Reference Number: 2022-018 Prior Year Finding: 2021-013 Federal Agency: Department of the Treasury State Agency: Department of Finance and Management (Finance) Federal Program: COVID-19 ? Coronavirus Relief Fund COVID-19 ? Emergency Rental Assistance COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.019, 21.023, 21.027 Award Number and Year: SLT0049 (2020), SLT0083 (2020) ERA0029 (2021), ERAE0054 (2021), ERAE1023 (2021) SLFRP4407 (2021), SLFRP4563 (2021), SLFRP4453 (2021-2022) Compliance Requirement: Reporting: Schedule of Expenditures of Federal Awards Type of Finding Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR 200 Section 510(b), the auditee must 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 Section 200.502. The schedule must list individual Federal programs by Federal agency and provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available. The schedule must also include the total amount provided to subrecipients from each Federal program. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Errors were detected in the Schedule of Expenditures of Federal Awards (SEFA) submitted to auditors, including errors in both total expenditures and the amount provided to subrecipients. Context: The following SEFA reporting errors were noted during audit test work: 1. The amount provided to subrecipients under assistance listing 21.023 ? Emergency Rental Assistance was understated by $118.8 million, or 99%. The amount originally reported was $1.3 million but during audit test work it was determined that this amount should have been $120.1 million. 2. The amount provided to subrecipients under assistance listing 21.027 ? Coronavirus State and Local Fiscal Recovery Funds was understated by $77.3 million, or 89%. The amount originally reported was $9.7 million but during audit test work it was determined that this amount should have been $87 million. 3. Total expenditures reported under assistance listing 21.027 ? Coronavirus State and Local Fiscal Recovery Funds were overstated by $6.2 million, or 6%. The amount originally reported was $107.8 million but during audit test work it was determined that this amount should have been $101.6 million. The original reported amount included duplicate expenditures of approximately $6 million. 4. The amount provided to subrecipients under assistance listing 21.019 ? Coronavirus Relief Fund could not be verified. During the prior year?s audit, significant reporting errors were noted in the amount provided to subrecipients. During the current year?s audit, Finance indicated that it had not yet fully implemented the FY 2021 corrective action plan for this issue and, as a result, it was unable to verify the accuracy of the amount reported as provided to subrecipients during FY 2022. Questioned costs: Undetermined. Cause: Individual State agencies/departments prepare their own sections of the SEFA and submit them to Finance which compiles the State?s consolidated report. Procedures and internal controls were not sufficient to ensure that expenditures reported by Finance on the SEFA were accurate and were supported by detail expenditure transactions recorded in the State?s accounting system. On the initial SEFA submitted to auditors, approximately $6 million had been duplicated in total expenditures under 21.027 - Coronavirus State and Local Fiscal Recovery Funds. Payments to subrecipients under Emergency Rental Assistance and Coronavirus State and Local Fiscal Recovery Funds were improperly coded in the State?s accounting system which caused them to be excluded when the SEFA was initially prepared. Further, the prior year?s corrective action plan had not been fully implemented to allow Finance to verify the accuracy of the amount reported as provided to subrecipients under the Coronavirus Relief Fund during FY 2022. Effect: The amount provided to subrecipients was incorrectly reported on the SEFA submitted to auditors which effected testing of subrecipient monitoring for the programs. Recommendation: We recommend that Finance improve its SEFA compilation process to ensure that program expenditures and the amounts provided to subrecipients reported on the State?s SEFA are complete and accurate. We further recommend that Finance work with the State?s agencies and departments to review and enhance procedures and controls to ensure that subrecipient payments are accurately recorded in the State?s accounting system and that expenditure information submitted to Finance for inclusion on the State?s SEFA is accurate and ties to detail expenditure transactions in the State?s accounting system. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-020 Prior Year Finding: No Federal Agency: Department of the Treasury State Agency: Agency of Administration Federal Program: COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: SLFRP4407 (3/1/2021 ? 12/31/2024) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR Section 200.430 (8)(i) Standards for Documentation of Personnel Expenses states that: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Payments to subrecipients were incorrectly recorded in the Agency of Administration?s (Agency?s) accounting system as payments for Unemployment Compensation. Context: Sixty payroll related expenditures were selected for testing, including two payments recorded as Unemployment Compensation. The two unemployment compensation payments were determined to be payments to subrecipients and were not payroll related. Although the payments, totaling $652,937, were incorrectly charged as Unemployment Compensation in the Agency?s accounting system, the costs were allowable subrecipient costs. Cause: The Agency?s procedures and controls were not sufficient to ensure that payments were properly recorded in the accounting system. Data entry errors occurred when the accounts payable transactions were recorded for payment and supervisory review and approval of the transactions did not detect the errors. Effect: Program expenditures were improperly recorded in the Agency?s accounting system. Failure to accurately record payments in the accounting system could lead to reporting errors, including incorrectly reporting payments to subrecipients. Questioned costs: None noted. Although the payments had been miscoded in the accounting system, the payments were allowable subrecipient costs. Recommendation: We recommend the Agency review and enhance procedures and internal controls to ensure that accounts payable transactions are properly recorded. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-021 Prior Year Finding: No Federal Agency: Department of the Treasury State Agency: Agency of Administration Federal Program: COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: SLFRP4407 (3/1/2021 ? 12/31/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1)(iii) Federal Award Identification Number (FAIN); Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Required federal award information was omitted from a subaward issued from the program. Context: The Agency of Administration (Agency) has oversight responsibility for Coronavirus State and Local Fiscal Recovery Funds expenditures and reporting for the State of Vermont (the State). Multiple agencies and departments within the State incur costs and issue subawards charged to the program. Twelve subrecipients were selected for testing and the Department of Public Service (Department) issued a subaward to 1 of the 12 subrecipients. The Federal Award Identification Number (FAIN) was not included on this subaward. Cause: The Department did not establish effective internal controls and procedures over subrecipient monitoring. It was unable to ensure that it provided all required information to its subrecipients upon award issuance. The Agency?s oversight of the program did not detect the error. Effect: Excluding the required federal grant award information at the time of subaward issuance may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports. Questioned costs: Undetermined. Recommendation: We recommend the Agency work with the Department to review and enhance internal controls and procedures to ensure that all required federal award information is included in subawards. We further recommend that the Agency review its oversight procedures and controls to ensure that all State agencies and departments that issue subawards under the program are in compliance with federal requirements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-024 Prior Year Finding: No Federal Agency: U.S. Department of Labor U.S. Department of Education State Agency: Department of Labor Agency of Education Department of Finance and Management Federal Program: Unemployment Insurance Title I Grants to Local Educational Agencies Special Education Cluster Assistance Listing Number: 17.225, 84.010, 84.027 and 84.173 Award Number and Year: UI340892055A50 (10/1/2019 ? 12/31/2022) UI356792155A50 (10/1/2020 ? 12/31/2023) UI372542255A50 (10/1/2021 ? 12/31/2024) S010A200045 (7/1/2020 ? 9/30/2021), S01A210045 (7/1/2021-9/30/2022) H027A200098 (7/1/2020 ? 9/30/2021), H173A200106 (7/1/2020 ? 9/30/2021), H027A210098 (7/1/2021 ? 9/30/2022), H173A210106 (7/1/2021 ? 9/30/2022) Compliance Requirement: Cash Management Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: US Department of the Treasury (Treasury) regulations at 31 CFR Part 205 implement the Cash Management Improvement Act of 1990 (CMIA), as amended (Pub. L. No. 101-453; 31 USC 6501 et seq.). Subpart A of those regulations requires state recipients to enter into Treasury-State Agreements that prescribe specific methods of drawing down federal funds (funding techniques) for federal programs listed in the Assistance Listing (Catalog of federal Domestic Assistance) that meet the funding threshold for a major federal assistance program under the CMIA. Treasury-State Agreements also specify the terms and conditions under which an interest liability would be incurred. Programs not covered by a Treasury-State Agreement are subject to procedures prescribed by Treasury in Subpart B of 31 CFR Part 205 (Subpart B), which at 31 CFR section 205.33(a) include the requirement for a state to minimize the time between the drawdown of federal funds and their disbursement for federal program purposes. Per 2 CFR section 200.514(a)(5), if a State fails to request funds timely as set forth in 2 CFR section 205.29, or otherwise fails to apply a funding technique properly, we may deny any resulting Federal interest liability, notwithstanding any other provision of this section. Annual Reports are submitted electronically by December 31 of each year. The Annual Report includes Federal interest liabilities, State interest liabilities, and State direct cost claims. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Labor (Department) and the Agency of Education (Agency) were not in compliance with the funding techniques included in the State? CMIA Treasury-State Agreement. Federal interest liabilities were improperly calculated on the CMIA Annual Report by the Department of Finance and Management (Finance) for Unemployment Insurance, Title I Grants to Local Educational Agencies, and the Special Education Cluster. Context: The following exceptions were noted when testing compliance with Cash Management: Department of Labor ? The Department was not in compliance with the Prior Month Actual funding technique included in the State?s Treasury-State Agreement. The funding technique requires cash draws to occur on a monthly basis, however, the Department performed multiple cash draws during certain months and other cash draws were performed inconsistently with this funding technique. We noted that the Department did not perform cash draws early, therefore, there is no State interest liability for these exceptions. Agency of Education ? The Agency was not in compliance with the funding techniques included in the State?s Treasury-State Agreement for the Title I Grants to Local Educational Agencies program and for the Special Education Cluster. The funding techniques for these programs required cash draws occur on a bi-weekly basis, or 26 times during the fiscal year. Instead, the Agency performed 11 cash draws on a random basis throughout the year. Department of Finance and Management ? Finance is the responsible State agency for submission of the CMIA Annual Report. The interest liability for the Unemployment Insurance program was calculated incorrectly and since the Agency of Education failed to request funds timely in accordance with the Treasury-State Agreement, a federal interest liability should not have been calculated for the Title I Grants to Local Education Agencies program nor for the Special Education Cluster. The following specific federal interest liability calculation errors were noted on the FY 2022 CMIA Annual Report: o $448 for Unemployment Insurance should have been calculated as $120. o $17,067 for Title I Grants to Local Educational Agencies should have been $0. o $12,706 for the Special Education Cluster should have been $0. Cause: The Agency?s and Department?s procedures were not sufficient to ensure that cash draws were performed timely per the terms of the Treasury-State Agreement. Internal controls did not detect or prevent these errors. Finance prepares the CMA Annual Report using data provided by the Agency and the Department. Finance?s CMIA Annual Report procedures were not sufficient to ensure that it calculated federal interest liabilities for these programs only when the State was entitled to this interest. Internal controls did not detect these errors prior to submission of the CMIA Annual Report. Effect: The Cash Management Improvement Act is intended to minimize the time between the transfer of federal funds to States and the payout of those funds for program purposes. When the Agency and Department do not draw down federal funds timely per the funding techniques included in the Treasury-State Agreement, it causes the State to advance its own funds for federal program purposes, negatively impacting the State?s cash flow. Improperly calculating Federal interest liabilities could potentially allow the State to receive interest payments to which it is not entitled per 2 CFR section 200.514. Questioned costs: Federal interest liabilities improperly calculated and included on the Annual Report: ? $328 for Unemployment Insurance, the difference between the $448 claimed and the allowable $120. ? $17,067 for Title I Grants to Local Educational Agencies ? $12,706 for the Special Education Cluster Recommendation: We recommend the Agency and the Department review and enhance their internal controls and procedures over cash management to ensure that cash draws are performed timely and in accordance with the funding techniques included in the State?s Treasury-State Agreement. We further recommend that Finance enhance its procedures and internal controls to ensure that federal interest liabilities are properly calculated in accordance with 2 CFR section 200.514. