Condition: The Organization’s written policies and procedures related to financial management and procurement do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Organization is required to have a written financial management policy. Additionally, according to 2 CFR Section 200.317 – 200.326, the Organization is required to have a written procurement policy. Cause: The Organization was unaware of requirements regarding policies and procedures outlined in the Uniform Guidance. Effect: Written policies necessary for non-Federal entities receiving federal funds were not in place. Repeat Finding: No Questioned Costs: None reported Recommendation: We recommend that the Organization update their written policies and procedures that meet the requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor’s finding and will update the Organization’s written policies and procedures for the Uniform Guidance requirements.
Condition: The Organization’s written policies and procedures related to financial management and procurement do not meet the requirements of 2 CFR 200, Subpart D and Subpart E. Criteria: According to 2 CFR Section 200.302.b and 2 CFR Section 200.305 of the Uniform Guidance, the Organization is required to have a written financial management policy. Additionally, according to 2 CFR Section 200.317 – 200.326, the Organization is required to have a written procurement policy. Cause: The Organization was unaware of requirements regarding policies and procedures outlined in the Uniform Guidance. Effect: Written policies necessary for non-Federal entities receiving federal funds were not in place. Repeat Finding: No Questioned Costs: None reported Recommendation: We recommend that the Organization update their written policies and procedures that meet the requirements of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Views of Responsible Officials and Planned Corrective Action: We concur with the auditor’s finding and will update the Organization’s written policies and procedures for the Uniform Guidance requirements.
CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. This is a repeat finding from (2022-003) from the previous fiscal year. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 2) accurate, current and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in sections 200.328 and 200.329 of the Uniform Guidance. EFFECT: The District was not in compliance with the financial reporting requirements in the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CAUSE: The District experienced turnover in key business office personnel during the last two fiscal years, which resulted in errors in posting federal expenditures to the appropriate general ledger account codes. This further lead to inaccurate reporting as outlined above. QUESTIONED COST: None RECOMMENDATION: I recommend that the District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance and PDE regulations. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. This is a repeat finding from (2022-003) from the previous fiscal year. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 2) accurate, current and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in sections 200.328 and 200.329 of the Uniform Guidance. EFFECT: The District was not in compliance with the financial reporting requirements in the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CAUSE: The District experienced turnover in key business office personnel during the last two fiscal years, which resulted in errors in posting federal expenditures to the appropriate general ledger account codes. This further lead to inaccurate reporting as outlined above. QUESTIONED COST: None RECOMMENDATION: I recommend that the District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance and PDE regulations. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. This is a repeat finding from (2022-003) from the previous fiscal year. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 2) accurate, current and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in sections 200.328 and 200.329 of the Uniform Guidance. EFFECT: The District was not in compliance with the financial reporting requirements in the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CAUSE: The District experienced turnover in key business office personnel during the last two fiscal years, which resulted in errors in posting federal expenditures to the appropriate general ledger account codes. This further lead to inaccurate reporting as outlined above. QUESTIONED COST: None RECOMMENDATION: I recommend that the District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance and PDE regulations. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. This is a repeat finding from (2022-003) from the previous fiscal year. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 2) accurate, current and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in sections 200.328 and 200.329 of the Uniform Guidance. EFFECT: The District was not in compliance with the financial reporting requirements in the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CAUSE: The District experienced turnover in key business office personnel during the last two fiscal years, which resulted in errors in posting federal expenditures to the appropriate general ledger account codes. This further lead to inaccurate reporting as outlined above. QUESTIONED COST: None RECOMMENDATION: I recommend that the District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance and PDE regulations. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. This is a repeat finding from (2022-003) from the previous fiscal year. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 2) accurate, current and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in sections 200.328 and 200.329 of the Uniform Guidance. EFFECT: The District was not in compliance with the financial reporting requirements in the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CAUSE: The District experienced turnover in key business office personnel during the last two fiscal years, which resulted in errors in posting federal expenditures to the appropriate general ledger account codes. This further lead to inaccurate reporting as outlined above. QUESTIONED COST: None RECOMMENDATION: I recommend that the District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance and PDE regulations. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
Finding 2023-006 Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award 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 award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . . 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the reporting compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Management misinterpreted the instructions for the reporting requirements and believed that they did not need to fill in the expense information as an LEA. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation was required to submit one Annual Data Report for each year in the audit period to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. Amounts reported on each ESSER I Annual Data Report did not agree to underlying detail for the ESSER I grant. ESSER I was overstated on the Year 3 report by $76,231. The finding is isolated to the S425D200013 award (ESSER I). Identification as a repeat finding: No. Recommendation: We recommend someone other than the preparer of the report perform a documented review prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditure adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: • Twelve-line items in the Title I grants, totaling $104,453.87. • Seven-line items in the ARP ESSER grant, totaling $259,335.59. • Two-line items in the Special Education IDEA Part B grant, totaling $6,499.58. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $370,289.04 Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditure adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: • Twelve-line items in the Title I grants, totaling $104,453.87. • Seven-line items in the ARP ESSER grant, totaling $259,335.59. • Two-line items in the Special Education IDEA Part B grant, totaling $6,499.58. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $370,289.04 Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditure adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: • Twelve-line items in the Title I grants, totaling $104,453.87. • Seven-line items in the ARP ESSER grant, totaling $259,335.59. • Two-line items in the Special Education IDEA Part B grant, totaling $6,499.58. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $370,289.04 Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditure adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: • Twelve-line items in the Title I grants, totaling $104,453.87. • Seven-line items in the ARP ESSER grant, totaling $259,335.59. • Two-line items in the Special Education IDEA Part B grant, totaling $6,499.58. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $370,289.04 Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.
