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.
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 2022-002Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS17SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)One of five annual reports required to be completed during the audit period contained materialerrors. The Elementary and Secondary School Emergency Relief (ESSER I), Year 1 annual data reportoverstated total expenditures made between March 13, 2020, and September, 30, 2020, by $130,918. Inaddition, documentation provided for the number of full-time employee positions did not support theamounts reported.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS18SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS17SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)One of five annual reports required to be completed during the audit period contained materialerrors. The Elementary and Secondary School Emergency Relief (ESSER I), Year 1 annual data reportoverstated total expenditures made between March 13, 2020, and September, 30, 2020, by $130,918. Inaddition, documentation provided for the number of full-time employee positions did not support theamounts reported.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS18SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersINDIANA STATE BOARD OF ACCOUNTS22MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with the requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation filed the four required Elementary and Secondary School EmergencyRelief (ESSER) annual data reports. However, the ESSER I, Year 1 and ESSER I, Year 2 reports werenot supported by the School Corporation's records. For each of the reports, two key line items wereselected for verification, none of the line items tested were supported by the School Corporation's records.For the ESSER I, Year 2 report the data included expenditures for two months beyond the reporting period.The lack of internal controls and noncompliance were applicable to the ESSER I grant during theaudit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."INDIANA STATE BOARD OF ACCOUNTS23MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not designed, nor implemented a system of internal controls that would haveensured compliance or that supporting documentation would have been maintained and available for auditrelated to the Reporting compliance requirement.EffectThe failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Noncompliancewith the grant agreement and the Reporting compliance requirement could result in the loss of future federalfunds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grantagreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersINDIANA STATE BOARD OF ACCOUNTS22MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with the requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation filed the four required Elementary and Secondary School EmergencyRelief (ESSER) annual data reports. However, the ESSER I, Year 1 and ESSER I, Year 2 reports werenot supported by the School Corporation's records. For each of the reports, two key line items wereselected for verification, none of the line items tested were supported by the School Corporation's records.For the ESSER I, Year 2 report the data included expenditures for two months beyond the reporting period.The lack of internal controls and noncompliance were applicable to the ESSER I grant during theaudit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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 ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."INDIANA STATE BOARD OF ACCOUNTS23MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not designed, nor implemented a system of internal controls that would haveensured compliance or that supporting documentation would have been maintained and available for auditrelated to the Reporting compliance requirement.EffectThe failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Noncompliancewith the grant agreement and the Reporting compliance requirement could result in the loss of future federalfunds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grantagreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2022-002 Significant DeficiencyAssistance Listing: 84.351 C.A.R.E.Condition:Cleveland Play House does not have adequate documentation to support all charges to the federalprogram.Of the 40 payroll charges tested, 26 did not have adequate documentation. In addition, it was notedthat for 2 of the 37 non-payroll charges tested supporting documentation was unable to be located.In addition, management provided an Excel spreadsheet to support the charges that were made to theprogram rather than reporting from their financial management system that is compliant with Section200.302.Criteria:2 CFR 200.403(g) states that for costs to be allowed under Federal awards, they must be adequatelydocumented.In addition, Section 200.302 requires that the financial management system must provide for anidentification, in its accounts, of all federal awards received and expended and the federal programsunder which they were received; an accurate, current, and complete disclosure of the financial resultsof each federal award or program; and a comparison of expenditures with budget amounts for eachfederal