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-022 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010 Award Number and Year: S010A200045 (7/1/2020 ? 9/30/2021) S01A210045 (7/1/2021-9/30/2022) Compliance Requirement: Reporting ? Financial Reporting Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR 200.302, each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Recipients of U.S. Department of Education funds use the G5 system to simultaneously request cash reimbursements and report expenditures. The G5 system is in lieu of the SF-270 ? Request for Advance or Reimbursement. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Agency of Education (Agency) was not able to support that the amount it had reported for drawdown in the G5 system was accurate and was supported by expenditures recorded in its accounting system and reported on the Schedule of Expenditures of Federal Awards (SEFA). The total draws by the Agency were less than the total expenditures on the SEFA. Context: The Agency of Education (Agency) was unable to provide supporting documentation for the amount it had reported and drawn down in the G5 system for the program as compared to expenditures it had incurred and reported on the Schedule of Expenditures of Federal Awards (SEFA). Auditors noted the total reported draws were $5.9 million (approximately 16%) less than expenditures reported on the SEFA. The Agency was unable to reconcile this variance. Cause: The Agency?s procedures and internal controls were not sufficient to account for timing differences and ensure that cash draws were complete, accurate and tied to expenditures incurred in its accounting system as reported on the SEFA. Effect: Auditors were unable to verify that cash draws in the G5 system were complete, accurate and supported by documentation recorded in the Agency?s accounting system. Questioned costs: Undetermined. Recommendation: We recommend the Agency review and enhance internal controls and procedures over financial reporting to ensure that cash draws requested in the G5 system are complete, accurate, and that supporting documentation is maintained and agrees with expenditures recorded in its accounting system. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-023 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010 Award Number and Year: S010A200045 (7/1/2020 ? 9/30/2021) S01A210045 (7/1/2021-9/30/2022) Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Agency of Education (Agency) was not in compliance with FSRS reporting requirements. Several subawards and subaward modifications were not reported accurately to FSRS or were not reported timely. Context: Nineteen subawards were selected for testing and many of these subawards were amended several times for a total of sixty transactions tested. Specifically, the following exceptions were noted: ? 9 of 41 subaward amendments reported an incorrect amount to FSRS. When reporting the amendments, the Agency frequently reported the cumulative subaward amount rather than only the current amendment amount which overstated the total amount reported for these subawards. ? 1 of 41 amendments were not reported to FSRS. ? 1 of 19 original subawards were not reported timely to FSRS. ? 1 of 41 subaward amendments were not reported timely to FSRS. SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLE Cause: The Agency?s procedures were not sufficient to ensure that all subawards and subaward amendments were reported timely and accurately to FSRS. Internal controls did not prevent or detect the errors. Effect: Subawards were not reported timely or accurately to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that all required subawards and subaward amendments are reported accurately and timely to FSRS no later than the end of the month following the month of issuance. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-024 Prior Year Finding: No Federal Agency: U.S. Department of Labor U.S. Department of Education State Agency: Department of Labor Agency of Education Department of Finance and Management Federal Program: Unemployment Insurance Title I Grants to Local Educational Agencies Special Education Cluster Assistance Listing Number: 17.225, 84.010, 84.027 and 84.173 Award Number and Year: UI340892055A50 (10/1/2019 ? 12/31/2022) UI356792155A50 (10/1/2020 ? 12/31/2023) UI372542255A50 (10/1/2021 ? 12/31/2024) S010A200045 (7/1/2020 ? 9/30/2021), S01A210045 (7/1/2021-9/30/2022) H027A200098 (7/1/2020 ? 9/30/2021), H173A200106 (7/1/2020 ? 9/30/2021), H027A210098 (7/1/2021 ? 9/30/2022), H173A210106 (7/1/2021 ? 9/30/2022) Compliance Requirement: Cash Management Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: US Department of the Treasury (Treasury) regulations at 31 CFR Part 205 implement the Cash Management Improvement Act of 1990 (CMIA), as amended (Pub. L. No. 101-453; 31 USC 6501 et seq.). Subpart A of those regulations requires state recipients to enter into Treasury-State Agreements that prescribe specific methods of drawing down federal funds (funding techniques) for federal programs listed in the Assistance Listing (Catalog of federal Domestic Assistance) that meet the funding threshold for a major federal assistance program under the CMIA. Treasury-State Agreements also specify the terms and conditions under which an interest liability would be incurred. Programs not covered by a Treasury-State Agreement are subject to procedures prescribed by Treasury in Subpart B of 31 CFR Part 205 (Subpart B), which at 31 CFR section 205.33(a) include the requirement for a state to minimize the time between the drawdown of federal funds and their disbursement for federal program purposes. Per 2 CFR section 200.514(a)(5), if a State fails to request funds timely as set forth in 2 CFR section 205.29, or otherwise fails to apply a funding technique properly, we may deny any resulting Federal interest liability, notwithstanding any other provision of this section. Annual Reports are submitted electronically by December 31 of each year. The Annual Report includes Federal interest liabilities, State interest liabilities, and State direct cost claims. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Labor (Department) and the Agency of Education (Agency) were not in compliance with the funding techniques included in the State? CMIA Treasury-State Agreement. Federal interest liabilities were improperly calculated on the CMIA Annual Report by the Department of Finance and Management (Finance) for Unemployment Insurance, Title I Grants to Local Educational Agencies, and the Special Education Cluster. Context: The following exceptions were noted when testing compliance with Cash Management: Department of Labor ? The Department was not in compliance with the Prior Month Actual funding technique included in the State?s Treasury-State Agreement. The funding technique requires cash draws to occur on a monthly basis, however, the Department performed multiple cash draws during certain months and other cash draws were performed inconsistently with this funding technique. We noted that the Department did not perform cash draws early, therefore, there is no State interest liability for these exceptions. Agency of Education ? The Agency was not in compliance with the funding techniques included in the State?s Treasury-State Agreement for the Title I Grants to Local Educational Agencies program and for the Special Education Cluster. The funding techniques for these programs required cash draws occur on a bi-weekly basis, or 26 times during the fiscal year. Instead, the Agency performed 11 cash draws on a random basis throughout the year. Department of Finance and Management ? Finance is the responsible State agency for submission of the CMIA Annual Report. The interest liability for the Unemployment Insurance program was calculated incorrectly and since the Agency of Education failed to request funds timely in accordance with the Treasury-State Agreement, a federal interest liability should not have been calculated for the Title I Grants to Local Education Agencies program nor for the Special Education Cluster. The following specific federal interest liability calculation errors were noted on the FY 2022 CMIA Annual Report: o $448 for Unemployment Insurance should have been calculated as $120. o $17,067 for Title I Grants to Local Educational Agencies should have been $0. o $12,706 for the Special Education Cluster should have been $0. Cause: The Agency?s and Department?s procedures were not sufficient to ensure that cash draws were performed timely per the terms of the Treasury-State Agreement. Internal controls did not detect or prevent these errors. Finance prepares the CMA Annual Report using data provided by the Agency and the Department. Finance?s CMIA Annual Report procedures were not sufficient to ensure that it calculated federal interest liabilities for these programs only when the State was entitled to this interest. Internal controls did not detect these errors prior to submission of the CMIA Annual Report. Effect: The Cash Management Improvement Act is intended to minimize the time between the transfer of federal funds to States and the payout of those funds for program purposes. When the Agency and Department do not draw down federal funds timely per the funding techniques included in the Treasury-State Agreement, it causes the State to advance its own funds for federal program purposes, negatively impacting the State?s cash flow. Improperly calculating Federal interest liabilities could potentially allow the State to receive interest payments to which it is not entitled per 2 CFR section 200.514. Questioned costs: Federal interest liabilities improperly calculated and included on the Annual Report: ? $328 for Unemployment Insurance, the difference between the $448 claimed and the allowable $120. ? $17,067 for Title I Grants to Local Educational Agencies ? $12,706 for the Special Education Cluster Recommendation: We recommend the Agency and the Department review and enhance their internal controls and procedures over cash management to ensure that cash draws are performed timely and in accordance with the funding techniques included in the State?s Treasury-State Agreement. We further recommend that Finance enhance its procedures and internal controls to ensure that federal interest liabilities are properly calculated in accordance with 2 CFR section 200.514. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-025 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Award Number and Year: H027A200098 (FY2020) H027A200098 - 20A (FY2021) H173A200106 (FY2020) H027A210098 (FY2021) H027A210098 - 21A (FY2022) H173A210106 (FY2021) Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Agency of Education (Agency) was not in compliance with FSRS reporting requirements. Subawards and subaward amendments were not reported to FSRS, were not reported accurately, or were not reported timely. Context: Twenty-six subawards were selected for testing and many of these subawards were amended several times for a total of fifty-two transactions tested. Specifically, the following exceptions were noted: ? 19 of 26 subawards were not reported to FSRS. Of these exceptions, 18 subawards were subsequently reported to FSRS after auditors requested samples for testing. ? 26 of 26 amendments were not reported to FSRS. ? 6 of 19 original subawards were reported incorrectly when reported to FSRS. ? 6 of 19 original subawards were not reported timely to FSRS. SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLE Cause: The Agency?s procedures were not sufficient to ensure that all subawards and subaward amendments were reported timely to FSRS. Internal controls did not prevent or detect the errors. Effect: Subawards were not reported accurately to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that all required subawards and subaward amendments are reported timely to FSRS no later than the end of the month following the month of issuance. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-024 Prior Year Finding: No Federal Agency: U.S. Department of Labor U.S. Department of Education State Agency: Department of Labor Agency of Education Department of Finance and Management Federal Program: Unemployment Insurance Title I Grants to Local Educational Agencies Special Education Cluster Assistance Listing Number: 17.225, 84.010, 84.027 and 84.173 Award Number and Year: UI340892055A50 (10/1/2019 ? 12/31/2022) UI356792155A50 (10/1/2020 ? 12/31/2023) UI372542255A50 (10/1/2021 ? 12/31/2024) S010A200045 (7/1/2020 ? 9/30/2021), S01A210045 (7/1/2021-9/30/2022) H027A200098 (7/1/2020 ? 9/30/2021), H173A200106 (7/1/2020 ? 9/30/2021), H027A210098 (7/1/2021 ? 9/30/2022), H173A210106 (7/1/2021 ? 9/30/2022) Compliance Requirement: Cash Management Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: US Department of the Treasury (Treasury) regulations at 31 CFR Part 205 implement the Cash Management Improvement Act of 1990 (CMIA), as amended (Pub. L. No. 101-453; 31 USC 6501 et seq.). Subpart A of those regulations requires state recipients to enter into Treasury-State Agreements that prescribe specific methods of drawing down federal funds (funding techniques) for federal programs listed in the Assistance Listing (Catalog of federal Domestic Assistance) that meet the funding threshold for a major federal assistance program under the CMIA. Treasury-State Agreements also specify the terms and conditions under which an interest liability would be incurred. Programs not covered by a Treasury-State Agreement are subject to procedures prescribed by Treasury in Subpart B of 31 CFR Part 205 (Subpart B), which at 31 CFR section 205.33(a) include the requirement for a state to minimize the time between the drawdown of federal funds and their disbursement for federal program purposes. Per 2 CFR section 200.514(a)(5), if a State fails to request funds timely as set forth in 2 CFR section 205.29, or otherwise fails to apply a funding technique properly, we may deny any resulting Federal interest liability, notwithstanding any other provision of this section. Annual Reports are submitted electronically by December 31 of each year. The Annual Report includes Federal interest liabilities, State interest liabilities, and State direct cost claims. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Labor (Department) and the Agency of Education (Agency) were not in compliance with the funding techniques included in the State? CMIA Treasury-State Agreement. Federal interest liabilities were improperly calculated on the CMIA Annual Report by the Department of Finance and Management (Finance) for Unemployment Insurance, Title I Grants to Local Educational Agencies, and the Special Education Cluster. Context: The following exceptions were noted when testing compliance with Cash Management: Department of Labor ? The Department was not in compliance with the Prior Month Actual funding technique included in the State?s Treasury-State Agreement. The funding technique requires cash draws to occur on a monthly basis, however, the Department performed multiple cash draws during certain months and other cash draws were performed inconsistently with this funding technique. We noted that the Department did not perform cash draws early, therefore, there is no State interest liability for these exceptions. Agency of Education ? The Agency was not in compliance with the funding techniques included in the State?s Treasury-State Agreement for the Title I Grants to Local Educational Agencies program and for the Special Education Cluster. The funding techniques for these programs required cash draws occur on a bi-weekly basis, or 26 times during the fiscal year. Instead, the Agency performed 11 cash draws on a random basis throughout the year. Department of Finance and Management ? Finance is the responsible State agency for submission of the CMIA Annual Report. The interest liability for the Unemployment Insurance program was calculated incorrectly and since the Agency of Education failed to request funds timely in accordance with the Treasury-State Agreement, a federal interest liability should not have been calculated for the Title I Grants to Local Education Agencies program nor for the Special Education Cluster. The following specific federal interest liability calculation errors were noted on the FY 2022 CMIA Annual Report: o $448 for Unemployment Insurance should have been calculated as $120. o $17,067 for Title I Grants to Local Educational Agencies should have been $0. o $12,706 for the Special Education Cluster should have been $0. Cause: The Agency?s and Department?s procedures were not sufficient to ensure that cash draws were performed timely per the terms of the Treasury-State Agreement. Internal controls did not detect or prevent these errors. Finance prepares the CMA Annual Report using data provided by the Agency and the Department. Finance?s CMIA Annual Report procedures were not sufficient to ensure that it calculated federal interest liabilities for these programs only when the State was entitled to this interest. Internal controls did not detect these errors prior to submission of the CMIA Annual Report. Effect: The Cash Management Improvement Act is intended to minimize the time between the transfer of federal funds to States and the payout of those funds for program purposes. When the Agency and Department do not draw down federal funds timely per the funding techniques included in the Treasury-State Agreement, it causes the State to advance its own funds for federal program purposes, negatively impacting the State?s cash flow. Improperly calculating Federal interest liabilities could potentially allow the State to receive interest payments to which it is not entitled per 2 CFR section 200.514. Questioned costs: Federal interest liabilities improperly calculated and included on the Annual Report: ? $328 for Unemployment Insurance, the difference between the $448 claimed and the allowable $120. ? $17,067 for Title I Grants to Local Educational Agencies ? $12,706 for the Special Education Cluster Recommendation: We recommend the Agency and the Department review and enhance their internal controls and procedures over cash management to ensure that cash draws are performed timely and in accordance with the funding techniques included in the State?s Treasury-State Agreement. We further recommend that Finance enhance its procedures and internal controls to ensure that federal interest liabilities are properly calculated in accordance with 2 CFR section 200.514. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-025 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: Special Education Cluster Assistance Listing Number: 84.027, 84.173 Award Number and Year: H027A200098 (FY2020) H027A200098 - 20A (FY2021) H173A200106 (FY2020) H027A210098 (FY2021) H027A210098 - 21A (FY2022) H173A210106 (FY2021) Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Agency of Education (Agency) was not in compliance with FSRS reporting requirements. Subawards and subaward amendments were not reported to FSRS, were not reported accurately, or were not reported timely. Context: Twenty-six subawards were selected for testing and many of these subawards were amended several times for a total of fifty-two transactions tested. Specifically, the following exceptions were noted: ? 19 of 26 subawards were not reported to FSRS. Of these exceptions, 18 subawards were subsequently reported to FSRS after auditors requested samples for testing. ? 26 of 26 amendments were not reported to FSRS. ? 6 of 19 original subawards were reported incorrectly when reported to FSRS. ? 6 of 19 original subawards were not reported timely to FSRS. SEE SCHEDULE OF FINDINGS AND QUESTIONED COSTS FOR CHART/TABLE Cause: The Agency?s procedures were not sufficient to ensure that all subawards and subaward amendments were reported timely to FSRS. Internal controls did not prevent or detect the errors. Effect: Subawards were not reported accurately to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that all required subawards and subaward amendments are reported timely to FSRS no later than the end of the month following the month of issuance. Views of responsible officials: Management agrees with the finding.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 5 of its 10 colleges did not accurately and/or timely report enrollment-status changes to the National Student Loan Data System (NSLDS) for 12 of 40 students we tested District-wide participating in the Federal Pell Grant (Pell) or Federal Direct Student Loans (Direct Loans) programs. Specifically, the District?s SFA offices did not report: ? Accurate enrollment status and effective date information for 8 students. ? An enrollment-status change within 60 days of the enrollment change for 4 students, which were reported between 10 to 21 days late. Effect?The District?s students may not be asked to repay student financial assistance grants and loans if or when required if the NSLDS does not accurately reflect students? enrollment status. Cause?The District did not monitor its SFA office?s adherence to District-wide policies and procedures to ensure their compliance with Pell and Direct Loans requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the federal programs, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. Thus, when the SFA offices at 5 of the 10 colleges did not follow the District-wide policies and procedures requiring them to review, verify, and correct, as necessary, the student data compiled from the District?s student information system before submitting reports to NSLDS, the District did not identify the errors. Criteria?Federal regulations and District policies and procedures require reporting to the NSLDS all applicable students? enrollment statuses and any enrollment-status changes for the Pell and Direct Loans programs within 60 days of the students? change. Student enrollment status changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves of absence (34 Code of Federal Regulations [CFR] ??685.309[b][2] and 690.83[b][2] and District?s Enrollment Reporting Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures to: a. Report accurate enrollment statuses and changes to the NSLDS within 60 days of the students? change for all students receiving Pell and Direct Loans. b. Review, verify, and correct as necessary the student-enrollment status data they compiled prior to submitting it to NSLDS. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Pell and Direct Loans programs. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-101.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Unknown Condition?Contrary to federal regulations and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 8 of its 10 colleges did not perform the Direct Loans program required monthly reconciliations of its student disbursement records with what was reported on the Common Origination and Disbursement (COD) system. Specifically at 8 of 10 colleges, the SFA office did not complete 10 of the 20 monthly reconciliations and/or did not resolve and investigate discrepancies found on another 3 of the 20 monthly reconciliations we selected. Effect?A student may be disbursed more Direct Loans than is allowable if the COD system does not accurately reflect students? award origination and disbursement data. Cause?The District did not monitor its SFA offices? adherence to District-wide policies and procedures to ensure their compliance with Direct Loans program requirements. Specifically, although the District had communicated District-wide policies to the SFA offices at each of its 10 colleges that are responsible for administering the Direct Loans program, adhering to federal regulations, and following District-wide policies and procedures, it did not monitor the colleges? adherence to them. As a result, the District was unaware that 8 SFA offices did not follow the District-wide policies and procedures for performing timely monthly reconciliations of students? Direct Loans information in the District student records to what they inputted in the COD system and to ensure they updated and corrected any discrepancies found in the reconciliations performed. District management reported that some of the SFA offices claimed to have performed the monthly reconciliations; however, the reconciliations were not documented and retained. Criteria?Federal regulations and District policies and procedures require the colleges? SFA offices, on a monthly basis, to reconcile student records with Direct Loans program disbursement records submitted to and accepted on the COD system (34 CFR ??685.300 [b][5] and [9] and District?s Direct Loan Monthly Reconciliation Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should follow the District-wide policies and procedures that require them to: a. Perform timely monthly reconciliations of their Direct Loans student information maintained on the District?s student system to the COD system and investigate and correct any errors in student data. b. Document and retain reconciliations performed. 2. The District should monitor its SFA offices to ensure their compliance with District policies and procedures for the Direct Loans program. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-103.