2023-003Financial Management System- (Material Weakness) Criteria:According to 2 CFR 200.302, the financial management system of each non-Federal entity must provide records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Condition: Statement of financial position transactions were not allocated properly to programs/properties funded with federal funds. Cause: Due to a human error of individuals who were handling the accounting entries, some of transactions were not accurately allocated to the correct programs/properties. Effect: Improper allocation of transactions among various programs/properties could lead to comingling of funds from different projects. This could result in unallowable cost or in allowable cost charged simultaneously to two different programs/properties. Questioned Cost: Undetermined Recommendation: Establish an internal control procedures in place that provide for separate accountability for projects by allocating transactions properly and producing accurate financial reports for each federally funded programs/properties. Management's Views and Corrective Action Plan Management's response is included in "Management's View and Corrective Action Plan" at the end of this report after the schedule of findings and questioned cost
2023-003Financial Management System- (Material Weakness) Criteria:According to 2 CFR 200.302, the financial management system of each non-Federal entity must provide records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Condition: Statement of financial position transactions were not allocated properly to programs/properties funded with federal funds. Cause: Due to a human error of individuals who were handling the accounting entries, some of transactions were not accurately allocated to the correct programs/properties. Effect: Improper allocation of transactions among various programs/properties could lead to comingling of funds from different projects. This could result in unallowable cost or in allowable cost charged simultaneously to two different programs/properties. Questioned Cost: Undetermined Recommendation: Establish an internal control procedures in place that provide for separate accountability for projects by allocating transactions properly and producing accurate financial reports for each federally funded programs/properties. Management's Views and Corrective Action Plan Management's response is included in "Management's View and Corrective Action Plan" at the end of this report after the schedule of findings and questioned cost
Finding 2023-005 Assistance Listing Number: 93.566 Program Title: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Agency: U.S. Department of Health and Human Services Pass-Through Entity: International Institute of St. Louis Missouri Office of Refugee Administration Federal Award Identification Number: 2203MORCMA, 2202MORSSS, 2302MORSS, and 2022MORSSS Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Reporting Criteria: In accordance with Title 2 CFR Part 200.302, costs must be supported by source documentation. In accordance with Title 2 CFR Part 200.403, costs must be adequately documented to be allowable costs under the federal program. Condition: We tested forty non-payroll expenditures charged to the federal program. Of the forty expenditures, seven expenditures did not have any supporting documentation that could be located. Cause: Catholic Charities was unable to locate supporting documentation for non-payroll expenditures charged to the federal program. Effect: Seven non-payroll expenditures did not have any supporting documentation as required by Title 2 CFR Part 200.302 and Title 2 CFR Part 200.403. Questioned Costs: $9,181 Context: Total non-payroll expenditures charged to the federal program was $423,059. Repeat Finding: This is a repeat finding. Recommendation: We recommend Catholic Charities maintain supporting documentation for all expenditures charged to the federal program. Views of the Responsible Officials: Catholic Charities of Central and Northern Missouri agrees with this finding and while some of the problems which arose were related to a burst water pipe over an extended holiday that destroyed many of the records, All invoices and documentation related to expenditure of federal funds are now scanned and attached to the accounting entry recording the payable.
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.
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.
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.
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.
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.