award.Cause:Due to significant organizational turnover, individuals were not completing timesheets to documentlevel of effort for federal programs. Although management was verbally communicating with theseindividuals during the year and tracking the time they spent on the program within a spreadsheet, thisis not considered adequate documentation. In addition, and also a result of the turnover, certaindocumentation to support non-payroll expenditures was unable to be located.Effect:Cleveland Play House did not have adequate documentation to support all costs charged to the federalprogram. In addition, an ineffective financial management system could lead to incorrectidentification of costs charged to a federal program and an inability to substantiate that double-chargingdid not occur.Repeat finding:This is not a repeat finding.Questioned costs:Non-payroll: $974Payroll: $20,720Recommendation:We recommend that Cleveland Play House develop a policy and procedure to ensure that all hourssubmitted for federal reimbursement are supported with timesheets that are approved by a supervisor.In addition, staff should be made aware of the policy and procedures to ensure retention ofdocumentation for non-payroll expenditures.Views of responsible officials:Management concurs with this recommendation. See also corrective action plan.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor 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.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2022-002 Preparation of Schedule of Expenditures and Federal Awards (?SEFA?) and timelysubmission to Federal Clearing HouseSignificant deficiency in internal control over complianceFederal Program(s) ? All programsFederal Award Year ? June 30, 2022Criteria:2 CFR 200.302(b)(1) states that the nonfederal entity must identify in its accounts all federal awardsreceived and expended, as well as the federal programs under which they were received. Federalprogram and award identification must include, as applicable, the assistance listing title and number,the federal award identification number and year, the name of the federal agency, and the name of thepass-through entity, if any. This information enables the auditee to reconcile amounts presented in thefinancial statements to related amounts in the schedule of expenditures of federal awards. Managementis responsible for the preparation of the SEFA and timely submission of the audited package to theFederal Clearing House.Condition/context:GRYC maintains grant agreements with various government funding pass-through entities. WhileGRYC may not always be subject to the Uniform Guidance report due to not meeting the fundingthreshold, in fiscal year 2022, GRYC exceeded the annual minimal reporting requirement of $750,000.GRYC?s Uniform Guidance audit package was due for submission to the Federal Clearing House byMarch 31, 2023. However, GRYC was unable to effectively determine funding from federal programsthat were subject to Uniform Guidance and as a result, it did not submit the audited package to theFederal Clearing House on time.Cause:Prior to fiscal 2022, GRYC was not subject to the Uniform Guidance audit. In addition, all GRYC?sfederal funding is considered pass-through. As a result, GRYC was under the impression that none oftheir funding was considered federal funding subject to Uniform Guidance. Consequently, GRYC wasunable to sufficiently generate information on all federal funding received during fiscal year 2022 andas a result there was insufficient information available, which led to a delay in the audit process andfiling with the Federal Clearing House.Effect:GRYC maintains its grant documentation internally, however, GRYC did not consider several grantsas being subject to Uniform Guidance in preparation of their SEFA. GRYC did not meet the March31st, 2023, deadline for Federal Clearing House filing.Auditors? Recommendation:We recommend that GRYC develop policies and procedures to ensure compliance with the UniformGuidance reporting requirements that includes proper and timely preparation of SEFA and the timelyfiling of the audit package to the Federal Clearing House. We recommend frequent communicationbetween GRYC and pass-through agencies (funding sources) to help identify federal programs. Inaddition, we recommend GRYC provides more training to grant management staff to both enhancethe skill in identifying pass through programs and ensure the accuracy and completeness of the SEFA.The above recommendation can also be achieved by reviewing all contracts thoroughly and lookingfor provisions that state whether the contracts are federal or state funded. Similarly, if a contract hasan Assistance Listing Number (?ALN?), this could potentially indicate that such grant is federallyfunded. GRYC should also develop better procedures to track all revenues and expenditures over thenext fiscal year to determine whether it exceeded the $750,000 threshold and will be subject to anUniform Guidance audit.Managements Response:GRYC acknowledges and agrees with the finding and is in process of reviewing and analyzing allcontracts and amendments to ensure that the SEFA includes all federally awarded programs. GRYCwill start implementing this recommendation during the year ended June 30, 2023, and plans to filethe 2023 Uniform Guidance report timely.