Cluster name: Student Financial Assistance Cluster Assistance Listings numbers and names: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work-Study Program 84.038 Federal Perkins Loan Program?Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award year: July 1, 2021 through June 30, 2022 Federal agency: U.S. Department of Education Compliance requirement: Special tests and provisions Questioned costs: Not applicable Condition?Contrary to federal regulation and District policies and procedures, the District?s Student Financial Assistance (SFA) offices at 2 of its 10 colleges did not disburse SFA credit balances directly to students or their parents in a timely manner after applying the awards to the student?s accounts for tuition-related fees. Specifically, for 4 of 50 students we tested, 2 of the SFA offices held the student?s SFA credit balances 1 to 6 days longer than the allowed 14 days after the award was posted to the student?s account. Effect?Students did not always have access to their SFA award monies in a timely manner to help them pay for other nontuition-related fees and expenses, which may have caused them hardships. Cause?The District-wide policies and procedures requiring reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days lacked detailed procedures for SFA credit balances when a manual review is required. These 4 students? accounts required the SFA offices to perform a manual review to release the SFA credit balances rather than the credit balances being processed automatically through the system, which is the typical method according to District management. Criteria?Federal regulation and District policies and procedures require the District?s SFA offices to apply each student?s SFA awards to the student?s account to satisfy tuition-related fees owed to the District. Any excess SFA awards result in a credit balance on the student?s account. When this occurs, the District?s SFA offices are required to disburse any remaining SFA award monies directly to the student or parent as soon as possible, but no later than 14 days after the award has been posted to the student?s account. If the credit balance occurred before the first day of class of that payment period, then disbursement to the student or parent would be required no later than 14 days after the first day of class of the payment period (34 CFR ?686.164[h] and District?s Title IV Credit Balance Process). Also, federal regulation requires the District?s establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations 1. The District?s SFA offices should complete reviews of students? accounts to disburse SFA credit balances to students or their parents within the required 14 days. 2. The District should update its District-wide policies and procedures to include detailed procedures to ensure all manual credit balances are processed within the required 14 days and monitor its SFA offices to ensure their compliance with these District-wide policies and procedures for disbursing the credit balances to students or their parents. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Assistance Listing number and name: 84.031 Higher Education?Institutional Aid Award numbers and years: P031S150032, October 1, 2015 through September 30, 2021 P031S150098, October 1, 2015 through September 30, 2021 P031S160090, October 1, 2016 through September 30, 2023 P031S190167, October 1, 2019 through September 30, 2024 P031S200096, October 1, 2020 through September 30, 2025 P031S200281, October 1, 2020 through September 30, 2025 P031C210057, October 1, 2021 through September 30, 2026 P031C210077, October 1, 2021 through September 30, 2026 Federal agency: U.S. Department of Education Compliance requirement: Reporting and special tests and provisions Questioned costs: Unknown Condition?The District did not act in accordance with federal regulations for its 10 endowments established from 2005 through 2021 by 6 of its 10 colleges.1 These endowments were created with Higher Education?Institutional Aid (HEIA) program monies held by its Foundation that ranged in value from $64,129 to $359,019, with a combined fiscal year-end balance of $1.6 million including interest earned. Specifically, we found that the District did not submit 3 of its endowments? annual reports for federal fiscal year October 1, 2020 through September 30, 2021, to the U.S. Department of Education (ED), as required, to certify that these endowment monies were spent in accordance with federal regulations. In addition, for all 4 endowment reports tested, we found the reports did not agree to the Foundation?s records and that no one at the responsible college had reviewed or approved them for accuracy prior to submitting them to ED. Further, in reviewing the reports, we found that the District Office and colleges were not aware of each endowment?s investment performance with the Foundation or whether the Foundation?s investment policies met the federal regulations. Effect?The District?s failure to submit accurate endowment reports and the lack of monitoring over the Foundation?s administration of its endowments increases the risk that ED could terminate the endowments and require the District to reimburse ED for the original endowment balances, including interest earned, if the District spent more of the endowments? income than allowed by federal regulations. We did not note any instances of the District spending more than allowed based on the 4 reports tested. Cause?The District Office indicated that all the endowment reports submitted to ED were prepared by the Foundation and were not reviewed for accuracy before the College certified and submitted them to ED. For the 3 reports not submitted, District management reported that they were unable to submit the reports electronically and have not been successful in their attempts to receive assistance from ED to submit the late reports. In addition, the District?s colleges separately contracted with the District?s Foundation to administer the endowments, which included investing the endowment balances and disbursing a portion of the interest earned for allowable program activities. However, the District did not ensure that the Foundation was aware of the program?s requirements or have a plan for ensuring compliance. Further, the District Office did not have written policies and procedures to monitor the Foundation?s contract and the District?s endowments held with the Foundation, and had not designated anyone to centrally monitor these endowments. Criteria?Federal regulation permits the District to designate its Foundation to invest and raise monies for the program?s endowments; however, the District is ultimately responsible for ensuring its endowments are administered in accordance with all federal regulations (34 CFR ?628.3). The District is required to monitor the Foundation?s compliance with all federal requirements, including those that specify the investment types and risks allowed, require the endowments? corpuses remain unspent during the grant award period, ensure it spends no more than 50 percent of the endowments? earnings in accordance with the endowments? purpose, and verify that endowment income is properly calculated and invested in a savings account or low-risk securities (34 CFR ??628.43 through .46). Additionally, federal regulation and the District colleges? federal program award terms require the District to submit annual reports for each of its endowments certifying that the endowments comply with federal regulations (34 CFR ?628.47[f]). Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District Office should develop and implement written policies and procedures to: 1. Update its endowment contracts with the Foundation to include provisions that: a. Require the Foundation to provide information on each endowment to the District for inclusion in the annual reports. b. Specify the types of investments and investment risks allowed by federal regulations. c. Require the Foundation to provide periodic reporting to the District Office and applicable colleges about the endowments? investment performance, income calculations, disbursements made from endowment interest, and compliance with federal regulations. 2. Designate an employee to centrally monitor the endowments with the Foundation to ensure the endowments are properly accounted for, spent, and invested in accordance with federal regulations. 3. Ensure that the District?s required endowment annual reports are certified and submitted to ED by the District only after the reports have been reviewed and approved for accuracy and agreement to the Foundation?s records by the responsible District employee. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2021-104. 1 The endowment grant award numbers and years are as follows: P031010003, October 1, 2001 through September 30, 2006; P031S080044, October 1 2007 through September 30, 2012; P031S080118, October 1, 2008 through September 30, 2014; P031S090050, October 1, 2009 through September 30, 2014; P031A110194, October 1, 2011 through September 30, 2016 (2 endowments); P031A110200, October 1, 2011 through September 30, 2017; P031S150085, October 1, 2015 through September 30, 2020; P031S150098, October 1, 2015 through September 30, 2021; and P031S160090, October 1, 2016 through September 30, 2023.
Cluster Name: TRIO Cluster Assistance Listings numbers and names: 84.042 TRIO?Student Support Services 84.047 TRIO?Upward Bound Award numbers and years: P042A2000873, September 1, 2020 through August 31, 2025; P042A201342, September 1, 2020 through August 31, 2025; P042A200859 September 1, 2020 through August 31, 2025; P047A171009 September 1, 2017 through August 31, 2022; P047A1710820 September 1, 2017 through August 31, 2022 Federal agency: U.S. Department of Education Compliance requirement: Eligibility Questioned costs: $14,678 Condition?The District?s 2 TRIO offices that administer the TRIO?Upward Bound program (program) did not review and approve their eligibility determinations for 21 of 24 students? eligibility we tested for the District?s program and, contrary to federal regulation, 1 of the 2 District?s TRIO offices did not maintain records for stipends awarded to students. Specifically, we found that: ? GateWay Community College did not independently review and approve its eligibility determinations for 12 of 12 students? eligibility we tested before making awards for services, contrary to its policies and procedures. Further, South Mountain Community College did not independently review and approve its eligibility determinations for 9 of 12 students? eligibility we tested before making awards for services. We did not identify any ineligible students in the samples we tested. ? GateWay Community College did not maintain records and other documentation demonstrating how students earned stipends and how its TRIO office calculated $14,678 of the total $15,653 of stipends it awarded to students for fall and spring semesters, contrary to its policies and procedures to maintain records for stipends awarded to students. Effect?Without performing independent reviews and approvals of eligibility determinations that the colleges? policies and procedures require, Gateway and South Mountain Community Colleges have an increased risk of ineligible students participating in the program. In addition, due to Gateway Community College?s lack of stipend records, there is an increased risk that $14,678 of the stipends it awarded to students may not have been earned or correctly calculated or may have exceeded the limits permitted by the program?s requirements. Cause?GateWay Community College experienced turnover in the key personnel administering the program, and the new personnel were not aware of the college?s policies and procedures requiring review and approval of eligibility determinations. They were also unable to locate records supporting the stipends it awarded to students. Also, South Mountain Community College?s policies and procedures did not address review and approval of student records and did not incorporate this process when the College transitioned to an electronic eligibility process during the COVID-19 pandemic. Criteria?GateWay Community College?s written policies and procedures require its TRIO office to perform an independent review and approval of their student eligibility determinations before awarding students program services (GateWay Community College?TRIO Upward Bound Eligibility Determination and Intake Process). In addition, federal regulation requires each District TRIO office to maintain attendance records and other documentation demonstrating the student?s satisfactory participation in program activities to earn the stipend and records supporting the District TRIO offices? calculation of the stipends in accordance with program requirements, which limit the amount of stipends to students depending on whether the stipend is earned during the academic year or summer session (34 CFR 645.42). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should: 1. Require all the District?s TRIO offices that administer the TRIO?Upward Bound program to follow or update policies and procedures to: a. Require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. b. Maintain records and other documentation demonstrating how students have earned and how the District?s TRIO offices have calculated the stipends awarded to students for participating in the program?s activities. 