2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
2022-003: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The amount overdrawn for the WIOA Cluster totaled $125,668. It was noted that other programs were also overdrawn as follows: SNAP Cluster (ALN 10.561): $81,751 and Unemployment Insurance (ALN 17.225): $8,143. The total amount of funds overdrawn as of year-end totaled $215,562. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding. Michigan Works! Southeast will continue to ensure it adheres to the policy standards for cash on hand time limits.
Criteria 2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. 2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.Condition During our procedures, we found the following exceptions: a) In a sample of fifteen (15) cash drawdown petitions for Epidemiology and Laboratory Capacity for Infectious Diseases, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request.Cause Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis. Effect Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions. Questioned Costs None Perspective Information Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe. Prior Year Audit Finding None Recommendation The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds. Views of responsible officials For the audited period and until August 2023, the procedure of the program and the Department of Health was "advanced" and was as follows: 1. The Epidemiology program worked with the validation of the voucher and recovered the director's signature for the punch of the "certificate". Once the validation and signature were in place, the cash request was processed. Once the cash request was remitted or the credit notice was registered, the receipt was delivered to the Tax Intervention area. 2. The Fiscal Intervention area works on the approval of the payment on the vouchers. Vouchers were worked on a first-come, first-served basis. This intervention process can take a week or more. The program had no control over the timing of payment approvals. This created a weakness when it came to cash management compliance. The program did confirm that the money was available at the time the payment was approved but had no control over the date the payment was approved. However, due to the nature of our funds and the volume of invoices, the Treasury Department asked us to change the modality for terms of cash requests from "advanced" to reimbursement. This began to be implemented as of September 2023. This method of reimbursement makes it easier for the program to have better control over cash management. With this method, the program requests the funds on the days that the Treasury Department makes the payment rolls. Once the petition is created on the same day of the print run and approved by the Program Director, it is submitted to the Office of Federal Affairs to prepare the request for funds to the federal government. The Office of Federal Affairs has the flexibility and agility to process such a request within two days. This helps us to meet the requirements of cash management. Responsible Officials Mrs. Sylvianette Luna Anavitate Program Director 787-765-2929 ext. 3121 Mr. Bryan Santos Martínez Financial and Accountant Analyst 787-765-2929 ext. 3361 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Criteria 2 CFR 200.302 states that each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. 2 CFR 200.333 states that financial records, supporting documents, statistical records, and all other non-Federal entity records must be retained for a period of three years from the date of submission of the final expenditure report. For Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.Condition During our procedures, we found the following exceptions: a) In a sample of fifteen (15) cash drawdown petitions for Epidemiology and Laboratory Capacity for Infectious Diseases, we observed transactions with the check issued after the required time lapsed in accordance with the program advance type request.Cause Programs have not established written procedures and internal controls to properly follow up the finance division in order to pay to the suppliers and service providers on a timely basis. Effect Failure to minimize the time elapsed between the drawdown from the US Treasury to the actual check issue date may result in the calculation and determination by the Federal grantors of interest costs on the average balance of funds held beyond the reasonable time. This situation may also expose the PRDH to possible sanctions by federal grantors, such as withholding payments, or other special conditions. Questioned Costs None Perspective Information Finding represents a significant and repetitive problem. The Department will reinforce procedures over the disbursement process to ensure that all program payments are made within the 3 days timeframe. Prior Year Audit Finding None Recommendation The PRDH should establish written procedures that payments are issued promptly after the drawdown is made. This will minimize the time elapsed between the drawdown and the payment of funds. The PRDH should also establish a procedure to periodically monitor the cash balances of Federal programs for the possible identification, investigation, and resolution of unused funds. Views of responsible officials For the audited period and until August 2023, the procedure of the program and the Department of Health was "advanced" and was as follows: 1. The Epidemiology program worked with the validation of the voucher and recovered the director's signature for the punch of the "certificate". Once the validation and signature were in place, the cash request was processed. Once the cash request was remitted or the credit notice was registered, the receipt was delivered to the Tax Intervention area. 2. The Fiscal Intervention area works on the approval of the payment on the vouchers. Vouchers were worked on a first-come, first-served basis. This intervention process can take a week or more. The program had no control over the timing of payment approvals. This created a weakness when it came to cash management compliance. The program did confirm that the money was available at the time the payment was approved but had no control over the date the payment was approved. However, due to the nature of our funds and the volume of invoices, the Treasury Department asked us to change the modality for terms of cash requests from "advanced" to reimbursement. This began to be implemented as of September 2023. This method of reimbursement makes it easier for the program to have better control over cash management. With this method, the program requests the funds on the days that the Treasury Department makes the payment rolls. Once the petition is created on the same day of the print run and approved by the Program Director, it is submitted to the Office of Federal Affairs to prepare the request for funds to the federal government. The Office of Federal Affairs has the flexibility and agility to process such a request within two days. This helps us to meet the requirements of cash management. Responsible Officials Mrs. Sylvianette Luna Anavitate Program Director 787-765-2929 ext. 3121 Mr. Bryan Santos Martínez Financial and Accountant Analyst 787-765-2929 ext. 3361 Estimated Completion Date Implementation is expected to be completed on or before the end of the fiscal year June 30, 2024.