Reference Number:2022-018Prior Year Finding:NoFederal Agency:U.S. Department of Health and Human ServicesState Agency:Department of Community AffairsFederal Program:Low-Income Home Energy Assistance, COVID-19 - Low-Income Home Energy AssistanceAssistance Listing Number:93.568Award Number and Year:2102NJE5C6 (3/11/21 ? 9/30/22), 2001NJE5C3 (3/27/20 ? 9/30/21), G-1701NJLIEA (10/1/16 ? 9/30/18), G-1801NJLIEA (10/1/17 ? 9/30/19), 2202NJLIEA (10/1/21 ? 9/30/22), 2001NJLIEA (10/1/19 ? 9/30/22), 2102NJLIEA (10/1/20 ? 9/30/21)Compliance Requirement:Cash ManagementType of Finding:Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance: Per 2 CFR 200.302, 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. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Community Affairs (Department) was not able to provide documentation that drawdown requests had been properly approved.Context:Two of eight drawdown requests selected did not have evidence of supervisory approval prior to submission of the requests to the federal agency. The amounts drawn down for the two samples were $282,956 and $74,916 respectively.Questioned costs:None noted.Cause:The Department?s procedures were not sufficient to ensure that drawdown requests were reviewed and approved prior to submission. Internal controls did not prevent or detect the errors.Effect:Without proper review and approval of drawdown requests, the amounts requested could be inaccurate which could result in the Department receiving program funds to which it is not entitled.Recommendation:We recommend that the Department review and enhance its procedures and controls to ensure that cash drawdowns are reviewed and approved prior to submission to the federal agency.Views of responsible officials:The Department of Community Affairs (DCA) staff responsible for the LIHEAP cash management function retired prior to this audit period without a proper transition of these tasks and there was also a delay in refilling the position. As recommended, the DCA has reviewed current procedures and controls regarding cash drawdown approvals and has developed a Policy Memo that details the Payment Management System (PMS) drawdown procedures going forward. For each request made, a Contract Administrator will produce a Business Object report for all transactions to be included in the drawdown and will send the report to the Program staff for review and approval that the amounts contained in the report are correct. Once the Program staff review is complete, the approved Business Object report will be forwarded with a cover email to the Division Fiscal Unit staff responsible for drawing down the funds in PMS for final processing.Views of responsible officials:
Reference Number:2022-018Prior Year Finding:NoFederal Agency:U.S. Department of Health and Human ServicesState Agency:Department of Community AffairsFederal Program:Low-Income Home Energy Assistance, COVID-19 - Low-Income Home Energy AssistanceAssistance Listing Number:93.568Award Number and Year:2102NJE5C6 (3/11/21 ? 9/30/22), 2001NJE5C3 (3/27/20 ? 9/30/21), G-1701NJLIEA (10/1/16 ? 9/30/18), G-1801NJLIEA (10/1/17 ? 9/30/19), 2202NJLIEA (10/1/21 ? 9/30/22), 2001NJLIEA (10/1/19 ? 9/30/22), 2102NJLIEA (10/1/20 ? 9/30/21)Compliance Requirement:Cash ManagementType of Finding:Significant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance: Per 2 CFR 200.302, 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. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award.Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Community Affairs (Department) was not able to provide documentation that drawdown requests had been properly approved.Context:Two of eight drawdown requests selected did not have evidence of supervisory approval prior to submission of the requests to the federal agency. The amounts drawn down for the two samples were $282,956 and $74,916 respectively.Questioned costs:None noted.Cause:The Department?s procedures were not sufficient to ensure that drawdown requests were reviewed and approved prior to submission. Internal controls did not prevent or detect the errors.Effect:Without proper review and approval of drawdown requests, the amounts requested could be inaccurate which could result in the Department receiving program funds to which it is not entitled.Recommendation:We recommend that the Department review and enhance its procedures and controls to ensure that cash drawdowns are reviewed and approved prior to submission to the federal agency.Views of responsible officials:The Department of Community Affairs (DCA) staff responsible for the LIHEAP cash management function retired prior to this audit period without a proper transition of these tasks and there was also a delay in refilling the position. As recommended, the DCA has reviewed current procedures and controls regarding cash drawdown approvals and has developed a Policy Memo that details the Payment Management System (PMS) drawdown procedures going forward. For each request made, a Contract Administrator will produce a Business Object report for all transactions to be included in the drawdown and will send the report to the Program staff for review and approval that the amounts contained in the report are correct. Once the Program staff review is complete, the approved Business Object report will be forwarded with a cover email to the Division Fiscal Unit staff responsible for drawing down the funds in PMS for final processing.Views of responsible officials:
CONDITION: The District did not properly record its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. This is a repeat finding (2021-005) from the previous fiscal year. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: By not using federal source codes to properly track its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs, the School District did not comply with the financial reporting standards for federal program expenditures as prescribed by the Pennsylvania Department of Education, through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts and Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance. This situation significantly reduced the District’s internal controls over the ability to properly manage and account for these federal program expenditures in accordance with the compliance requirements of PDE and the Uniform Guidance. CAUSE: Management used proper funding source codes for the revenues received under the GEER, ESSER, and ARP ESSER federal grant programs, but erroneously did not realize the federal funding source coding applied to expenditures as well. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: The District did not properly record its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. This is a repeat finding (2021-005) from the previous fiscal year. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: By not using federal source codes to properly track its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs, the School District did not comply with the financial reporting standards for federal program expenditures as prescribed by the Pennsylvania Department of Education, through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts and Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance. This situation significantly reduced the District’s internal controls over the ability to properly manage and account for these federal program expenditures in accordance with the compliance requirements of PDE and the Uniform Guidance. CAUSE: Management used proper funding source codes for the revenues received under the GEER, ESSER, and ARP ESSER federal grant programs, but erroneously did not realize the federal funding source coding applied to expenditures as well. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my sample review of the District’s completion of its federal grant program ‘Quarterly Cash On Hand Reconciliations’ for the 2021-2022 4th fiscal quarter for the ESSER II and ARP ESSER grants, I noted that the amounts reported to date for ‘total disbursements’ could not be ascertained from the coding of these expenditures in the District’s general ledger (See Finding 2022-005) and did not reconcile to the separate spreadsheets maintained by the School District. This is a repeat finding (2021-006) from the previous fiscal year. CRITERIA: Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: The School District did not comply with Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance which prescribes the proper financial management system for the tracking of federal program expenditures. CAUSE: The School District did not utilize the federal source code tracking system as prescribed by the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts, which would have enabled the District to print reports from the accounting software system, by federal source program, to properly prepare the quarterly reconciliations. It was not readily determinable as to why the ‘total disbursements’ line on the quarterly cash on hand reconciliations did not match the separate spreadsheets the School District utilized for tracking federal program expenditures. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance, to allow for the proper completion of the ‘quarterly cash on hand reconciliations’. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: The District did not properly record its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. This is a repeat finding (2021-005) from the previous fiscal year. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: By not using federal source codes to properly track its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs, the School District did not comply with the financial reporting standards for federal program expenditures as prescribed by the Pennsylvania Department of Education, through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts and Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance. This situation significantly reduced the District’s internal controls over the ability to properly manage and account for these federal program expenditures in accordance with the compliance requirements of PDE and the Uniform Guidance. CAUSE: Management used proper funding source codes for the revenues received under the GEER, ESSER, and ARP ESSER federal grant programs, but erroneously did not realize the federal funding source coding applied to expenditures as well. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my sample review of the District’s completion of its federal grant program ‘Quarterly Cash On Hand Reconciliations’ for the 2021-2022 4th fiscal quarter for the ESSER II and ARP ESSER grants, I noted that the amounts reported to date for ‘total disbursements’ could not be ascertained from the coding of these expenditures in the District’s general ledger (See Finding 2022-005) and did not reconcile to the separate spreadsheets maintained by the School District. This is a repeat finding (2021-006) from the previous fiscal year. CRITERIA: Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: The School District did not comply with Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance which prescribes the proper financial management system for the tracking of federal program expenditures. CAUSE: The School District did not utilize the federal source code tracking system as prescribed by the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts, which would have enabled the District to print reports from the accounting software system, by federal source program, to properly prepare the quarterly reconciliations. It was not readily determinable as to why the ‘total disbursements’ line on the quarterly cash on hand reconciliations did not match the separate spreadsheets the School District utilized for tracking federal program expenditures. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance, to allow for the proper completion of the ‘quarterly cash on hand reconciliations’. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: The District did not properly record its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. This is a repeat finding (2021-005) from the previous fiscal year. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: By not using federal source codes to properly track its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs, the School District did not comply with the financial reporting standards for federal program expenditures as prescribed by the Pennsylvania Department of Education, through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts and Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance. This situation significantly reduced the District’s internal controls over the ability to properly manage and account for these federal program expenditures in accordance with the compliance requirements of PDE and the Uniform Guidance. CAUSE: Management used proper funding source codes for the revenues received under the GEER, ESSER, and ARP ESSER federal grant programs, but erroneously did not realize the federal funding source coding applied to expenditures as well. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my sample review of the District’s completion of its federal grant program ‘Quarterly Cash On Hand Reconciliations’ for the 2021-2022 4th fiscal quarter for the ESSER II and ARP ESSER grants, I noted that the amounts reported to date for ‘total disbursements’ could not be ascertained from the coding of these expenditures in the District’s general ledger (See Finding 2022-005) and did not reconcile to the separate spreadsheets maintained by the School District. This is a repeat finding (2021-006) from the previous fiscal year. CRITERIA: Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: The School District did not comply with Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance which prescribes the proper financial management system for the tracking of federal program expenditures. CAUSE: The School District did not utilize the federal source code tracking system as prescribed by the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts, which would have enabled the District to print reports from the accounting software system, by federal source program, to properly prepare the quarterly reconciliations. It was not readily determinable as to why the ‘total disbursements’ line on the quarterly cash on hand reconciliations did not match the separate spreadsheets the School District utilized for tracking federal program expenditures. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance, to allow for the proper completion of the ‘quarterly cash on hand reconciliations’. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: The District did not properly record its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. This is a repeat finding (2021-005) from the previous fiscal year. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: By not using federal source codes to properly track its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs, the School District did not comply with the financial reporting standards for federal program expenditures as prescribed by the Pennsylvania Department of Education, through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts and Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance. This situation significantly reduced the District’s internal controls over the ability to properly manage and account for these federal program expenditures in accordance with the compliance requirements of PDE and the Uniform Guidance. CAUSE: Management used proper funding source codes for the revenues received under the GEER, ESSER, and ARP ESSER federal grant programs, but erroneously did not realize the federal funding source coding applied to expenditures as well. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my sample review of the District’s completion of its federal grant program ‘Quarterly Cash On Hand Reconciliations’ for the 2021-2022 4th fiscal quarter for the ESSER II and ARP ESSER grants, I noted that the amounts reported to date for ‘total disbursements’ could not be ascertained from the coding of these expenditures in the District’s general ledger (See Finding 2022-005) and did not reconcile to the separate spreadsheets maintained by the School District. This is a repeat finding (2021-006) from the previous fiscal year. CRITERIA: Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. EFFECT: The School District did not comply with Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance which prescribes the proper financial management system for the tracking of federal program expenditures. CAUSE: The School District did not utilize the federal source code tracking system as prescribed by the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts, which would have enabled the District to print reports from the accounting software system, by federal source program, to properly prepare the quarterly reconciliations. It was not readily determinable as to why the ‘total disbursements’ line on the quarterly cash on hand reconciliations did not match the separate spreadsheets the School District utilized for tracking federal program expenditures. QUESTIONED COSTS: None RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance, to allow for the proper completion of the ‘quarterly cash on hand reconciliations’. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
2022-002 Financial Management and Internal Controls Compliance Requirement Allowable Costs/Cost Principles Category Significant Deficiency in Internal Control and Noncompliance Federal Agency U.S. Department of the Treasury Pass-Through Entity Puerto Rico Fiscal Agency and Financial Advisory Authority ALN 21.027 Federal Program COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Criteria 2 CFR section 200.302 Financial management. (a) 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. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. (b) ….. (1) ….. (2) ….. (3) ..... (5) ….. (6) ….. (7) Written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the Federal award. 2 CFR section 200.303 Internal controls. The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. Condition Written Policies The Corporation has no written policies for determining the activities allowed or unallowed and the allowability of costs as described in subpart E, Cost Principles of 2 CFR Part 200. Cause It is the first year for the Corporation to be subjected to a single audit compliance requirements. However, since the Commonwealth of Puerto Rico (the Commonwealth) filed for Title III under the PROMESA, all the instrumentalities of the Commonwealth had to reduce their staff as part of the Fiscal Plan to reduce expenditures. This has disrupted the segregation of duties, which is a key control. Effect The Corporation could incurred in unallowable costs failing to comply with 2 CFR sections 200.302 and 202.305, the Corporation could then be subjected to temporarily withholding of cash payments pending correction of the deficiency and/or withholding further federal awards for the program. Questioned Costs None Recommendations We recommend the Corporation obtain a thorough understanding of the provisions of federal statutes, regulations, or the terms and conditions of federal awards to prepare the required written policies under subpart E, Cost Principles of 2 CFR Part 200. Views of responsible officials Refer to Corrective Action Plan section.
