8. Criteria or specific requirement (including statutory, regulatory, or other citation): The compliance requirements for "L. Reporting", requires the District to maintain accurate accounting records for grant expenditures. In addition, per subpart D (Post Federal Award Requirements), § 200.302, the underlying accounts records must be adequately documented and consistent with the terms and conditions of the grant. '9. Condition: The District claimed expenditures that did not agree with their underlying accounting records. '10. Questioned Costs: 110867. '11. Context: During compliance testing of the District’s accounting records in comparison to the expenditure reports filed with the Illinois State Board of Education, it was noted that the District overclaimed a total of $110,867 in expenditures as of June 30, 2024. The following discrepancies were identified: Function 1000-300: The District claimed $50,148 on the quarterly report filed as of 6/30/24. This amount could not be traced to the accounting records as of that date, resulting in an overclaim of $50,148. Function 1000-200: The District claimed $107,470 on the final report filed 9/30/24. Supporting expenditures could only be provided for $67,752, resulting in an overclaim of $39,718. Function 2130-100: The District claimed $10,440 on the final report filed 9/30/24. Supporting expenditures could only be provided for $10,200, resulting in an overclaim of $240. Function 2130-200: The District claimed $1,054 on the final report filed 9/30/24. Supporting expenditures could only be provided for $709, resulting in an overclaim of $345. Function 2400-100: The District claimed $44,160 on the final report filed 9/30/24. Supporting expenditures could only be provided for $37,960, resulting in an overclaim of $6,200. Function 2660-300: The District claimed $1,711,854 on the final report filed 9/30/24 for expenditures as of 6/30/24. Supporting expenditures could only be provided for $1,697,638, resulting in an overclaim of $14,216. '12. Effect: The District was not compliant with reporting requirements. Inaccurate reporting resulted in the District being reimbursed for an additional $110,867 as of 6/30/24. 13. Cause: Policies and procedures are in place that provide reasonable assurance that reports of federal awards submitted to ISBE are supported by the underlying accounting records and are fairly presented in accordance with program requirements. These policies and procedures were not followed when the expenditure report was prepared and filed. 14. Recommendation: We recommend the District periodically review the itemized budget and ensure claimed expenditures fall within or file amendments as necessary for any changes. 15. Management's response: The District has agreed with the findings and recommendations as presented. The District will review the itemized budget and ensure claimed expenditures fall within the grant. See Corrective Action Plan provided by the District.
Condition - The Municipality’s staff was unable to provide officially prepared and certified reports supporting compliance with the filing and submission requirements for reports and financial information, as established by federal award and regulatory agreements. Similarly, reconciliations were not provided between the information used to prepare the required and submitted reports and the formal data recorded in the Municipality’s official accounting system. Due to these conditions, compliance with the reporting requirements established by the federal grantor and effectiveness of related internal controls could not be verified. Based on an analysis prepared by the Municipality of the bank accounts and certain records and subsidiary ledgers designated for managing Community Development Block Grant / Disaster Recovery (CDBG-DR) funds, including transactions during the fiscal year ended June 30, 2024, and subsequent disbursements, a total of $850,079 was either expended or transferred to the General Fund to cover eligible expenditures under the terms permitted by the CDBG-DR program. Criteria - Per the Compliance and Reporting Guidance – Part I: General Guidance – Section D: Uniform Administrative Requirements – Section 10: Reporting: establishes that: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Recipients should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, recipients need to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Also, as established in the 2 CFR Section 200.302 (a) of the Uniform Guidance, the 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. In addition, 2 CFR Section 200.403 states that otherwise authorized by statue, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity and be adequately documented. Cause - There is a lack of adequate knowledge and training among personnel assigned to the management and preparation of reports required by this federal award. Additionally, the Municipality did not demonstrate, nor did it provide evidence, that it has designed and implemented an adequate system of procedures and internal controls to monitor the activity, filing, and custody of reports, as required by the federal award and the pass-through entity. These deficiencies limit the Municipality’s ability to document and support compliance with the reporting requirements. Effect - These conditions expose the program to noncompliance with the reporting requirements established in the grant agreement. Furthermore, the Municipality may be at risk of the grantor questioning the allowability and use of federal funds. Recommendation - We recommend that the responsible personnel or department identify, compile, and retain all reports required under the grant agreement, including reconciliations with the Municipality’s official accounting records and subsidiary ledgers. Additionally, it is essential for the Municipality to develop, document, and implement a comprehensive training program, along with written guidelines and procedures, for all personnel involved, directly or indirectly, in the management of these federal funds. Questioned Costs - None
Condition - The Municipality’s staff was unable to provide officially prepared and certified reports supporting compliance with the filing and submission requirements for reports and financial information, as established by federal award and regulatory agreements. Similarly, reconciliations were not provided between the information used to prepare the required and submitted reports and the formal data recorded in the Municipality’s official accounting system. Due to these conditions, compliance with the reporting requirements established by the federal grantor and effectiveness of related internal controls could not be verified. Based on an analysis prepared by the Municipality of the bank accounts and certain records and subsidiary ledgers designated for managing Community Development Block Grant / Disaster Recovery (CDBG-DR) funds, including transactions during the fiscal year ended June 30, 2024, and subsequent disbursements, a total of $850,079 was either expended or transferred to the General Fund to cover eligible expenditures under the terms permitted by the CDBG-DR program. Criteria - Per the Compliance and Reporting Guidance – Part I: General Guidance – Section D: Uniform Administrative Requirements – Section 10: Reporting: establishes that: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Recipients should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, recipients need to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Also, as established in the 2 CFR Section 200.302 (a) of the Uniform Guidance, the 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. In addition, 2 CFR Section 200.403 states that otherwise authorized by statue, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity and be adequately documented. Cause - There is a lack of adequate knowledge and training among personnel assigned to the management and preparation of reports required by this federal award. Additionally, the Municipality did not demonstrate, nor did it provide evidence, that it has designed and implemented an adequate system of procedures and internal controls to monitor the activity, filing, and custody of reports, as required by the federal award and the pass-through entity. These deficiencies limit the Municipality’s ability to document and support compliance with the reporting requirements. Effect - These conditions expose the program to noncompliance with the reporting requirements established in the grant agreement. Furthermore, the Municipality may be at risk of the grantor questioning the allowability and use of federal funds. Recommendation - We recommend that the responsible personnel or department identify, compile, and retain all reports required under the grant agreement, including reconciliations with the Municipality’s official accounting records and subsidiary ledgers. Additionally, it is essential for the Municipality to develop, document, and implement a comprehensive training program, along with written guidelines and procedures, for all personnel involved, directly or indirectly, in the management of these federal funds. Questioned Costs - None
Condition - The Municipality’s staff was unable to provide officially prepared and certified reports supporting compliance with the filing and submission requirements for reports and financial information, as established by federal award and regulatory agreements. Similarly, reconciliations were not provided between the information used to prepare the required and submitted reports and the formal data recorded in the Municipality’s official accounting system. Due to these conditions, compliance with the reporting requirements established by the federal grantor and effectiveness of related internal controls could not be verified. Based on an analysis prepared by the Municipality of the bank account and certain records and subsidiary ledgers designated for managing Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) funds, including transactions during the fiscal year ended June 30, 2024, and subsequent disbursements, a total of $768,525 was either expended or transferred to the General Fund to cover eligible expenditures under the terms permitted by the CSLFRF programs. Criteria - Per the Compliance and Reporting Guidance – Part I: General Guidance – Section D: Uniform Administrative Requirements – Section 10: Reporting: establishes that: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Recipients should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, recipients need to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Also, as established in the 2 CFR Section 200.302 (a) of the Uniform Guidance, the 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. In addition, 2 CFR Section 200.403, states that otherwise authorized by statue, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity and be adequately documented. Cause - There is a lack of adequate knowledge and training among personnel assigned to the management and preparation of reports required by this federal award. Additionally, the Municipality did not demonstrate, nor did it provide evidence, that it has designed and implemented an adequate system of procedures and internal controls to monitor the activity, filing, and custody of reports, as required by the federal award and the pass-through entity. These deficiencies limit the Municipality’s ability to document and support compliance with the reporting requirements. Effect -These conditions expose the program to noncompliance with the reporting requirements established in the grant agreement. Furthermore, the Municipality may be at risk of the grantor questioning the allowability and use of federal funds. Recommendation - We recommend that the responsible personnel or department identify, compile, and retain all reports required under the grant agreement, including reconciliations with the Municipality’s official accounting records and subsidiary ledgers. Additionally, it is essential for the Municipality to develop, document, and implement a comprehensive training program, along with written guidelines and procedures, for all personnel involved, directly or indirectly, in the management of these federal funds. Questioned Costs – None