Unidentifiable Federal Funds Information on the Federal Program: Coronavirus State and Local Fiscal Recovery Funds (AL Number 21.027) – U.S. Department of the Treasury Criteria: 2 CFR 200.302 (b) (1) -The financial management system of each non-federal entity must provide for the identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. federal program and federal award identification must include, as applicable, the Assistance Listings title and number, federal award identification number and year, name of the federal agency, and name of the pass-through entity, if any. Condition: Federal funds totaling $138,700 were not identified within the accounts of the University’s financial management system. These funds were posted in a payment holding account and were not identifiable as federal funds. Questioned Cost: $-0- Cause: The internal controls in place to ensure the identification of all federal payments received and expended failed to identify the above funds as federal funds. Effect: Without further investigation into the holding account, these funds would not have been identifiable within the University’s financial management system and would have been excluded from the Schedule of Expenditures of federal Awards. Recommendation: We recommend the University review the controls in place to identify federal funds and enhance if warranted.
Finding 2022-004: Allocation of Employee Benefit Expenses. Information on the federal program: Assistance Listing Number 17.268 - H1-B Job Training Grant, U.S. Department of Labor, Employment Training Administration. Award number: HG-34352-20-60-A-53. Compliance requirements: Allowable Costs/Cost Principles, Reporting. Type of finding: Material Noncompliance, Material Weakness. Condition: Employee benefit costs were charged to the grant using a fixed percentage rate that did not accurately reflect the actual cost of the employee benefits. Effect or potential effect: The fixed percentage rate used to charge employee benefits did not accurately reflect the actual cost incurred and resulted in incorrect reporting of expense to the federal agency. Cause: Lack of appropriate policies and reconciliation procedures. Criteria: Uniform Guidance 2 CFR 200.302 (b)(3) requires records to identify adequately the source and application of funds for federally funded activities. These records must be supported by source documentation. Context: We tested 100% of the employee benefits charged to the grant totaling $135,884 and noted that the source documentation did not support the total amount billed, the procedures identified overbilling of benefits in the amount of $7,356. Management was able to provide additional allowable costs to replace the overbilling. Questioned costs: None. Recommendations: We recommend management charge actual employee benefits incurred to the grant. We recommend management implement policies and procedures related to reconciliation processes each payroll to ensure that only supportable charges are billed to the grant. Views of the responsible officials and planned corrective actions: AJAC Directors have developed and implemented policies and procedures to appropriately allocate employee benefits. The new policies and procedures align the employee benefit expense with the wage allocations at the employee level.
Finding 2022-005: Coding of Indirect Expenses. Information on the federal program: Assistance Listing Number 17.268 - H1-B Job Training Grant, U.S. Department of Labor, Employment Training Administration. Award number: HG-34352-20-60-A-53. Compliance requirements: Allowable Costs/Costs Principals. Type of finding: Material Noncompliance, Material Weakness. Condition: Indirect costs were not coded in the accounting system to the individual grant. Effect or potential effect: Improper coding of indirect costs in the accounting system to individual grants may result in improper reporting and potential questioned costs. Cause: Lack of appropriate cost allocation policies and reconciliation procedures. Criteria: Uniform Guidance 2 CFR 200.302 (b)(3) requires records to identify adequately the source and application of funds for federally funded activities. Context: Indirect costs in the amount of $46,577 charged to the grant as indirect costs were not coded to the H1-B Job Training Grant class code in the accounting system. Questioned costs: None. Recommendations: We recommend management code indirect costs to individual grants. We recommend management implement a reconciliation process monthly to ensure that indirect costs charged to the grant are properly coded. Views of the responsible officials and planned corrective actions: AJAC has implemented monthly reconciliations to identify all appropriate indirect expenses specific to each grant or contract agreement. All indirect expenses identified as being reimbursable to a specific grant or contract will be reclassified in the accounting software to match the reimbursement request.