2. Train all employees responsible for administering the TRIO programs at the District?s TRIO offices on the District-wide policies and procedures. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Cluster Name: TRIO Cluster Assistance Listings numbers and names: 84.042 TRIO?Student Support Services 84.047 TRIO?Upward Bound Award numbers and years: P042A2000873, September 1, 2020 through August 31, 2025; P042A201342, September 1, 2020 through August 31, 2025; P042A200859 September 1, 2020 through August 31, 2025; P047A171009 September 1, 2017 through August 31, 2022; P047A1710820 September 1, 2017 through August 31, 2022 Federal agency: U.S. Department of Education Compliance requirement: Eligibility Questioned costs: $14,678 Condition?The District?s 2 TRIO offices that administer the TRIO?Upward Bound program (program) did not review and approve their eligibility determinations for 21 of 24 students? eligibility we tested for the District?s program and, contrary to federal regulation, 1 of the 2 District?s TRIO offices did not maintain records for stipends awarded to students. Specifically, we found that: ? GateWay Community College did not independently review and approve its eligibility determinations for 12 of 12 students? eligibility we tested before making awards for services, contrary to its policies and procedures. Further, South Mountain Community College did not independently review and approve its eligibility determinations for 9 of 12 students? eligibility we tested before making awards for services. We did not identify any ineligible students in the samples we tested. ? GateWay Community College did not maintain records and other documentation demonstrating how students earned stipends and how its TRIO office calculated $14,678 of the total $15,653 of stipends it awarded to students for fall and spring semesters, contrary to its policies and procedures to maintain records for stipends awarded to students. Effect?Without performing independent reviews and approvals of eligibility determinations that the colleges? policies and procedures require, Gateway and South Mountain Community Colleges have an increased risk of ineligible students participating in the program. In addition, due to Gateway Community College?s lack of stipend records, there is an increased risk that $14,678 of the stipends it awarded to students may not have been earned or correctly calculated or may have exceeded the limits permitted by the program?s requirements. Cause?GateWay Community College experienced turnover in the key personnel administering the program, and the new personnel were not aware of the college?s policies and procedures requiring review and approval of eligibility determinations. They were also unable to locate records supporting the stipends it awarded to students. Also, South Mountain Community College?s policies and procedures did not address review and approval of student records and did not incorporate this process when the College transitioned to an electronic eligibility process during the COVID-19 pandemic. Criteria?GateWay Community College?s written policies and procedures require its TRIO office to perform an independent review and approval of their student eligibility determinations before awarding students program services (GateWay Community College?TRIO Upward Bound Eligibility Determination and Intake Process). In addition, federal regulation requires each District TRIO office to maintain attendance records and other documentation demonstrating the student?s satisfactory participation in program activities to earn the stipend and records supporting the District TRIO offices? calculation of the stipends in accordance with program requirements, which limit the amount of stipends to students depending on whether the stipend is earned during the academic year or summer session (34 CFR 645.42). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should: 1. Require all the District?s TRIO offices that administer the TRIO?Upward Bound program to follow or update policies and procedures to: a. Require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. b. Maintain records and other documentation demonstrating how students have earned and how the District?s TRIO offices have calculated the stipends awarded to students for participating in the program?s activities. 2. Train all employees responsible for administering the TRIO programs at the District?s TRIO offices on the District-wide policies and procedures. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Finding No. 2022-005 ? Internal Controls over Compliance of Federal Awards (Partial Repeat 2021-007) Federal Program Name: Twenty-First Century Community Learning Centers, Education Stabilization Funds (Elementary and Secondary School Emergency Relief (ESSER II) Fund Project Number: N/A CFDA Number: 84.287C, 84.425D, 84.425X Passed Through: Illinois State Board of Education Federal Agency: U.S. Department of Education Criteria/Specific Requirement: 2 CFR 200.303 ? Internal Controls, requires the District to establish and maintain effective internal controls over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 2, subpart E ? Cost Principles, among other guidance states that costs charged to federal programs must be necessary and reasonable for the performance of the federal program. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit and the expenditure and/or allocation must be adequately documented. Condition: 1) During testing of compliance over disbursements, we noted the following: a. One (1) transaction that did not have indication of review or approval on the supporting documentation b. One (1) instance where the District paid sales tax in the amount of $135.71 c. One (1) instance where the District paid for a software subscription for the period 07/01/23-06/30/24, which is outside of the program period 2) During testing of compliance over reporting, we noted the following: a. One (1) instance where the expenditure report was filed five (5) days late b. Two (2) instances where the District appeared to complete the expenditure report submitted to Illinois State Board of Education from the budget versus the actual general ledger detail Questioned Costs: 1)a) $1,500.00 b) $135.71 c) $ 26,968.00 Context: 1) 3 exceptions of 47 disbursements tested The expenditure detailed in item 1(c) of the condition was completed prior to the release of the June 30, 2021 audit, when the District was made aware of the issue which was reported as finding 2021-007 in that audit. No additional expenditures outside of the grant period were noted after the date the June 30, 2021 audit was released. 2) 3 exceptions of 6 grants tested Effect: 1) The lack of proper internal controls of disbursements could result in the District paying for unallowable expenditures from the grant funds. 2) Noncompliance with grant agreement. Cause: Lack of proper oversight by District personnel. Recommendation: We recommend that the District appoint an individual that is knowledgeable, or provide the appropriate training, of the federal compliance requirements set forth in the Code of Federal Regulation to oversee the District?s federal programs to ensure the District is in compliance with all applicable federal compliance requirements. Management?s Response: The District is working to implement that the auditor?s recommendation.
Finding No. 2022-005 ? Internal Controls over Compliance of Federal Awards (Partial Repeat 2021-007) Federal Program Name: Twenty-First Century Community Learning Centers, Education Stabilization Funds (Elementary and Secondary School Emergency Relief (ESSER II) Fund Project Number: N/A CFDA Number: 84.287C, 84.425D, 84.425X Passed Through: Illinois State Board of Education Federal Agency: U.S. Department of Education Criteria/Specific Requirement: 2 CFR 200.303 ? Internal Controls, requires the District to establish and maintain effective internal controls over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 2, subpart E ? Cost Principles, among other guidance states that costs charged to federal programs must be necessary and reasonable for the performance of the federal program. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit and the expenditure and/or allocation must be adequately documented. Condition: 1) During testing of compliance over disbursements, we noted the following: a. One (1) transaction that did not have indication of review or approval on the supporting documentation b. One (1) instance where the District paid sales tax in the amount of $135.71 c. One (1) instance where the District paid for a software subscription for the period 07/01/23-06/30/24, which is outside of the program period 2) During testing of compliance over reporting, we noted the following: a. One (1) instance where the expenditure report was filed five (5) days late b. Two (2) instances where the District appeared to complete the expenditure report submitted to Illinois State Board of Education from the budget versus the actual general ledger detail Questioned Costs: 1)a) $1,500.00 b) $135.71 c) $ 26,968.00 Context: 1) 3 exceptions of 47 disbursements tested The expenditure detailed in item 1(c) of the condition was completed prior to the release of the June 30, 2021 audit, when the District was made aware of the issue which was reported as finding 2021-007 in that audit. No additional expenditures outside of the grant period were noted after the date the June 30, 2021 audit was released. 2) 3 exceptions of 6 grants tested Effect: 1) The lack of proper internal controls of disbursements could result in the District paying for unallowable expenditures from the grant funds. 2) Noncompliance with grant agreement. Cause: Lack of proper oversight by District personnel. Recommendation: We recommend that the District appoint an individual that is knowledgeable, or provide the appropriate training, of the federal compliance requirements set forth in the Code of Federal Regulation to oversee the District?s federal programs to ensure the District is in compliance with all applicable federal compliance requirements. Management?s Response: The District is working to implement that the auditor?s recommendation.
Finding No. 2022-005 ? Internal Controls over Compliance of Federal Awards (Partial Repeat 2021-007) Federal Program Name: Twenty-First Century Community Learning Centers, Education Stabilization Funds (Elementary and Secondary School Emergency Relief (ESSER II) Fund Project Number: N/A CFDA Number: 84.287C, 84.425D, 84.425X Passed Through: Illinois State Board of Education Federal Agency: U.S. Department of Education Criteria/Specific Requirement: 2 CFR 200.303 ? Internal Controls, requires the District to establish and maintain effective internal controls over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 2, subpart E ? Cost Principles, among other guidance states that costs charged to federal programs must be necessary and reasonable for the performance of the federal program. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit and the expenditure and/or allocation must be adequately documented. Condition: 1) During testing of compliance over disbursements, we noted the following: a. One (1) transaction that did not have indication of review or approval on the supporting documentation b. One (1) instance where the District paid sales tax in the amount of $135.71 c. One (1) instance where the District paid for a software subscription for the period 07/01/23-06/30/24, which is outside of the program period 2) During testing of compliance over reporting, we noted the following: a. One (1) instance where the expenditure report was filed five (5) days late b. Two (2) instances where the District appeared to complete the expenditure report submitted to Illinois State Board of Education from the budget versus the actual general ledger detail Questioned Costs: 1)a) $1,500.00 b) $135.71 c) $ 26,968.00 Context: 1) 3 exceptions of 47 disbursements tested The expenditure detailed in item 1(c) of the condition was completed prior to the release of the June 30, 2021 audit, when the District was made aware of the issue which was reported as finding 2021-007 in that audit. No additional expenditures outside of the grant period were noted after the date the June 30, 2021 audit was released. 2) 3 exceptions of 6 grants tested Effect: 1) The lack of proper internal controls of disbursements could result in the District paying for unallowable expenditures from the grant funds. 2) Noncompliance with grant agreement. Cause: Lack of proper oversight by District personnel. Recommendation: We recommend that the District appoint an individual that is knowledgeable, or provide the appropriate training, of the federal compliance requirements set forth in the Code of Federal Regulation to oversee the District?s federal programs to ensure the District is in compliance with all applicable federal compliance requirements. Management?s Response: The District is working to implement that the auditor?s recommendation.