Condition - The Municipality’s staff was unable to provide officially prepared and certified reports supporting compliance with the filing and submission requirements for reports and financial information, as established by federal award and regulatory agreements. Similarly, reconciliations were not provided between the information used to prepare the required and submitted reports and the formal data recorded in the Municipality’s official accounting system. Due to these conditions, compliance with the reporting requirements established by the federal grantor and effectiveness of related internal controls could not be verified. Based on an analysis prepared by the Municipality of the bank account and certain records and subsidiary ledgers designated for managing Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) funds, including transactions during the fiscal year ended June 30, 2024, and subsequent disbursements, a total of $768,525 was either expended or transferred to the General Fund to cover eligible expenditures under the terms permitted by the CSLFRF programs. Criteria - Per the Compliance and Reporting Guidance – Part I: General Guidance – Section D: Uniform Administrative Requirements – Section 10: Reporting: establishes that: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Recipients should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, recipients need to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Also, as established in the 2 CFR Section 200.302 (a) of the Uniform Guidance, the 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. In addition, 2 CFR Section 200.403, states that otherwise authorized by statue, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity and be adequately documented. Cause - There is a lack of adequate knowledge and training among personnel assigned to the management and preparation of reports required by this federal award. Additionally, the Municipality did not demonstrate, nor did it provide evidence, that it has designed and implemented an adequate system of procedures and internal controls to monitor the activity, filing, and custody of reports, as required by the federal award and the pass-through entity. These deficiencies limit the Municipality’s ability to document and support compliance with the reporting requirements. Effect -These conditions expose the program to noncompliance with the reporting requirements established in the grant agreement. Furthermore, the Municipality may be at risk of the grantor questioning the allowability and use of federal funds. Recommendation - We recommend that the responsible personnel or department identify, compile, and retain all reports required under the grant agreement, including reconciliations with the Municipality’s official accounting records and subsidiary ledgers. Additionally, it is essential for the Municipality to develop, document, and implement a comprehensive training program, along with written guidelines and procedures, for all personnel involved, directly or indirectly, in the management of these federal funds. Questioned Costs – None
Condition - The Municipality’s staff was unable to provide officially prepared and certified reports supporting compliance with the filing and submission requirements for reports and financial information, as established by federal award and regulatory agreements. Similarly, reconciliations were not provided between the information used to prepare the required and submitted reports and the formal data recorded in the Municipality’s official accounting system. Due to these conditions, compliance with the reporting requirements established by the federal grantor and effectiveness of related internal controls could not be verified. Based on an analysis prepared by the Municipality of the bank account and certain records and subsidiary ledgers designated for managing Disaster Grants - Public Assistance (Presidentially Declared Disasters) funds, including transactions during the fiscal year ended June 30, 2024, and subsequent disbursements, a total of $4,115,693 was either expended or transferred to the General Fund to cover eligible expenditures under the terms permitted by the grants. Criteria - The state is required to make an accounting of eligible costs. Similarly, the subrecipient must make an accounting to the state. In submitting the accounting, the entity is required to certify that reported costs were incurred in performance of eligible work, that the approved work was completed, that the project in in compliance with the provisions of the State Agreement, all grants conditions were met, and the provisions for that project were made in accordance with the applicable payment provisions. Also, as established in the 2 CFR Section 200.302 (a) of the Uniform Guidance, the 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. In addition, 2 CFR Section 200.403, states that otherwise authorized by statue, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity and be adequately documented. Cause - There is a lack of adequate knowledge and training among personnel assigned to the management and preparation of reports required by this federal award. Additionally, the Municipality did not demonstrate, nor did it provide evidence, that it has designed and implemented an adequate system of procedures and internal controls to monitor the activity, filing, and custody of reports, as required by the federal award and the pass-through entity. These deficiencies limit the Municipality’s ability to document and support compliance with the reporting requirements. Effect - These conditions expose the program to noncompliance with the reporting requirements established in the grant agreement. Furthermore, the Municipality may be at risk of the grantor questioning the allowability and use of federal funds. Recommendation - We recommend that the responsible personnel or department identify, compile, and retain all reports required under the grant agreement, including reconciliations with the Municipality’s official accounting records and subsidiary ledgers. Additionally, it is essential for the Municipality to develop, document, and implement a comprehensive training program, along with written guidelines and procedures, for all personnel involved, directly or indirectly, in the management of these federal funds. Questioned Costs - None
Condition - The Municipality’s staff was unable to provide officially prepared and certified reports supporting compliance with the filing and submission requirements for reports and financial information, as established by federal award and regulatory agreements. Similarly, reconciliations were not provided between the information used to prepare the required and submitted reports and the formal data recorded in the Municipality’s official accounting system. Due to these conditions, compliance with the reporting requirements established by the federal grantor and effectiveness of related internal controls could not be verified. Based on an analysis prepared by the Municipality of the bank account and certain records and subsidiary ledgers designated for managing Disaster Grants - Public Assistance (Presidentially Declared Disasters) funds, including transactions during the fiscal year ended June 30, 2024, and subsequent disbursements, a total of $4,115,693 was either expended or transferred to the General Fund to cover eligible expenditures under the terms permitted by the grants. Criteria - The state is required to make an accounting of eligible costs. Similarly, the subrecipient must make an accounting to the state. In submitting the accounting, the entity is required to certify that reported costs were incurred in performance of eligible work, that the approved work was completed, that the project in in compliance with the provisions of the State Agreement, all grants conditions were met, and the provisions for that project were made in accordance with the applicable payment provisions. Also, as established in the 2 CFR Section 200.302 (a) of the Uniform Guidance, the 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. In addition, 2 CFR Section 200.403, states that otherwise authorized by statue, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity and be adequately documented. Cause - There is a lack of adequate knowledge and training among personnel assigned to the management and preparation of reports required by this federal award. Additionally, the Municipality did not demonstrate, nor did it provide evidence, that it has designed and implemented an adequate system of procedures and internal controls to monitor the activity, filing, and custody of reports, as required by the federal award and the pass-through entity. These deficiencies limit the Municipality’s ability to document and support compliance with the reporting requirements. Effect - These conditions expose the program to noncompliance with the reporting requirements established in the grant agreement. Furthermore, the Municipality may be at risk of the grantor questioning the allowability and use of federal funds. Recommendation - We recommend that the responsible personnel or department identify, compile, and retain all reports required under the grant agreement, including reconciliations with the Municipality’s official accounting records and subsidiary ledgers. Additionally, it is essential for the Municipality to develop, document, and implement a comprehensive training program, along with written guidelines and procedures, for all personnel involved, directly or indirectly, in the management of these federal funds. Questioned Costs - None
#2024‐001 – Significant Deficiency – Supporting Documentation Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.302(b)(3) states, “The recipient’s financial management system must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.” Condition During the course of the audit, we noted there was no approved source documentation for a recurring expense tested. Cause The Organization has made a reasonable effort to design proper controls, but has faced challenges in implementing them effectively, due to growth across multiple locations and frequent turnover. Effect The potential effects of not having supporting documentation on file could include over or undercharging expenses to the federal grants. Questioned Costs None Perspective Information The finding noted related to one (1) transaction examined when testing a sample of forty (40) non‐payroll cash disbursements. The transaction was a recurring monthly charge that was supported by an agreement approved by an employee who has since left the Organization. The Organization was unable to locate a copy of the signed agreement. Identification as a repeat finding There was no similar finding in the prior year. Recommendation We recommend having supporting documentation on file for all expenses charged to the Federal grants that shows approval of the expense from an appropriate member of management. View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.
