidance and GaDOE guidance. In addition, the School District could potentially accrue an interest liability that would be owed back to the federal government. Furthermore, when the School District cannot meet the requirement to minimize the time elapsing between the transfer of funds and disbursement of those funds, provisions included in the Uniform Guidance allow GaDOE to change the method by which the School District is transferred funds and delay the School District’s receipt of these funds. This may include a requirement by GaDOE to submit invoices prior to being reimbursed for program expenditures. Recommendation: The School District should establish procedures to accurately forecast the cash needs of the ESSER program and minimize the time elapsing between the transfer of funds from GaDOE and the disbursement of such funds by the School District. In addition, these procedures should be documented in writing in accordance with the Uniform Guidance Section 200.302(b)(6). Furthermore, management should develop and implement a monitoring process to ensure that these procedures are followed. Views of Responsible Officials: We concur with this finding.
Statement of condition: Lack of adequate supporting documentation for expenditures of federal awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.302-303 requires non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, all recipients and subrecipients of federal awards must maintain records which are sufficient to track expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause of condition: Procedures are in place which require every transaction recorded to be supported by the appropriate documentation. However, these procedures were not appropriately followed as managment has not kept or maintained records of transactions for expenditures of federal awards. Supporting documentation has either been lost or disposed. Effect of condition: Management did not maintain adequate supporting documentation for certain expenditures of federal awards, thus making it impossible to determine if funds were spent in accordance with regulations. Context: Management was unable to provide supporting documentation for 3 of the 10 non-payroll expenditures selected for testing. These expenditures totaled $15,468. Recommendation: To ensure proper records are maintained, after recording all transactions, supporting documentation for which the transaction was derived should be maintained in an organized fashion so that the records and be accessed in a timely manner. This process should be done to ensure accounting records are accurate and to provide support if questions arise from the public or any government agencies. Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to maintain adequate supporting documentation for all transactions. Action Plan: Establish clear guidelines and training on allowable costs for federally funded programs. Implement a compliance checklist for all federally funded expenditures to ensure alignment with Education Stabilization Fund requirements. Conduct internal audits every quarter to monitor compliance and document findings. Timeline: Immediate implementation; quarterly compliance reviews. Responsible Parties: Finance Director, APSRC, and Directors.
Statement of condition: Lack of adequate supporting documentation for expenditures of federal awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.302-303 requires non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, all recipients and subrecipients of federal awards must maintain records which are sufficient to track expenditures to establish that funds have been used in accordance with Federal statutes, regulations, and the terms and conditions of the Federal award. Cause of condition: Procedures are in place which require every transaction recorded to be supported by the appropriate documentation. However, these procedures were not appropriately followed as managment has not kept or maintained records of transactions for expenditures of federal awards. Supporting documentation has either been lost or disposed. Effect of condition: Management did not maintain adequate supporting documentation for certain expenditures of federal awards, thus making it impossible to determine if funds were spent in accordance with regulations. Context: Management was unable to provide supporting documentation for 3 of the 10 non-payroll expenditures selected for testing. These expenditures totaled $15,468. Recommendation: To ensure proper records are maintained, after recording all transactions, supporting documentation for which the transaction was derived should be maintained in an organized fashion so that the records and be accessed in a timely manner. This process should be done to ensure accounting records are accurate and to provide support if questions arise from the public or any government agencies. Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to maintain adequate supporting documentation for all transactions. Action Plan: Establish clear guidelines and training on allowable costs for federally funded programs. Implement a compliance checklist for all federally funded expenditures to ensure alignment with Education Stabilization Fund requirements. Conduct internal audits every quarter to monitor compliance and document findings. Timeline: Immediate implementation; quarterly compliance reviews. Responsible Parties: Finance Director, APSRC, and Directors.