Finding No. 2022-005 ? Internal Controls over Compliance of Federal Awards (Partial Repeat 2021-007) Federal Program Name: Twenty-First Century Community Learning Centers, Education Stabilization Funds (Elementary and Secondary School Emergency Relief (ESSER II) Fund Project Number: N/A CFDA Number: 84.287C, 84.425D, 84.425X Passed Through: Illinois State Board of Education Federal Agency: U.S. Department of Education Criteria/Specific Requirement: 2 CFR 200.303 ? Internal Controls, requires the District to establish and maintain effective internal controls over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 2, subpart E ? Cost Principles, among other guidance states that costs charged to federal programs must be necessary and reasonable for the performance of the federal program. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit and the expenditure and/or allocation must be adequately documented. Condition: 1) During testing of compliance over disbursements, we noted the following: a. One (1) transaction that did not have indication of review or approval on the supporting documentation b. One (1) instance where the District paid sales tax in the amount of $135.71 c. One (1) instance where the District paid for a software subscription for the period 07/01/23-06/30/24, which is outside of the program period 2) During testing of compliance over reporting, we noted the following: a. One (1) instance where the expenditure report was filed five (5) days late b. Two (2) instances where the District appeared to complete the expenditure report submitted to Illinois State Board of Education from the budget versus the actual general ledger detail Questioned Costs: 1)a) $1,500.00 b) $135.71 c) $ 26,968.00 Context: 1) 3 exceptions of 47 disbursements tested The expenditure detailed in item 1(c) of the condition was completed prior to the release of the June 30, 2021 audit, when the District was made aware of the issue which was reported as finding 2021-007 in that audit. No additional expenditures outside of the grant period were noted after the date the June 30, 2021 audit was released. 2) 3 exceptions of 6 grants tested Effect: 1) The lack of proper internal controls of disbursements could result in the District paying for unallowable expenditures from the grant funds. 2) Noncompliance with grant agreement. Cause: Lack of proper oversight by District personnel. Recommendation: We recommend that the District appoint an individual that is knowledgeable, or provide the appropriate training, of the federal compliance requirements set forth in the Code of Federal Regulation to oversee the District?s federal programs to ensure the District is in compliance with all applicable federal compliance requirements. Management?s Response: The District is working to implement that the auditor?s recommendation.
Finding No. 2022-005 ? Internal Controls over Compliance of Federal Awards (Partial Repeat 2021-007) Federal Program Name: Twenty-First Century Community Learning Centers, Education Stabilization Funds (Elementary and Secondary School Emergency Relief (ESSER II) Fund Project Number: N/A CFDA Number: 84.287C, 84.425D, 84.425X Passed Through: Illinois State Board of Education Federal Agency: U.S. Department of Education Criteria/Specific Requirement: 2 CFR 200.303 ? Internal Controls, requires the District to establish and maintain effective internal controls over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 2, subpart E ? Cost Principles, among other guidance states that costs charged to federal programs must be necessary and reasonable for the performance of the federal program. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit and the expenditure and/or allocation must be adequately documented. Condition: 1) During testing of compliance over disbursements, we noted the following: a. One (1) transaction that did not have indication of review or approval on the supporting documentation b. One (1) instance where the District paid sales tax in the amount of $135.71 c. One (1) instance where the District paid for a software subscription for the period 07/01/23-06/30/24, which is outside of the program period 2) During testing of compliance over reporting, we noted the following: a. One (1) instance where the expenditure report was filed five (5) days late b. Two (2) instances where the District appeared to complete the expenditure report submitted to Illinois State Board of Education from the budget versus the actual general ledger detail Questioned Costs: 1)a) $1,500.00 b) $135.71 c) $ 26,968.00 Context: 1) 3 exceptions of 47 disbursements tested The expenditure detailed in item 1(c) of the condition was completed prior to the release of the June 30, 2021 audit, when the District was made aware of the issue which was reported as finding 2021-007 in that audit. No additional expenditures outside of the grant period were noted after the date the June 30, 2021 audit was released. 2) 3 exceptions of 6 grants tested Effect: 1) The lack of proper internal controls of disbursements could result in the District paying for unallowable expenditures from the grant funds. 2) Noncompliance with grant agreement. Cause: Lack of proper oversight by District personnel. Recommendation: We recommend that the District appoint an individual that is knowledgeable, or provide the appropriate training, of the federal compliance requirements set forth in the Code of Federal Regulation to oversee the District?s federal programs to ensure the District is in compliance with all applicable federal compliance requirements. Management?s Response: The District is working to implement that the auditor?s recommendation.
Finding No. 2022-005 ? Internal Controls over Compliance of Federal Awards (Partial Repeat 2021-007) Federal Program Name: Twenty-First Century Community Learning Centers, Education Stabilization Funds (Elementary and Secondary School Emergency Relief (ESSER II) Fund Project Number: N/A CFDA Number: 84.287C, 84.425D, 84.425X Passed Through: Illinois State Board of Education Federal Agency: U.S. Department of Education Criteria/Specific Requirement: 2 CFR 200.303 ? Internal Controls, requires the District to establish and maintain effective internal controls over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 2, subpart E ? Cost Principles, among other guidance states that costs charged to federal programs must be necessary and reasonable for the performance of the federal program. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit and the expenditure and/or allocation must be adequately documented. Condition: 1) During testing of compliance over disbursements, we noted the following: a. One (1) transaction that did not have indication of review or approval on the supporting documentation b. One (1) instance where the District paid sales tax in the amount of $135.71 c. One (1) instance where the District paid for a software subscription for the period 07/01/23-06/30/24, which is outside of the program period 2) During testing of compliance over reporting, we noted the following: a. One (1) instance where the expenditure report was filed five (5) days late b. Two (2) instances where the District appeared to complete the expenditure report submitted to Illinois State Board of Education from the budget versus the actual general ledger detail Questioned Costs: 1)a) $1,500.00 b) $135.71 c) $ 26,968.00 Context: 1) 3 exceptions of 47 disbursements tested The expenditure detailed in item 1(c) of the condition was completed prior to the release of the June 30, 2021 audit, when the District was made aware of the issue which was reported as finding 2021-007 in that audit. No additional expenditures outside of the grant period were noted after the date the June 30, 2021 audit was released. 2) 3 exceptions of 6 grants tested Effect: 1) The lack of proper internal controls of disbursements could result in the District paying for unallowable expenditures from the grant funds. 2) Noncompliance with grant agreement. Cause: Lack of proper oversight by District personnel. Recommendation: We recommend that the District appoint an individual that is knowledgeable, or provide the appropriate training, of the federal compliance requirements set forth in the Code of Federal Regulation to oversee the District?s federal programs to ensure the District is in compliance with all applicable federal compliance requirements. Management?s Response: The District is working to implement that the auditor?s recommendation.
Finding No. 2022-005 ? Internal Controls over Compliance of Federal Awards (Partial Repeat 2021-007) Federal Program Name: Twenty-First Century Community Learning Centers, Education Stabilization Funds (Elementary and Secondary School Emergency Relief (ESSER II) Fund Project Number: N/A CFDA Number: 84.287C, 84.425D, 84.425X Passed Through: Illinois State Board of Education Federal Agency: U.S. Department of Education Criteria/Specific Requirement: 2 CFR 200.303 ? Internal Controls, requires the District to establish and maintain effective internal controls over the federal awards that provide reasonable assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 2, subpart E ? Cost Principles, among other guidance states that costs charged to federal programs must be necessary and reasonable for the performance of the federal program. If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit and the expenditure and/or allocation must be adequately documented. Condition: 1) During testing of compliance over disbursements, we noted the following: a. One (1) transaction that did not have indication of review or approval on the supporting documentation b. One (1) instance where the District paid sales tax in the amount of $135.71 c. One (1) instance where the District paid for a software subscription for the period 07/01/23-06/30/24, which is outside of the program period 2) During testing of compliance over reporting, we noted the following: a. One (1) instance where the expenditure report was filed five (5) days late b. Two (2) instances where the District appeared to complete the expenditure report submitted to Illinois State Board of Education from the budget versus the actual general ledger detail Questioned Costs: 1)a) $1,500.00 b) $135.71 c) $ 26,968.00 Context: 1) 3 exceptions of 47 disbursements tested The expenditure detailed in item 1(c) of the condition was completed prior to the release of the June 30, 2021 audit, when the District was made aware of the issue which was reported as finding 2021-007 in that audit. No additional expenditures outside of the grant period were noted after the date the June 30, 2021 audit was released. 2) 3 exceptions of 6 grants tested Effect: 1) The lack of proper internal controls of disbursements could result in the District paying for unallowable expenditures from the grant funds. 2) Noncompliance with grant agreement. Cause: Lack of proper oversight by District personnel. Recommendation: We recommend that the District appoint an individual that is knowledgeable, or provide the appropriate training, of the federal compliance requirements set forth in the Code of Federal Regulation to oversee the District?s federal programs to ensure the District is in compliance with all applicable federal compliance requirements. Management?s Response: The District is working to implement that the auditor?s recommendation.
2022-010 ? Equipment and Real Property Management ? Material Weakness Federal Program Information Funding Agency: Department of Defense, National Science Foundation, Department of Education, Department of Health and Human Services ? National Institute of Health Federal Award Agreement Number: Not Applicable Award Year: Fiscal year 2022 Title: Research and Development Cluster Assistance Listing Number: 12.598, 47.050, 47.076, 84.031, and 93.859 Pass-through Agency: Not Applicable, Direct Program Pass-through Identification Number: Not Applicable, Direct Program Condition - The College was not able to provide an equipment listing tracking items purchased with federal funding nor did the College conduct a physical inventory.Criteria - Per 2 CFR 200.313(d)(2), a physical inventory of program property must be taken and the results reconciled with the property records at least once every 2 years and per 2 CFR 200.303(a) states that 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. Questioned Costs - Not applicable. Effect - The College could dispose of or lose federally funded equipment without following federal guidelines. Cause - The College does not have policies and procedures to ensure that equipment purchases with federal funds is maintained and tracked and that the College performing a physical inventory at a minimum of every two years.
2022?007 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education Federal Program Title: Student Financial Aid Cluster CFDA Number: 84.425 Higher Education Emergency Relief Fund Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: Non-compliance with reporting requirements under HEERF Questioned costs: None Context: ? We were not able to obtain documentation to demonstrate that the quarterly reporting for institutional and student expenditures was done in a timely manner. ? We were not able to obtain documentation of approval for the quarterly student reporting, the quarterly institutional reporting, or the annual report. ? We noted instances where the information in the reports did not agree to supporting documentation. This applied to one of the three quarterly institutional reports and the annual report. ? The three quarterly student reports omitted information on the number of students wo were eligible to receive funding. Cause: University?s policies and procedures did not ensure compliance. Effect: Non-compliance with the reporting requirements. Repeat Finding: Yes, prior year finding 2021-004. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Views of responsible officials: See Corrective Action Plan prepared by the University.