#2024‐001 – Significant Deficiency – Supporting Documentation Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.302(b)(3) states, “The recipient’s financial management system must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.” Condition During the course of the audit, we noted there was no approved source documentation for a recurring expense tested. Cause The Organization has made a reasonable effort to design proper controls, but has faced challenges in implementing them effectively, due to growth across multiple locations and frequent turnover. Effect The potential effects of not having supporting documentation on file could include over or undercharging expenses to the federal grants. Questioned Costs None Perspective Information The finding noted related to one (1) transaction examined when testing a sample of forty (40) non‐payroll cash disbursements. The transaction was a recurring monthly charge that was supported by an agreement approved by an employee who has since left the Organization. The Organization was unable to locate a copy of the signed agreement. Identification as a repeat finding There was no similar finding in the prior year. Recommendation We recommend having supporting documentation on file for all expenses charged to the Federal grants that shows approval of the expense from an appropriate member of management. View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.
#2024‐001 – Significant Deficiency – Supporting Documentation Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.302(b)(3) states, “The recipient’s financial management system must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.” Condition During the course of the audit, we noted there was no approved source documentation for a recurring expense tested. Cause The Organization has made a reasonable effort to design proper controls, but has faced challenges in implementing them effectively, due to growth across multiple locations and frequent turnover. Effect The potential effects of not having supporting documentation on file could include over or undercharging expenses to the federal grants. Questioned Costs None Perspective Information The finding noted related to one (1) transaction examined when testing a sample of forty (40) non‐payroll cash disbursements. The transaction was a recurring monthly charge that was supported by an agreement approved by an employee who has since left the Organization. The Organization was unable to locate a copy of the signed agreement. Identification as a repeat finding There was no similar finding in the prior year. Recommendation We recommend having supporting documentation on file for all expenses charged to the Federal grants that shows approval of the expense from an appropriate member of management. View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.
#2024‐001 – Significant Deficiency – Supporting Documentation Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.302(b)(3) states, “The recipient’s financial management system must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.” Condition During the course of the audit, we noted there was no approved source documentation for a recurring expense tested. Cause The Organization has made a reasonable effort to design proper controls, but has faced challenges in implementing them effectively, due to growth across multiple locations and frequent turnover. Effect The potential effects of not having supporting documentation on file could include over or undercharging expenses to the federal grants. Questioned Costs None Perspective Information The finding noted related to one (1) transaction examined when testing a sample of forty (40) non‐payroll cash disbursements. The transaction was a recurring monthly charge that was supported by an agreement approved by an employee who has since left the Organization. The Organization was unable to locate a copy of the signed agreement. Identification as a repeat finding There was no similar finding in the prior year. Recommendation We recommend having supporting documentation on file for all expenses charged to the Federal grants that shows approval of the expense from an appropriate member of management. View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.
#2024‐001 – Significant Deficiency – Supporting Documentation Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.302(b)(3) states, “The recipient’s financial management system must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.” Condition During the course of the audit, we noted there was no approved source documentation for a recurring expense tested. Cause The Organization has made a reasonable effort to design proper controls, but has faced challenges in implementing them effectively, due to growth across multiple locations and frequent turnover. Effect The potential effects of not having supporting documentation on file could include over or undercharging expenses to the federal grants. Questioned Costs None Perspective Information The finding noted related to one (1) transaction examined when testing a sample of forty (40) non‐payroll cash disbursements. The transaction was a recurring monthly charge that was supported by an agreement approved by an employee who has since left the Organization. The Organization was unable to locate a copy of the signed agreement. Identification as a repeat finding There was no similar finding in the prior year. Recommendation We recommend having supporting documentation on file for all expenses charged to the Federal grants that shows approval of the expense from an appropriate member of management. View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.
#2024‐001 – Significant Deficiency – Supporting Documentation Opioid STR Grant ALN 93.788 Criteria The Office of Management and Budget issuance of the Code of Federal Regulations (CFR) specifically states uniform administrative requirements, cost principles, and audit requirements for federal awards. CFR 200.302(b)(3) states, “The recipient’s financial management system must maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation.” Condition During the course of the audit, we noted there was no approved source documentation for a recurring expense tested. Cause The Organization has made a reasonable effort to design proper controls, but has faced challenges in implementing them effectively, due to growth across multiple locations and frequent turnover. Effect The potential effects of not having supporting documentation on file could include over or undercharging expenses to the federal grants. Questioned Costs None Perspective Information The finding noted related to one (1) transaction examined when testing a sample of forty (40) non‐payroll cash disbursements. The transaction was a recurring monthly charge that was supported by an agreement approved by an employee who has since left the Organization. The Organization was unable to locate a copy of the signed agreement. Identification as a repeat finding There was no similar finding in the prior year. Recommendation We recommend having supporting documentation on file for all expenses charged to the Federal grants that shows approval of the expense from an appropriate member of management. View of Responsible Official The CEO has implemented a policy that all signed documents and contracts will be uniformly kept in a corresponding file, and the files will be stored in a locked filing cabinet at the corporate office. The Director of Operations will be responsible to ensure that the documents and contracts are filed in a timely fashion.
2024-003 Internal Controls over Payroll – (Significant Deficiency) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2023; A23AV00801 U.S. Department of Interior Indian Schools Student Transportation 15.044 2023; A23AV00801 U.S. Department of Interior Administrative Cost Grants for Indian Schools 15.046 2023; A23AV00801 U.S. Department of Interior Indian Education Facilities, Operations, and Maintenance 15.047 2023; A23AV00801 Criteria or Specific Requirements: In accordance with 2 CFR § 200.302(b)(3) and § 200.430(i), recipients of federal funds must maintain documentation that supports the allowability and allocability of compensation costs. Personnel expenses must be supported by records that accurately reflect the work performed, and documentation must be maintained for each employee, including executed contracts, offer letters, pay rate approvals, timesheets, and separation documentation. Adequate support is necessary to demonstrate that federal funds were used in compliance with award conditions. Condition: During our review of internal controls over payroll processing, we selected 102 payroll transactions across four major programs. The School did not fully comply with its own adopted policies or applicable federal regulations concerning payroll documentation and processing. The following exceptions were identified: Termination letters were not provided for 5 samples. Adequate supporting document was not provided for 1 sample. Timesheet was not provided for 1 sample. Cause: The deficiencies appear to be due to a lack of consistent personnel file maintenance and insufficient internal controls over payroll documentation, record retention, and post-hiring compliance reviews. Effect: The lack of complete personnel documentation increases the risk of charging unallowable or unsupported costs to federal awards. It also affects the ability to verify employee eligibility, compensation accuracy, and the proper use of federal funds, potentially resulting in questioned costs and potential repayment obligations to granting agencies. Auditor's Recommendation: We recommend that the School implement enhanced internal controls and standardized procedures to ensure complete and accurate personnel records are maintained. This should include routine documentation checks to ensure that all required items, such as offer letters, contracts, paystubs, pay rate verifications, timesheets, and termination letters, are present and properly filed. Management should also provide training to relevant staff on federal compliance requirements related to payroll and personnel documentation.