Finding 2022-001 – B. Allowable Costs Federal Agency: U.S. Department of Health and Human Services Passthrough Entity: N/A Assistance Listing Number and Federal Program: 93.829 Section 223 Demonstration Programs to Improve Community Mental Health Services Criteria: In accordance with 2 CFR part 200.302, the Association is required to maintain financial management systems to trace funds to expenditures to establish that funds have been used according to Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system must provide for records that identify adequately the source and application of funds for federally funded activities, among other conditions. The reporting of the federal expenditures should be supported by these records. Amounts may not be expended from project funds on an arbitrary basis. Additionally, in accordance with 2 CFR 200.430, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records, among other things, should support the distribution of the employee’s salary or wages among specific activities if the employee works on a Federal award and non-Federal award. Budget estimates do not qualify as support for charges to Federal awards. Statement of Condition: During the course of our audit, supporting detail for expenses allocated and charged to the grant was not available and could not be determined. Salaries and benefits charged to the grant were based on estimates of employees’ expected workload and client needs, and not supported by records that accurately reflected the work performed on the Federal program. Additionally, the de minimis indirect cost rate was not correctly calculated and applied. The indirect cost charged to the grant was based on the indirect cost obligated by the Notice of Award rather than by calculating the indirect cost from the modified total direct cost base. Statement Cause: This is the first year the Association received this type of grant funding, coupled with significant growth experienced by the Association, the accounting system and staff were not yet prepared to effectively adhere to the requirements of the grant. Supporting documentation is not available for employees’ actual time spent and charged to the grants. Statement of Effect: Without proper accounting of expenditures and support of salaries and wages, grant expenditures can be over or understated on the drawdown requests. This could result in noncompliance with grant agreements which could lead to adverse conditions with the grantors. Questioned Costs: No questioned costs were identified. Identification of Repeat Findings: Not a repeat finding. Recommendations: Project codes or classes should be created within the accounting system, if available. This will allow for expenses to be properly segregated by grant or other funding. When expenses are properly segregated, the indirect cost can be properly calculated using the correct direct cost base. The Association should also implement that all employees submit personnel activity reports to provide documentation of their time allocated to the grant. Views of Responsible Official(s): The Association is in agreement with the finding and is continuing to expand their knowledge on grant expenditures and compliance as it relates to the new financial management software to aid in tracking grants. See corrective action plan.
Financial Management System- (Material Weakness) Criteria:According to 2 CFR 200.302, the financial management system of each non-Federal entity must provide records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Condition: Statement of financial position transactions were not allocated properly to programs/properties funded with federal funds. Cause: Due to a human error of individuals who were handling the accounting entries, some of transactions were not accurately allocated to the correct programs/properties. Effect: Improper allocation of transactions among various programs/properties could lead to comingling of funds from different projects. This could result in unallowable cost or in allowable cost charged simultaneously to two different programs/properties. Questioned Cost: Undetermined Recommendation: Establish an internal control procedures in place that provide for separate accountability for projects by allocating transactions properly and producing accurate financial reports for each federally funded programs/properties. Management's Views and Corrective Action Plan Management's response is included in "Management's View and Corrective Action Plan" at the end of this report after the schedule of findings and questioned cost