Identification of the Federal Programs: Assistance Listing Number: 20.507 Assistance Listing Title: Federal Transit Cluster Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Identification Number: CA-2017-149-00; CA-90-Z085-00; CA-90-Y974-00; CA -2019-033-00; CA -90-Y900-00; CA-2020-177-00; CA-2021-169-01; CA-2022-041-00; CA-2021-075-00 Assistance Listing Number: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: N/A Federal Award Identification Number: 1505-0271 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR ?200.303 Internal Controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under ?200.302 Financial Management, (b) (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Under ?200.430(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity. Condition: During the audit, we could not verify if the Bus Operators? and Police Officers? timecards were properly approved by their supervisors. The timecard reports were uploaded from the time entry system to the payroll module by the supervisors; however, there were no records on who reviewed the timecard reports or completed the upload of the timecard reports to the payroll module. Additionally, 8 out of 25 Police Officers? personnel action forms could not be located. Cause: The Bus Line and Police Departments did not have formal policies and procedures over the timecard approval process. There was also ineffective monitoring of human resources processes, including the maintenance of personnel action forms. Effect or Potential Effect: Without approved personnel action forms and review or approval of time cards, inaccurate payroll expenditures could be charged to the federal programs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City adopt formal policies and procedures on the documentation of timecard approval process for the Bus Line and Police Departments. The City should also implement regular monitoring and conduct periodic reviews of personnel files to verify the presence and completeness of personnel action forms. Views of Responsible Officials: Management has reviewed the payroll/timecard approval process. The City utilizes New World Systems eSuites for employees to enter their bi-weekly hours, and for employees and supervisors to approve timesheets. However, not all employees can utilize eSuites, as the requirements for timekeeping for Bus Operators, Police and Fire personnel is such that separate timekeeping systems must be maintained and utilized. To that end, staff has initiated a process whereby ? for employees not using eSuites ? manual review and approval of bi-weekly hours is conducted by supervisors in the appropriate department (i.e., Transit, Police, etc.). Management believes this additional review and approval level will provide the necessary back-up to improve internal control over timecards/timekeeping.
Identification of the Federal Programs: Assistance Listing Number: 20.507 Assistance Listing Title: Federal Transit Cluster Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Identification Number: CA-2017-149-00; CA-90-Z085-00; CA-90-Y974-00; CA -2019-033-00; CA -90-Y900-00; CA-2020-177-00; CA-2021-169-01; CA-2022-041-00; CA-2021-075-00 Assistance Listing Number: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: N/A Federal Award Identification Number: 1505-0271 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR ?200.303 Internal Controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under ?200.302 Financial Management, (b) (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Under ?200.430(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity. Condition: During the audit, we could not verify if the Bus Operators? and Police Officers? timecards were properly approved by their supervisors. The timecard reports were uploaded from the time entry system to the payroll module by the supervisors; however, there were no records on who reviewed the timecard reports or completed the upload of the timecard reports to the payroll module. Additionally, 8 out of 25 Police Officers? personnel action forms could not be located. Cause: The Bus Line and Police Departments did not have formal policies and procedures over the timecard approval process. There was also ineffective monitoring of human resources processes, including the maintenance of personnel action forms. Effect or Potential Effect: Without approved personnel action forms and review or approval of time cards, inaccurate payroll expenditures could be charged to the federal programs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City adopt formal policies and procedures on the documentation of timecard approval process for the Bus Line and Police Departments. The City should also implement regular monitoring and conduct periodic reviews of personnel files to verify the presence and completeness of personnel action forms. Views of Responsible Officials: Management has reviewed the payroll/timecard approval process. The City utilizes New World Systems eSuites for employees to enter their bi-weekly hours, and for employees and supervisors to approve timesheets. However, not all employees can utilize eSuites, as the requirements for timekeeping for Bus Operators, Police and Fire personnel is such that separate timekeeping systems must be maintained and utilized. To that end, staff has initiated a process whereby ? for employees not using eSuites ? manual review and approval of bi-weekly hours is conducted by supervisors in the appropriate department (i.e., Transit, Police, etc.). Management believes this additional review and approval level will provide the necessary back-up to improve internal control over timecards/timekeeping.
Identification of the Federal Programs: Assistance Listing Number: 20.507 Assistance Listing Title: Federal Transit Cluster Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Identification Number: CA-2017-149-00; CA-90-Z085-00; CA-90-Y974-00; CA -2019-033-00; CA -90-Y900-00; CA-2020-177-00; CA-2021-169-01; CA-2022-041-00; CA-2021-075-00 Assistance Listing Number: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: N/A Federal Award Identification Number: 1505-0271 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR ?200.303 Internal Controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under ?200.302 Financial Management, (b) (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Under ?200.430(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity. Condition: During the audit, we could not verify if the Bus Operators? and Police Officers? timecards were properly approved by their supervisors. The timecard reports were uploaded from the time entry system to the payroll module by the supervisors; however, there were no records on who reviewed the timecard reports or completed the upload of the timecard reports to the payroll module. Additionally, 8 out of 25 Police Officers? personnel action forms could not be located. Cause: The Bus Line and Police Departments did not have formal policies and procedures over the timecard approval process. There was also ineffective monitoring of human resources processes, including the maintenance of personnel action forms. Effect or Potential Effect: Without approved personnel action forms and review or approval of time cards, inaccurate payroll expenditures could be charged to the federal programs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City adopt formal policies and procedures on the documentation of timecard approval process for the Bus Line and Police Departments. The City should also implement regular monitoring and conduct periodic reviews of personnel files to verify the presence and completeness of personnel action forms. Views of Responsible Officials: Management has reviewed the payroll/timecard approval process. The City utilizes New World Systems eSuites for employees to enter their bi-weekly hours, and for employees and supervisors to approve timesheets. However, not all employees can utilize eSuites, as the requirements for timekeeping for Bus Operators, Police and Fire personnel is such that separate timekeeping systems must be maintained and utilized. To that end, staff has initiated a process whereby ? for employees not using eSuites ? manual review and approval of bi-weekly hours is conducted by supervisors in the appropriate department (i.e., Transit, Police, etc.). Management believes this additional review and approval level will provide the necessary back-up to improve internal control over timecards/timekeeping.
Identification of the Federal Programs: Assistance Listing Number: 20.507 Assistance Listing Title: Federal Transit Cluster Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Identification Number: CA-2017-149-00; CA-90-Z085-00; CA-90-Y974-00; CA -2019-033-00; CA -90-Y900-00; CA-2020-177-00; CA-2021-169-01; CA-2022-041-00; CA-2021-075-00 Assistance Listing Number: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: N/A Federal Award Identification Number: 1505-0271 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR ?200.303 Internal Controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under ?200.302 Financial Management, (b) (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Under ?200.430(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity. Condition: During the audit, we could not verify if the Bus Operators? and Police Officers? timecards were properly approved by their supervisors. The timecard reports were uploaded from the time entry system to the payroll module by the supervisors; however, there were no records on who reviewed the timecard reports or completed the upload of the timecard reports to the payroll module. Additionally, 8 out of 25 Police Officers? personnel action forms could not be located. Cause: The Bus Line and Police Departments did not have formal policies and procedures over the timecard approval process. There was also ineffective monitoring of human resources processes, including the maintenance of personnel action forms. Effect or Potential Effect: Without approved personnel action forms and review or approval of time cards, inaccurate payroll expenditures could be charged to the federal programs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City adopt formal policies and procedures on the documentation of timecard approval process for the Bus Line and Police Departments. The City should also implement regular monitoring and conduct periodic reviews of personnel files to verify the presence and completeness of personnel action forms. Views of Responsible Officials: Management has reviewed the payroll/timecard approval process. The City utilizes New World Systems eSuites for employees to enter their bi-weekly hours, and for employees and supervisors to approve timesheets. However, not all employees can utilize eSuites, as the requirements for timekeeping for Bus Operators, Police and Fire personnel is such that separate timekeeping systems must be maintained and utilized. To that end, staff has initiated a process whereby ? for employees not using eSuites ? manual review and approval of bi-weekly hours is conducted by supervisors in the appropriate department (i.e., Transit, Police, etc.). Management believes this additional review and approval level will provide the necessary back-up to improve internal control over timecards/timekeeping.
Identification of the Federal Programs: Assistance Listing Number: 20.507 Assistance Listing Title: Federal Transit Cluster Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Identification Number: CA-2017-149-00; CA-90-Z085-00; CA-90-Y974-00; CA -2019-033-00; CA -90-Y900-00; CA-2020-177-00; CA-2021-169-01; CA-2022-041-00; CA-2021-075-00 Assistance Listing Number: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: N/A Federal Award Identification Number: 1505-0271 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR ?200.303 Internal Controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under ?200.302 Financial Management, (b) (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Under ?200.430(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity. Condition: During the audit, we could not verify if the Bus Operators? and Police Officers? timecards were properly approved by their supervisors. The timecard reports were uploaded from the time entry system to the payroll module by the supervisors; however, there were no records on who reviewed the timecard reports or completed the upload of the timecard reports to the payroll module. Additionally, 8 out of 25 Police Officers? personnel action forms could not be located. Cause: The Bus Line and Police Departments did not have formal policies and procedures over the timecard approval process. There was also ineffective monitoring of human resources processes, including the maintenance of personnel action forms. Effect or Potential Effect: Without approved personnel action forms and review or approval of time cards, inaccurate payroll expenditures could be charged to the federal programs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City adopt formal policies and procedures on the documentation of timecard approval process for the Bus Line and Police Departments. The City should also implement regular monitoring and conduct periodic reviews of personnel files to verify the presence and completeness of personnel action forms. Views of Responsible Officials: Management has reviewed the payroll/timecard approval process. The City utilizes New World Systems eSuites for employees to enter their bi-weekly hours, and for employees and supervisors to approve timesheets. However, not all employees can utilize eSuites, as the requirements for timekeeping for Bus Operators, Police and Fire personnel is such that separate timekeeping systems must be maintained and utilized. To that end, staff has initiated a process whereby ? for employees not using eSuites ? manual review and approval of bi-weekly hours is conducted by supervisors in the appropriate department (i.e., Transit, Police, etc.). Management believes this additional review and approval level will provide the necessary back-up to improve internal control over timecards/timekeeping.