2024-003 Internal Controls over Payroll – (Significant Deficiency) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2023; A23AV00801 U.S. Department of Interior Indian Schools Student Transportation 15.044 2023; A23AV00801 U.S. Department of Interior Administrative Cost Grants for Indian Schools 15.046 2023; A23AV00801 U.S. Department of Interior Indian Education Facilities, Operations, and Maintenance 15.047 2023; A23AV00801 Criteria or Specific Requirements: In accordance with 2 CFR § 200.302(b)(3) and § 200.430(i), recipients of federal funds must maintain documentation that supports the allowability and allocability of compensation costs. Personnel expenses must be supported by records that accurately reflect the work performed, and documentation must be maintained for each employee, including executed contracts, offer letters, pay rate approvals, timesheets, and separation documentation. Adequate support is necessary to demonstrate that federal funds were used in compliance with award conditions. Condition: During our review of internal controls over payroll processing, we selected 102 payroll transactions across four major programs. The School did not fully comply with its own adopted policies or applicable federal regulations concerning payroll documentation and processing. The following exceptions were identified: Termination letters were not provided for 5 samples. Adequate supporting document was not provided for 1 sample. Timesheet was not provided for 1 sample. Cause: The deficiencies appear to be due to a lack of consistent personnel file maintenance and insufficient internal controls over payroll documentation, record retention, and post-hiring compliance reviews. Effect: The lack of complete personnel documentation increases the risk of charging unallowable or unsupported costs to federal awards. It also affects the ability to verify employee eligibility, compensation accuracy, and the proper use of federal funds, potentially resulting in questioned costs and potential repayment obligations to granting agencies. Auditor's Recommendation: We recommend that the School implement enhanced internal controls and standardized procedures to ensure complete and accurate personnel records are maintained. This should include routine documentation checks to ensure that all required items, such as offer letters, contracts, paystubs, pay rate verifications, timesheets, and termination letters, are present and properly filed. Management should also provide training to relevant staff on federal compliance requirements related to payroll and personnel documentation.
2024-003 Internal Controls over Payroll – (Significant Deficiency) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2023; A23AV00801 U.S. Department of Interior Indian Schools Student Transportation 15.044 2023; A23AV00801 U.S. Department of Interior Administrative Cost Grants for Indian Schools 15.046 2023; A23AV00801 U.S. Department of Interior Indian Education Facilities, Operations, and Maintenance 15.047 2023; A23AV00801 Criteria or Specific Requirements: In accordance with 2 CFR § 200.302(b)(3) and § 200.430(i), recipients of federal funds must maintain documentation that supports the allowability and allocability of compensation costs. Personnel expenses must be supported by records that accurately reflect the work performed, and documentation must be maintained for each employee, including executed contracts, offer letters, pay rate approvals, timesheets, and separation documentation. Adequate support is necessary to demonstrate that federal funds were used in compliance with award conditions. Condition: During our review of internal controls over payroll processing, we selected 102 payroll transactions across four major programs. The School did not fully comply with its own adopted policies or applicable federal regulations concerning payroll documentation and processing. The following exceptions were identified: Termination letters were not provided for 5 samples. Adequate supporting document was not provided for 1 sample. Timesheet was not provided for 1 sample. Cause: The deficiencies appear to be due to a lack of consistent personnel file maintenance and insufficient internal controls over payroll documentation, record retention, and post-hiring compliance reviews. Effect: The lack of complete personnel documentation increases the risk of charging unallowable or unsupported costs to federal awards. It also affects the ability to verify employee eligibility, compensation accuracy, and the proper use of federal funds, potentially resulting in questioned costs and potential repayment obligations to granting agencies. Auditor's Recommendation: We recommend that the School implement enhanced internal controls and standardized procedures to ensure complete and accurate personnel records are maintained. This should include routine documentation checks to ensure that all required items, such as offer letters, contracts, paystubs, pay rate verifications, timesheets, and termination letters, are present and properly filed. Management should also provide training to relevant staff on federal compliance requirements related to payroll and personnel documentation.
2024-003 Internal Controls over Payroll – (Significant Deficiency) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2023; A23AV00801 U.S. Department of Interior Indian Schools Student Transportation 15.044 2023; A23AV00801 U.S. Department of Interior Administrative Cost Grants for Indian Schools 15.046 2023; A23AV00801 U.S. Department of Interior Indian Education Facilities, Operations, and Maintenance 15.047 2023; A23AV00801 Criteria or Specific Requirements: In accordance with 2 CFR § 200.302(b)(3) and § 200.430(i), recipients of federal funds must maintain documentation that supports the allowability and allocability of compensation costs. Personnel expenses must be supported by records that accurately reflect the work performed, and documentation must be maintained for each employee, including executed contracts, offer letters, pay rate approvals, timesheets, and separation documentation. Adequate support is necessary to demonstrate that federal funds were used in compliance with award conditions. Condition: During our review of internal controls over payroll processing, we selected 102 payroll transactions across four major programs. The School did not fully comply with its own adopted policies or applicable federal regulations concerning payroll documentation and processing. The following exceptions were identified: Termination letters were not provided for 5 samples. Adequate supporting document was not provided for 1 sample. Timesheet was not provided for 1 sample. Cause: The deficiencies appear to be due to a lack of consistent personnel file maintenance and insufficient internal controls over payroll documentation, record retention, and post-hiring compliance reviews. Effect: The lack of complete personnel documentation increases the risk of charging unallowable or unsupported costs to federal awards. It also affects the ability to verify employee eligibility, compensation accuracy, and the proper use of federal funds, potentially resulting in questioned costs and potential repayment obligations to granting agencies. Auditor's Recommendation: We recommend that the School implement enhanced internal controls and standardized procedures to ensure complete and accurate personnel records are maintained. This should include routine documentation checks to ensure that all required items, such as offer letters, contracts, paystubs, pay rate verifications, timesheets, and termination letters, are present and properly filed. Management should also provide training to relevant staff on federal compliance requirements related to payroll and personnel documentation.