Finding 2022-006: Coding of Direct Expenses. Information on the federal program: Assistance Listing Number 17.268 - H1-B Job Training Grant, U.S. Department of Labor, Employment Training Administration. Award number: HG-34352-20-60-A-53. Compliance requirements: Allowable Costs/ Cost Principles. Type of finding: Material Noncompliance, Material Weakness. Condition: Direct costs were not coded in the accounting system to the individual grant. Effect or potential effect: Improper coding of direct costs in the accounting system to individual grants may result in improper reporting and potential questioned costs. Cause: Lack of appropriate cost allocation policies and reconciliation procedures. Criteria: Uniform Guidance 2 CFR 200.302 (b)(3) requires records to identify adequately the source and application of funds for federally funded activities. Context: Unable to reconcile the direct costs reported in the books and records to the costs reported on the quarterly ETA – 9130 forms. Costs not specifically identified in the accounting records as H1- B Job Training Grant costs totaled $34,426. Questioned costs: None. Recommendations: We recommend management code direct costs to the individual grant. We recommend management implement a reconciliation process monthly to ensure that direct costs charged to the grant are properly coded. Views of the responsible officials and planned corrective actions: AJAC Directors will review all direct expenses related to each grant or contract agreement monthly and verify that they are appropriately recorded in the accounting software and tie to the reimbursement request.
Finding 2022-007: Financial Reporting Information on the federal program: Assistance Listing Number 17.268 - H1-B Job Training Grant, U.S. Department of Labor, Employment Training Administration. Award number: HG-34352-20-60-A-53. Compliance requirements: Allowable Costs/ Costs Principles, Period of Performance, Reporting. Type of finding: Material Noncompliance, Material Weakness. Condition: Subrecipient costs were not reported on the accrual basis on the quarterly ETA – 9130 forms. Effect or potential effect: Improper reporting results in inaccurate incomplete financial results. Cause: Management did not request and obtain subrecipient reports timely. Criteria: Uniform Guidance 2 CFR 200.302(b)(2) requires accurate, current, and complete disclosure of financial results. Context: Management did not request and receive quarterly financial reports from their subrecipient timely, which resulted in subrecipient expenditures of $4,002 being reported in the wrong quarter. Questioned costs: None. Recommendations: We recommend management report subrecipient expenses on the accrual basis. We recommend management implement policies and procedures to request and obtain subrecipient reports timely. Views of the responsible officials and planned corrective actions: Monthly financial statements will be delivered to AJAC Directors. AJAC Accounting Department will hold monthly close calls to collaborate with AJAC Directors to ensure accuracy of the financial records.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-001Prior Year Finding: 2021-005Federal Agency: U.S. Department of the TreasuryU.S. Department of EducationFederal Program: COVID-19 -Coronavirus State and Local Fiscal Recovery FundsCOVID-19 - Education Stabilization FundSupporting Effective Instruction State Grants (formerlyImproving Teacher Quality State Grants)Assistance Listing: 21.027, 84.425C,D,U,W, 84.367Pass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:211838-01 (3/3/21 ? 12/31/24) 211815-01 (3/3/21 ? 12/31/24)211875-01 (3/3/21 ? 12/31/24) 201873-01 (3/13/20 ? 9/30/22)201787-01 (3/13/20 ? 9/30/22) 202233-01 (3/13/20 ? 9/30/22)191360-01 (7/1/18 ? 9/30/21) 201067-01 (7/1/19 ? 9/30/21)210781-01 (7/1/20 ? 6/30/22) 221052-01 (7/1/21 ? 6/30/23)Compliance Requirement: ReportingType of Finding Significant Deficiency in Internal Control over Compliance, OtherMattersCriteria or Specific Requirement:Compliance: Per 2 CFR section 200.302(b), financial management systems of non-Federal entitiesmust provide for accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with program reporting requirements and provide records that identifyadequately the source and application of funds for federally funded activities. Per Part L of the OMBCompliance Supplement, financial reports must include all activity of the reporting period, be supportedby applicable accounting or performance records, and be fairly presented in accordance with governingrequirements.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effectiveinternal control over the Federal award that provides reasonable assurance that the non-federal entityis managing the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO). Condition/Context:The Board is required to submit monthly Financial Status Reports (FSR) to the Maryland StateDepartment of Education (MSDE). MSDE utilizes these reports as reimbursement requests andsubsequently submits payment to the board based on reported expenditures. The Final September2021 FSR and its related supporting documentation/reconciliations were not retained. Specifically, wenoted the following:? Education Stabilization Fund: 3 out of 23 grants; 1 out of 5 months? Coronavirus State and Local Fiscal Recovery Fund: 3 out of 16 grants; 1 out of 5 months? Supporting Effective Instruction State Grants: 4 out of 11 grants; 1 out of 3 monthsQuestioned Costs:Undetermined, due to lack of documentation.Cause:The Final September 2021 FSR Reimbursement Request and supporting documentation used toprepare it was not retained.Effect:The lack of reconciliations performed on the differences between the monthly FSR & GL Detail couldresult in inaccurate amounts reported and received for the Federal programs. In addition, the Board didnot have supporting documentation to show controls were in place over expenditure reporting andreimbursement requests.Recommendation:We recommend that the Board review its policies and procedures to ensure that ReimbursementRequests and the detail & accompanying reconciliations used to prepare it are retained for auditpurposes.Views of responsible officials:Management agrees with the finding.