Identification of the Federal Programs: Assistance Listing Number: 20.507 Assistance Listing Title: Federal Transit Cluster Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Identification Number: CA-2017-149-00; CA-90-Z085-00; CA-90-Y974-00; CA -2019-033-00; CA -90-Y900-00; CA-2020-177-00; CA-2021-169-01; CA-2022-041-00; CA-2021-075-00 Assistance Listing Number: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: N/A Federal Award Identification Number: 1505-0271 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR ?200.303 Internal Controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under ?200.302 Financial Management, (b) (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Under ?200.430(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity. Condition: During the audit, we could not verify if the Bus Operators? and Police Officers? timecards were properly approved by their supervisors. The timecard reports were uploaded from the time entry system to the payroll module by the supervisors; however, there were no records on who reviewed the timecard reports or completed the upload of the timecard reports to the payroll module. Additionally, 8 out of 25 Police Officers? personnel action forms could not be located. Cause: The Bus Line and Police Departments did not have formal policies and procedures over the timecard approval process. There was also ineffective monitoring of human resources processes, including the maintenance of personnel action forms. Effect or Potential Effect: Without approved personnel action forms and review or approval of time cards, inaccurate payroll expenditures could be charged to the federal programs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City adopt formal policies and procedures on the documentation of timecard approval process for the Bus Line and Police Departments. The City should also implement regular monitoring and conduct periodic reviews of personnel files to verify the presence and completeness of personnel action forms. Views of Responsible Officials: Management has reviewed the payroll/timecard approval process. The City utilizes New World Systems eSuites for employees to enter their bi-weekly hours, and for employees and supervisors to approve timesheets. However, not all employees can utilize eSuites, as the requirements for timekeeping for Bus Operators, Police and Fire personnel is such that separate timekeeping systems must be maintained and utilized. To that end, staff has initiated a process whereby ? for employees not using eSuites ? manual review and approval of bi-weekly hours is conducted by supervisors in the appropriate department (i.e., Transit, Police, etc.). Management believes this additional review and approval level will provide the necessary back-up to improve internal control over timecards/timekeeping.
Identification of the Federal Programs: Assistance Listing Number: 20.507 Assistance Listing Title: Federal Transit Cluster Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Identification Number: CA-2017-149-00; CA-90-Z085-00; CA-90-Y974-00; CA -2019-033-00; CA -90-Y900-00; CA-2020-177-00; CA-2021-169-01; CA-2022-041-00; CA-2021-075-00 Assistance Listing Number: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: N/A Federal Award Identification Number: 1505-0271 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR ?200.303 Internal Controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under ?200.302 Financial Management, (b) (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Under ?200.430(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity. Condition: During the audit, we could not verify if the Bus Operators? and Police Officers? timecards were properly approved by their supervisors. The timecard reports were uploaded from the time entry system to the payroll module by the supervisors; however, there were no records on who reviewed the timecard reports or completed the upload of the timecard reports to the payroll module. Additionally, 8 out of 25 Police Officers? personnel action forms could not be located. Cause: The Bus Line and Police Departments did not have formal policies and procedures over the timecard approval process. There was also ineffective monitoring of human resources processes, including the maintenance of personnel action forms. Effect or Potential Effect: Without approved personnel action forms and review or approval of time cards, inaccurate payroll expenditures could be charged to the federal programs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City adopt formal policies and procedures on the documentation of timecard approval process for the Bus Line and Police Departments. The City should also implement regular monitoring and conduct periodic reviews of personnel files to verify the presence and completeness of personnel action forms. Views of Responsible Officials: Management has reviewed the payroll/timecard approval process. The City utilizes New World Systems eSuites for employees to enter their bi-weekly hours, and for employees and supervisors to approve timesheets. However, not all employees can utilize eSuites, as the requirements for timekeeping for Bus Operators, Police and Fire personnel is such that separate timekeeping systems must be maintained and utilized. To that end, staff has initiated a process whereby ? for employees not using eSuites ? manual review and approval of bi-weekly hours is conducted by supervisors in the appropriate department (i.e., Transit, Police, etc.). Management believes this additional review and approval level will provide the necessary back-up to improve internal control over timecards/timekeeping.
Identification of the Federal Programs: Assistance Listing Number: 20.507 Assistance Listing Title: Federal Transit Cluster Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Identification Number: CA-2017-149-00; CA-90-Z085-00; CA-90-Y974-00; CA -2019-033-00; CA -90-Y900-00; CA-2020-177-00; CA-2021-169-01; CA-2022-041-00; CA-2021-075-00 Assistance Listing Number: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: N/A Federal Award Identification Number: 1505-0271 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR ?200.303 Internal Controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under ?200.302 Financial Management, (b) (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Under ?200.430(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity. Condition: During the audit, we could not verify if the Bus Operators? and Police Officers? timecards were properly approved by their supervisors. The timecard reports were uploaded from the time entry system to the payroll module by the supervisors; however, there were no records on who reviewed the timecard reports or completed the upload of the timecard reports to the payroll module. Additionally, 8 out of 25 Police Officers? personnel action forms could not be located. Cause: The Bus Line and Police Departments did not have formal policies and procedures over the timecard approval process. There was also ineffective monitoring of human resources processes, including the maintenance of personnel action forms. Effect or Potential Effect: Without approved personnel action forms and review or approval of time cards, inaccurate payroll expenditures could be charged to the federal programs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City adopt formal policies and procedures on the documentation of timecard approval process for the Bus Line and Police Departments. The City should also implement regular monitoring and conduct periodic reviews of personnel files to verify the presence and completeness of personnel action forms. Views of Responsible Officials: Management has reviewed the payroll/timecard approval process. The City utilizes New World Systems eSuites for employees to enter their bi-weekly hours, and for employees and supervisors to approve timesheets. However, not all employees can utilize eSuites, as the requirements for timekeeping for Bus Operators, Police and Fire personnel is such that separate timekeeping systems must be maintained and utilized. To that end, staff has initiated a process whereby ? for employees not using eSuites ? manual review and approval of bi-weekly hours is conducted by supervisors in the appropriate department (i.e., Transit, Police, etc.). Management believes this additional review and approval level will provide the necessary back-up to improve internal control over timecards/timekeeping.
Identification of the Federal Programs: Assistance Listing Number: 20.507 Assistance Listing Title: Federal Transit Cluster Federal Agency: U.S. Department of Transportation Pass-Through Entity: N/A Federal Award Identification Number: CA-2017-149-00; CA-90-Z085-00; CA-90-Y974-00; CA -2019-033-00; CA -90-Y900-00; CA-2020-177-00; CA-2021-169-01; CA-2022-041-00; CA-2021-075-00 Assistance Listing Number: 21.027 Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Entity: N/A Federal Award Identification Number: 1505-0271 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): In accordance with 2 CFR ?200.303 Internal Controls, the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under ?200.302 Financial Management, (b) (3) Records that identify adequately the source and application of funds for federally-funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Under ?200.430(i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity. Condition: During the audit, we could not verify if the Bus Operators? and Police Officers? timecards were properly approved by their supervisors. The timecard reports were uploaded from the time entry system to the payroll module by the supervisors; however, there were no records on who reviewed the timecard reports or completed the upload of the timecard reports to the payroll module. Additionally, 8 out of 25 Police Officers? personnel action forms could not be located. Cause: The Bus Line and Police Departments did not have formal policies and procedures over the timecard approval process. There was also ineffective monitoring of human resources processes, including the maintenance of personnel action forms. Effect or Potential Effect: Without approved personnel action forms and review or approval of time cards, inaccurate payroll expenditures could be charged to the federal programs. Questioned Costs: None noted. Context: See condition above for the context of the finding. Identification as a Repeat Finding, If Applicable: Not applicable. Recommendation: We recommended the City adopt formal policies and procedures on the documentation of timecard approval process for the Bus Line and Police Departments. The City should also implement regular monitoring and conduct periodic reviews of personnel files to verify the presence and completeness of personnel action forms. Views of Responsible Officials: Management has reviewed the payroll/timecard approval process. The City utilizes New World Systems eSuites for employees to enter their bi-weekly hours, and for employees and supervisors to approve timesheets. However, not all employees can utilize eSuites, as the requirements for timekeeping for Bus Operators, Police and Fire personnel is such that separate timekeeping systems must be maintained and utilized. To that end, staff has initiated a process whereby ? for employees not using eSuites ? manual review and approval of bi-weekly hours is conducted by supervisors in the appropriate department (i.e., Transit, Police, etc.). Management believes this additional review and approval level will provide the necessary back-up to improve internal control over timecards/timekeeping.
FEDERAL COMMUNICATIONS COMMISSION EMERGENCY CONNECTIVITY FUND PROGRAM CFDA #: 32.009 DIRECT FUNDING REFERENCE: 2022 -001 CONDITION The asset inventory listing did not identify the person receiving the devices that were purchased with the Program?s funds. Additionally, the asset inventory listing of the devices only listed 738 of the 800 devices purchased with Program funds. CRITERIA 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. EFFECT Purchases made with grant program funds may not meet the allowability criteria, resulting in funds needing to be returned to the granting agency. CAUSE The School was not aware of all of the compliance requirements. RECOMMENDATION AND BENEFIT Procedures should be improved to ensure that appropriate personnel are knowledgeable of, and have a good understanding of, each grant?s compliance requirements. New grants provide additional risk and therefore, more than one person should review the grant requirements. This will help ensure that the School is aware of the requirements for each grant received, which should help ensure compliance with the various grant requirements.
Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) - Significant Deficiency All Federal Programs Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, we noted there is no documentation of the review process of the SEFA to ensure accuracy and completeness. Cause: The entity does not have an appropriate process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner.
Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) - Significant Deficiency All Federal Programs Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, we noted there is no documentation of the review process of the SEFA to ensure accuracy and completeness. Cause: The entity does not have an appropriate process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner.
Review And Approval Of The Schedule Of Expenditures Of Federal Awards (SEFA) - Significant Deficiency All Federal Programs Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School should have a process in place to perform a review of the SEFA, to include evidence of the resolution of variances, as well as a process to document the overall review and approval to ensure proper presentation, completeness, and accuracy of the SEFA. Condition: During the course of the audit, we noted there is no documentation of the review process of the SEFA to ensure accuracy and completeness. Cause: The entity does not have an appropriate process in place to review the SEFA, to include retaining evidence of the resolution of variances, as well as documentation of the overall review and approval. Effect: Potential misstatement could occur if expenditure amounts are not accurately presented on the SEFA. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Yes. Recommendation: The School should develop a consistent process to review the SEFA. Issues identified during the course of the review should be investigated and resolved in a timely manner.