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024.003: Cash Management - Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Substance Abuse and Mental Health Services Projects of Regional and National Significance Certified Community Behavioral Health Clinic Expansion Grants Federal Assistance Listing Number: 93.243 and 93.696 Federal Award Identification Number and Year: H79SM087223 - 2024, H79SM086969 - 2024 Criteria In accordance with §200.305, federal payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None Context We selected seven drawdowns for testing of cash management relating to these major programs. We noted there was no formal approval or evidence of review for these drawdowns Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Finding 2024.003: Cash Management - Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Substance Abuse and Mental Health Services Projects of Regional and National Significance Certified Community Behavioral Health Clinic Expansion Grants Federal Assistance Listing Number: 93.243 and 93.696 Federal Award Identification Number and Year: H79SM087223 - 2024, H79SM086969 - 2024 Criteria In accordance with §200.305, federal payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None Context We selected seven drawdowns for testing of cash management relating to these major programs. We noted there was no formal approval or evidence of review for these drawdowns Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Finding 2024.003: Cash Management - Significant Deficiency Grantor: U.S. Department of Health and Human Services Federal Program Names: Substance Abuse and Mental Health Services Projects of Regional and National Significance Certified Community Behavioral Health Clinic Expansion Grants Federal Assistance Listing Number: 93.243 and 93.696 Federal Award Identification Number and Year: H79SM087223 - 2024, H79SM086969 - 2024 Criteria In accordance with §200.305, federal payment, grantees and subgrantees that receive grant funds are responsible for maintaining controls regarding the management of federal program funds under the Uniform Guidance in 2 CFR 200.302 and 200.303. Condition The Center's drawdowns did not illustrate review and approval by management. Cause The Center did not have adequate controls to ensure drawdowns were properly approved and such approval is documented. Effect The condition may lead to inaccurate or improper drawdowns. Questioned Costs None Context We selected seven drawdowns for testing of cash management relating to these major programs. We noted there was no formal approval or evidence of review for these drawdowns Identification of Repeat Finding Not a repeat finding. Recommendation The Center should develop written procedures to review all drawdowns that occur in order to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions Management and the Board of Directors agree with the finding and will implement additional controls to ensure there is formal evidence of review being performed.
Information on the Federal Program: Assistance Listing Number 10.568—Food Distribution Cluster; Emergency Food Assistance Program (Food Commodities). Pass-Through Entity: Los Angeles Regional Foodbank. Compliance Requirements: Special Test and Provision. Type of Finding: Material Noncompliance. Criteria: The Compliance Supplement for the Food Distribution Cluster requires recipient organizations to maintain accurate, timely records of USDA Foods activity, including receipts, distributions (usage), and losses. Records must reflect correct quantities, proper periods, and supporting documentation for federal commodities. Additionally, Uniform Guidance 2 CFR § 200.302 mandates that non-federal entities maintain complete and accurate financial and programmatic records to ensure accountability for federal funds and assets. Condition: During our testing, we found that NVCS recorded all TEFAP distributions as a single year-end transaction instead of recording distributions as they occurred. Consequently, detailed, contemporaneous records of usage or distributions were not available, preventing verification of the accuracy, timing, and proper support of federal food distributions during the audit period. Cause: NVCS misunderstood the requirement to record USDA Foods usage and distributions throughout the year, believing a year-end summary was sufficient. Furthermore, NVCS lacked written procedures and internal controls to ensure timely and compliant documentation of commodity distributions. Effect or Potential Effect: Without detailed records of distributions throughout the year, NVCS cannot demonstrate compliance with federal requirements. This increases the risk of incorrect quantities, misreporting periods, or distributions to ineligible recipients. It may also result in questioned costs or affect NVCS’s eligibility to continue administering the program. Questioned Costs: None Context: NVCS recorded only one summary distribution transaction for the year ended June 30, 2024, representing 100% of USDA Foods activity. No detailed records were maintained, preventing sample testing and indicating a systemic control deficiency. Repeat Finding: No — This is NVCS's first Single Audit. Recommendation: We recommend NVCS establish procedures to record USDA Foods distributions at the time they occur, documenting quantities, dates, recipient agencies (if applicable), and supporting evidence. Staff should be trained on proper recordkeeping requirements, and management should implement periodic reviews to ensure accuracy and timeliness. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding and will revise procedures to ensure detailed, timely recording of USDA Foods distributions. Staff will receive training on documentation requirements, and management will implement periodic compliance reviews. These corrective actions are expected to be completed by March 1, 2025.
2024-001 – Reporting - Preparation of the Schedule of Expenditures of Federal Awards Identification of the Federal Program – Department of Housing and Urban Development - 14.128 Mortgage Insurance Hospitals - FHA Section 242 Mortgage Insurance Program Loan Criteria – CFR Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards (Schedule) for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with §200.502”. Also, in accordance with CFR Section §200.302, a 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. Condition – We noted that there were adjustments needed to the Schedule to include initial debt issuance costs incurred and drawn during the period in connection with the new HUD mortgage secured during January 2024. Cause – Internal controls over review of the completeness of the Schedule were not properly implemented during the period of additional mortgages secured. Such internal controls were designed to require timely review of the completeness of the Schedule by appropriate personnel. Effect – The Schedule for the year ended June 30, 2024 inappropriately excluded $845,273 of related expenditures against the latest HUD mortgage established during January 2024. Questioned costs – none Context – Internal controls did not operate as intended to ensure the Schedule captured nonrecurring expenditures. In connection with securing the January 2024 HUD mortgage, certain debt issuance costs were charged against the mortgage upon closing. These expenditures were not part of the routine expenditure and draw processes and controls in place at the Authority due to their unique nature and infrequency. Therefore, management did not identify such initial closing costs for capture on the Schedule. Repeat finding – No Recommendation – We recommend the Schedule to be reviewed timely and with sufficient precision by the appropriate level of personnel and reconciliation of new HUD mortgage closing documents. View of Responsible Officials - Management agrees with the Federal Award Finding regarding the determination of when a Federal award is expended. As part of the Corrective Action Plan, management will validate mortgage activity against HUD mortgage provided information.
2024-002 WRITTEN POLICIES REQUIRED BY UNIFORM GRANT GUIDANCE Programs: Assistance to Firefighters Grants; U.S. Department of Homeland Security; ALN 97.044 Airport Improvement Program; U.S. Department of Transportation; ALN 20.106; All Award Numbers Condition: The City has not adopted federal policies as required by the Uniform Guidance (2 CFR Part 200). Key policies, including, but not limited to, procurement, subrecipient monitoring, and financial management, have not been implemented in accordance with federal standards. Criteria: Uniform Guidance mandates that entities expending federal awards comply with federal policies and procedures to ensure proper management and accountability of federal funds. Specifically, 2 CFR 200.302(b) and 200.318 require entities to implement adequate financial and procurement management systems. Cause: The City lacks formal processes to update and align its internal policies with Uniform Guidance requirements, leading to gaps in federally compliant procedures. Effect: Noncompliance with the Uniform Guidance could result in improper use or oversight of federal funds, increasing the risk of audit findings, potential disallowed costs, and jeopardizing future federal funding. Questioned Costs: No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowable costs or excess cash draws. Recommendation: Management should establish and implement federal-compliant policies, specifically focusing on procurement, financial management, and subrecipient monitoring, to ensure full alignment with Uniform Guidance requirements. Periodic policy reviews should be conducted to ensure continued compliance. View of Responsible Officials: Management agrees with the finding and will create appropriate policies and procedures to alleviate the finding from re-occurring.
2024-002 WRITTEN POLICIES REQUIRED BY UNIFORM GRANT GUIDANCE Programs: Assistance to Firefighters Grants; U.S. Department of Homeland Security; ALN 97.044 Airport Improvement Program; U.S. Department of Transportation; ALN 20.106; All Award Numbers Condition: The City has not adopted federal policies as required by the Uniform Guidance (2 CFR Part 200). Key policies, including, but not limited to, procurement, subrecipient monitoring, and financial management, have not been implemented in accordance with federal standards. Criteria: Uniform Guidance mandates that entities expending federal awards comply with federal policies and procedures to ensure proper management and accountability of federal funds. Specifically, 2 CFR 200.302(b) and 200.318 require entities to implement adequate financial and procurement management systems. Cause: The City lacks formal processes to update and align its internal policies with Uniform Guidance requirements, leading to gaps in federally compliant procedures. Effect: Noncompliance with the Uniform Guidance could result in improper use or oversight of federal funds, increasing the risk of audit findings, potential disallowed costs, and jeopardizing future federal funding. Questioned Costs: No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowable costs or excess cash draws. Recommendation: Management should establish and implement federal-compliant policies, specifically focusing on procurement, financial management, and subrecipient monitoring, to ensure full alignment with Uniform Guidance requirements. Periodic policy reviews should be conducted to ensure continued compliance. View of Responsible Officials: Management agrees with the finding and will create appropriate policies and procedures to alleviate the finding from re-occurring.
2024-002 WRITTEN POLICIES REQUIRED BY UNIFORM GRANT GUIDANCE Programs: Assistance to Firefighters Grants; U.S. Department of Homeland Security; ALN 97.044 Airport Improvement Program; U.S. Department of Transportation; ALN 20.106; All Award Numbers Condition: The City has not adopted federal policies as required by the Uniform Guidance (2 CFR Part 200). Key policies, including, but not limited to, procurement, subrecipient monitoring, and financial management, have not been implemented in accordance with federal standards. Criteria: Uniform Guidance mandates that entities expending federal awards comply with federal policies and procedures to ensure proper management and accountability of federal funds. Specifically, 2 CFR 200.302(b) and 200.318 require entities to implement adequate financial and procurement management systems. Cause: The City lacks formal processes to update and align its internal policies with Uniform Guidance requirements, leading to gaps in federally compliant procedures. Effect: Noncompliance with the Uniform Guidance could result in improper use or oversight of federal funds, increasing the risk of audit findings, potential disallowed costs, and jeopardizing future federal funding. Questioned Costs: No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowable costs or excess cash draws. Recommendation: Management should establish and implement federal-compliant policies, specifically focusing on procurement, financial management, and subrecipient monitoring, to ensure full alignment with Uniform Guidance requirements. Periodic policy reviews should be conducted to ensure continued compliance. View of Responsible Officials: Management agrees with the finding and will create appropriate policies and procedures to alleviate the finding from re-occurring.
Reference Number: 2024-003 Description: Written Procedures Condition and Criteria: At the beginning of the audit period, the District did not have a Federal Funds Manual in place to document policies and procedures for managing federal awards in compliance 2 CFR 200, Subparts D and E. The Uniform Guidance requires the following written procedures: Written procedures for grant financial management (2 CFR 200.302 and 2 CFR 200.305) Written procurement policy (2 CFR 200.318a) Written procedures for allowable costs (2 CFR 200.403) Written procedures for managing and safeguarding property or equipment acquired with federal funds (2 CFR 200.313) During the course of the audit, the District developed and implemented a Federal Funds Manual to address this deficiency. Cause: There was an administrative oversight of ensuring the District had these written procedures in place. Effect: The absence of a documented Federal Funds Manual increased the risk of noncompliance with federal requirements and ineffective management of federal funds. However, the district’s subsequent implementation of the manual before the audit’s completion reduced this risk. Recommendation: We recommend that the District continue to utilize and periodically review the Federal Funds Manual to ensure it remains comprehensive and up-to-date with changes in federal requirements. Views of Responsible Officials and Corrective Action: See Corrective Action Plan.
Reference Number: 2024-003 Description: Written Procedures Condition and Criteria: At the beginning of the audit period, the District did not have a Federal Funds Manual in place to document policies and procedures for managing federal awards in compliance 2 CFR 200, Subparts D and E. The Uniform Guidance requires the following written procedures: Written procedures for grant financial management (2 CFR 200.302 and 2 CFR 200.305) Written procurement policy (2 CFR 200.318a) Written procedures for allowable costs (2 CFR 200.403) Written procedures for managing and safeguarding property or equipment acquired with federal funds (2 CFR 200.313) During the course of the audit, the District developed and implemented a Federal Funds Manual to address this deficiency. Cause: There was an administrative oversight of ensuring the District had these written procedures in place. Effect: The absence of a documented Federal Funds Manual increased the risk of noncompliance with federal requirements and ineffective management of federal funds. However, the district’s subsequent implementation of the manual before the audit’s completion reduced this risk. Recommendation: We recommend that the District continue to utilize and periodically review the Federal Funds Manual to ensure it remains comprehensive and up-to-date with changes in federal requirements. Views of Responsible Officials and Corrective Action: See Corrective Action Plan.
Reference Number: 2024-003 Description: Written Procedures Condition and Criteria: At the beginning of the audit period, the District did not have a Federal Funds Manual in place to document policies and procedures for managing federal awards in compliance 2 CFR 200, Subparts D and E. The Uniform Guidance requires the following written procedures: Written procedures for grant financial management (2 CFR 200.302 and 2 CFR 200.305) Written procurement policy (2 CFR 200.318a) Written procedures for allowable costs (2 CFR 200.403) Written procedures for managing and safeguarding property or equipment acquired with federal funds (2 CFR 200.313) During the course of the audit, the District developed and implemented a Federal Funds Manual to address this deficiency. Cause: There was an administrative oversight of ensuring the District had these written procedures in place. Effect: The absence of a documented Federal Funds Manual increased the risk of noncompliance with federal requirements and ineffective management of federal funds. However, the district’s subsequent implementation of the manual before the audit’s completion reduced this risk. Recommendation: We recommend that the District continue to utilize and periodically review the Federal Funds Manual to ensure it remains comprehensive and up-to-date with changes in federal requirements. Views of Responsible Officials and Corrective Action: See Corrective Action Plan.
Information on the federal program: U.S. Department of Treasury, Assistance Listing No. 21.027 COVID-19 Coronavirus Fiscal Recovery Funds Criteria: 2 CFR 200.302 and 2 CFR 200.303 require entities to establish and maintain internal controls and financial management procedures to provide reasonable assurance the award is managed in compliance with statutes, regulations, and terms and conditions of the award and to ensure federal award expenditures are adequately supported by source documentation. Condition: We tested controls over disbursements to 11 hospitals during the year. For each hospital to receive funding they were to submit a staffing spreadsheet reporting their increased staffing costs due to COVID. Of the 11 tested, supporting documentation for 3 hospitals was not readily available. Additional information had to be obtained from the hospital to support the information reported by the hospital in the staffing spreadsheet. Cause: Salary information obtained in support of the staffing spreadsheet included Employees Quarterly Federal Tax Return (941) and payroll registers. Additional general ledger information had to be requested from the hospitals during the audit to reconcile to the amounts reported in the staffing spreadsheet. Effect: Internal Controls were not properly implemented to obtain source documentation to adequately support the amounts reported by the hospitals as additional staffing costs. Recommendation: We recommend the Organization strengthen its policies and procedures surrounding disbursements to hospitals to ensure the amounts reported were accurate and source documentation is retained to ensure compliance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the findings. See Management’s View and Corrective Action Plan included at the end of the report.
FINDING 2024-003 Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School District in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School District's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School District at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in place to prevent, or detect and correct, errors. During tie out of the Year 3 report, a variance between the underlying records and reported expenditures of $187,649 was noted due to the lack of effective controls surrounding annual data reporting. 84.425U expenditures submitted within the Year 3 report were overstated by $187,649. Identification as a repeat finding: Yes, see Finding 2022-001. Recommendation: We recommend someone other than the preparer of the report perform a documented, secondary review of the report information prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Finding Number 2024-006: Criteria or specific requirement: The District should maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards in accordance with 2 CFR 200.302(b)(3). Condition: The District did not maintain records that contain information necessary to identify Federal expenditures supported by source documentation. Questioned Costs: $5,200 Context: A Federal grant expenditure was claimed twice on the same grant expenditure report. Effect: Due to the same Federal grant expenditure being double-reported on the same grant expenditure report, actual grant expenditures were overstated. Cause: The same Federal grant expenditure was claimed twice (on two different line items) in the final grant expenditure report. Recommendation: The District should always maintain records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal expenditures. All records must be supported by source documentation. Management's Response: The District will work to ensure that records are maintained that sufficiently identify the amount, source and expenditure of Federal funds for Federal awards. Grant expenditure reports will be reviewed to make sure Federal award expenditures are not double-reported.
2024-001 Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards (SEFA)) Information on the Major Federal Programs: Department of Housing and Urban Development Federal Assistance Listing Number: 14.218 Federal Assistance Listing Name: Community Development Block Grants/Entitlement Grants Grant Number: CV-2-8 Department of Health and Human Services Federal Assistance Listing Number: 93.566 Federal Assistance Listing Name: Refugee and Entrant Assistance - State-Administered Programs Grant Number: JA-FSA-RSS-2022 Criteria: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR part 200) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a 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. The financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for Federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets.
2024-001 Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards (SEFA)) Information on the Major Federal Programs: Department of Housing and Urban Development Federal Assistance Listing Number: 14.218 Federal Assistance Listing Name: Community Development Block Grants/Entitlement Grants Grant Number: CV-2-8 Department of Health and Human Services Federal Assistance Listing Number: 93.566 Federal Assistance Listing Name: Refugee and Entrant Assistance - State-Administered Programs Grant Number: JA-FSA-RSS-2022 Criteria: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR part 200) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a 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. The financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for Federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets.
2024-001 Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards (SEFA)) Information on the Major Federal Programs: Department of Housing and Urban Development Federal Assistance Listing Number: 14.218 Federal Assistance Listing Name: Community Development Block Grants/Entitlement Grants Grant Number: CV-2-8 Department of Health and Human Services Federal Assistance Listing Number: 93.566 Federal Assistance Listing Name: Refugee and Entrant Assistance - State-Administered Programs Grant Number: JA-FSA-RSS-2022 Criteria: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR part 200) Section §200.510(b) states in part: “The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section §200.502 Basis for determining Federal awards expended.” The schedule must provide total federal awards expended for each individual Federal program. In accordance with §200.302 Financial Management, a 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. The financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for Federally-funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets.
SIGNIFICANT DEFICENCY AND MATERIAL NONCOMPLIANCE Internal Controls and Report Submissions Criteria: Pursuant to the Code of Federal Regulations (CFR), Title 2 Grants and Agreements, Subpart D Post Federal Award Requirements, Section 200.303 “the 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.” Also pursuant to the Code of Federal Regulations (CFR), Title 2 Grants and Agreements, Subpart D Post Federal Award Requirements, Section 200.302 Financial Management (2 CFR §200.302), “identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received.” Condition: When investigating the controls related to Education Stabilization Fund reporting to the State of Kanas, we became aware that the same individual compiling the information is the same submitting the reports with no secondary review. During our examination of the reports submitted for the fiscal year, the report for the quarter ending June 2024 did not back to financial records by approximately $60.989. Cause: The controls related to reporting for Education Stabilization Fund are non-existent. Effect: There is no internal control related to reporting for Education Stabilization Fund. Questioned Costs: $60,989 Recommendations: The District should have an employee compare the Board Clerk’s supporting documentation and the Education Stabilization Fund spreadsheet report before its submission to the State of Kansas for its accuracy. After the approval by the secondary review employee, the report submitted should be printed, initialed by the secondary reviewer, stapled with the information used to compile the report and combined with all financial records for the fiscal year. Views of Responsible Officials and Planned Corrective Actions: The District agrees with the finding. See separate document for planned corrective actions.
Criteria - 2 CFR Part 200, Subpart D, paragraph 200.302 (b)(3) - Maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. Condition - Expenditures were claimed as federal expenditures for the purchase of supplies even though the purchase agreement had not been fulfilled and supported by appropriate source documentation. Questioned Costs - Expenditiures in the amount of $258,750 for incomplete purchase transactions were reported to the grantor. Context - Supplies for the federal program were budgeted, ordered and approved, but due to delays in delivery by the vendor, the orders were not completed by the end of the fiscal year. Checks were prepared in anticipation of completion of the orders and expenditures were recorded and reported to the grantor even though the prepared checks were held by management. Effect - Program expenditures were overstated by $258,750. Cause -The procedures for approval and preparation of payment for supplies were completed even though the supply purchase agreement had not been fulfilled. Recommendation - The District should amend and submit corrected reports to the Grantor. Any expenditure reimbursements received should be refunded to the Grantor. Procedures for payment of supplies should not be completed until the purchase agreement terms have been fulfilled by the vendor. Management's response - All funds have been refunded to state agency and expense reports amended appropriately.
2024-003: Material Weakness in Internal Control / Material Noncompliance – Cash Management (repeat comment) Federal Program: Employment Services Cluster (ALN 17.207/17.801) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The total amount of funds overdrawn as of year-end totaled $173,888. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding.
2024-004: Significant Deficiency in Internal Control / Immaterial Noncompliance – Cash Management (repeat comment) Federal Program: WIOA Cluster (ALN 17.258/17.259/17.278) Criteria: 2 CFR 200.305(b) states, in part: “For Non-Federal entities payment methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity…” 2 CFR 200.305(b)(2)(ii) states, in part: “Non-Federal entities must be authorized to submit requests for advance payments and reimbursements….”. 2 CFR 200.302(b)(6) states, in part: “the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR 200.305 – Federal Payment”. Condition: 1) The Consortium requested funds in advance of when the related disbursements were made, 2) the basis for the advances (requests) were not supported by appropriate documentation, and 3) authorization for requesting funds in advance was not obtained. Context: The total amount of funds overdrawn as of year-end totaled $199,778. Cause: Management oversight. Effect: Funds were requested and received in advance of when the related payments were disbursed without obtaining authorization for advance payments, and without properly documenting the basis for the requested funds. Consequently, the Consortium did not minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity. Recommendation: The Consortium should carefully review their policies and procedures and make the necessary changes to assure that cash draws are based on expenditures already incurred and they are supported by transactions recorded in the books and records of the Consortium. Views of Responsible Officials: We agree with the finding.
Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.425U American Rescue Plan Elementary and Secondary School Emergency Relief Compliance Requirement: B. Allowable Costs Criteria: The District is responsible for the efficient and effective administration of federal awards though the application of sound management practices. 2 CFR Section 200.302 discusses the importance of a financial management system and records that identify adequately the source and applications of funds for federally funded activities. There should be effective control over, and accountability for all funds. Statement of Condition: During our testing of ESSER III grants, it was noted that the District requested more for purchased services than was shown as expended in the District’s accounting records. Statement of Cause: The District does not have the appropriate internal controls in place to review expenditures claimed under each grant within the program. As a result, the District was required to reclassify certain purchased service expenditures from one project code to another to meet a state requirement. However, these expenditures had already been reported on the ESSER III expenditure report. Therefore, due to the reclassification, the District had requested an excess amount of purchased service expenditures than what is shown on the District’s underlying accounting records. Statement of Effect: The grant project code for purchased services had more reimbursement requested for it in the current year than expenditures coded to the project code in the District’s accounting records. The District requested a surplus of reimbursements for related expenditures. This could result in the District being required by the granting agency to return their reimbursements and/or other adverse conditions with the granting agency.Questioned Costs: The District reported $9,430 more in purchased service expenditures than the underlying accounting records support. No other questioned costs noted. Perspective Information: Since there was a one-time adjustment to move purchased services from ESSER III to meet the requirements of another program this appears to be an isolated occurrence. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District implement a process for tracking expenditures related to the grants in a clear and concise manner that is comprehensible to others to ensure expenditures used for reimbursement requests exist and are supported by proper supporting documentation. Proper supporting documentation should be maintained and easily accessible for evidence of the expenditures. We also recommend that another party review all grant reporting and reconciliations before submission to ensure accuracy. Views of Responsible Officials: Each month when reporting our financials, all federal grant accounts will be separated and will be reviewed for accuracy and to ensure proper project codes are correct. Also, expenditures for 1% professional development will be reviewed for accuracy. All payment requests for federal fund grants will be approved prior to submission by the Superintendent. See Corrective Action Plan.
Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.425U American Rescue Plan Elementary and Secondary School Emergency Relief Compliance Requirement: B. Allowable Costs Criteria: The District is responsible for the efficient and effective administration of federal awards though the application of sound management practices. 2 CFR Section 200.302 discusses the importance of a financial management system and records that identify adequately the source and applications of funds for federally funded activities. There should be effective control over, and accountability for all funds. Statement of Condition: During our testing of ESSER III grants, it was noted that the District requested more for purchased services than was shown as expended in the District’s accounting records. Statement of Cause: The District does not have the appropriate internal controls in place to review expenditures claimed under each grant within the program. As a result, the District was required to reclassify certain purchased service expenditures from one project code to another to meet a state requirement. However, these expenditures had already been reported on the ESSER III expenditure report. Therefore, due to the reclassification, the District had requested an excess amount of purchased service expenditures than what is shown on the District’s underlying accounting records. Statement of Effect: The grant project code for purchased services had more reimbursement requested for it in the current year than expenditures coded to the project code in the District’s accounting records. The District requested a surplus of reimbursements for related expenditures. This could result in the District being required by the granting agency to return their reimbursements and/or other adverse conditions with the granting agency.Questioned Costs: The District reported $9,430 more in purchased service expenditures than the underlying accounting records support. No other questioned costs noted. Perspective Information: Since there was a one-time adjustment to move purchased services from ESSER III to meet the requirements of another program this appears to be an isolated occurrence. Identification of Repeat Findings: Not a repeat finding. Recommendation: We recommend that the District implement a process for tracking expenditures related to the grants in a clear and concise manner that is comprehensible to others to ensure expenditures used for reimbursement requests exist and are supported by proper supporting documentation. Proper supporting documentation should be maintained and easily accessible for evidence of the expenditures. We also recommend that another party review all grant reporting and reconciliations before submission to ensure accuracy. Views of Responsible Officials: Each month when reporting our financials, all federal grant accounts will be separated and will be reviewed for accuracy and to ensure proper project codes are correct. Also, expenditures for 1% professional development will be reviewed for accuracy. All payment requests for federal fund grants will be approved prior to submission by the Superintendent. See Corrective Action Plan.
Federal Program: U.S. Department of Commerce-ALN 11.307, Urban Agriculture Mapping and CEDS Integration Criteria: 2 CFR 200.302 requires that non-federal entities must provide for the accurate, current, and complete disclosure of financial results for each Federal award or program in accordance with the reporting requirements set forth in 2 CFR section 200.328 Condition/Context: During our testing, we reviewed the semi-annual and final federal financial report and noted that the semi-annual federal financial report due on October 31, 2023, was submitted on November 13, 2023. Cause: The Board did not have adequate policies and procedures in place to allow all federal financial reporting to occur timely. Effect: The Board is not in compliance with reporting requirements. Questioned Cost: None Recommendation: The Board should enhance it policies and procedures to ensure that all future reports are submitted timely. Views of responsible officials: Management agrees with the finding and the Auditors’ recommendation. See Corrective Action Plan at the end of the report.
Assistance Listing Number, Federal Agency, and Program Name - 84.007, 84.033, 84.063, 84.268; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Federal Award Identification Number and Year - P007A236053, P033A236053, P063P232857, P268K242857; 2023-2024 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - In accordance with 2 CFR 200.302(b)(6), the College must establish written procedures to implement the requirements of 200.305 (federal payment), which outlines cash management requirements. Condition - As the College does not have a written cash management policy related to federal payments/awards, there was a lack of internal controls in place to ensure that this compliance requirement is met. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - The College does not have a written cash management policy related to federal payments/awards. Cause and Effect - As there is no control established to ensure this written policy is in place, the College is not in compliance with 2 CFR 200.302(b)(6). Recommendation - We recommend that the College establish a written cash management policy related to federal payments/awards and that controls are implemented to ensure that it is updated as necessary. Views of Responsible Officials and Planned Corrective Actions - In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards, in order to implement the requirements of 200.305.
Assistance Listing Number, Federal Agency, and Program Name - 84.007, 84.033, 84.063, 84.268; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Federal Award Identification Number and Year - P007A236053, P033A236053, P063P232857, P268K242857; 2023-2024 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - In accordance with 2 CFR 200.302(b)(6), the College must establish written procedures to implement the requirements of 200.305 (federal payment), which outlines cash management requirements. Condition - As the College does not have a written cash management policy related to federal payments/awards, there was a lack of internal controls in place to ensure that this compliance requirement is met. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - The College does not have a written cash management policy related to federal payments/awards. Cause and Effect - As there is no control established to ensure this written policy is in place, the College is not in compliance with 2 CFR 200.302(b)(6). Recommendation - We recommend that the College establish a written cash management policy related to federal payments/awards and that controls are implemented to ensure that it is updated as necessary. Views of Responsible Officials and Planned Corrective Actions - In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards, in order to implement the requirements of 200.305.
Assistance Listing Number, Federal Agency, and Program Name - 84.007, 84.033, 84.063, 84.268; U.S. Department of Education; Federal Supplemental Educational Opportunity Grants, Federal Work-Study Program, Federal Pell Grant Program, Federal Direct Student Loans Federal Award Identification Number and Year - P007A236053, P033A236053, P063P232857, P268K242857; 2023-2024 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - In accordance with 2 CFR 200.302(b)(6), the College must establish written procedures to implement the requirements of 200.305 (federal payment), which outlines cash management requirements. Condition - As the College does not have a written cash management policy related to federal payments/awards, there was a lack of internal controls in place to ensure that this compliance requirement is met. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - The College does not have a written cash management policy related to federal payments/awards. Cause and Effect - As there is no control established to ensure this written policy is in place, the College is not in compliance with 2 CFR 200.302(b)(6). Recommendation - We recommend that the College establish a written cash management policy related to federal payments/awards and that controls are implemented to ensure that it is updated as necessary. Views of Responsible Officials and Planned Corrective Actions - In accordance with 2 CFR 200.302(b)(6), the College will establish a written cash management policy, including written procedures related to federal payments/awards, in order to implement the requirements of 200.305.