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.
Approval Of Expense Reimbursement Submittals ? Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.425/84.425C/84.425D/84.425U - Elementary And Secondary School Emergency Relief Fund (ESSER) 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 has an internal control in place that expense reimbursement submittals on federal grants be approved by School management prior to their submission to the state for reimbursement. Condition: During the course of the audit, the engagement team identified multiple instances where the support showing School management?s approval of the expense reimbursement submittal for federal grants was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before expense reimbursement requests were submitted. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by School management for accuracy and completeness. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all expense reimbursement submittals.
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.
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.
Approval Of Expense Reimbursement Submittals ? Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.425/84.425C/84.425D/84.425U - Elementary And Secondary School Emergency Relief Fund (ESSER) 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 has an internal control in place that expense reimbursement submittals on federal grants be approved by School management prior to their submission to the state for reimbursement. Condition: During the course of the audit, the engagement team identified multiple instances where the support showing School management?s approval of the expense reimbursement submittal for federal grants was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before expense reimbursement requests were submitted. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by School management for accuracy and completeness. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all expense reimbursement submittals.
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.
Approval Of Expense Reimbursement Submittals ? Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.425/84.425C/84.425D/84.425U - Elementary And Secondary School Emergency Relief Fund (ESSER) 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 has an internal control in place that expense reimbursement submittals on federal grants be approved by School management prior to their submission to the state for reimbursement. Condition: During the course of the audit, the engagement team identified multiple instances where the support showing School management?s approval of the expense reimbursement submittal for federal grants was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before expense reimbursement requests were submitted. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by School management for accuracy and completeness. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all expense reimbursement submittals.
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.
Approval Of Expense Reimbursement Submittals ? Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.425/84.425C/84.425D/84.425U - Elementary And Secondary School Emergency Relief Fund (ESSER) 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 has an internal control in place that expense reimbursement submittals on federal grants be approved by School management prior to their submission to the state for reimbursement. Condition: During the course of the audit, the engagement team identified multiple instances where the support showing School management?s approval of the expense reimbursement submittal for federal grants was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before expense reimbursement requests were submitted. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by School management for accuracy and completeness. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all expense reimbursement submittals.
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.
Approval Of Expense Reimbursement Submittals ? Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.425/84.425C/84.425D/84.425U - Elementary And Secondary School Emergency Relief Fund (ESSER) 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 has an internal control in place that expense reimbursement submittals on federal grants be approved by School management prior to their submission to the state for reimbursement. Condition: During the course of the audit, the engagement team identified multiple instances where the support showing School management?s approval of the expense reimbursement submittal for federal grants was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before expense reimbursement requests were submitted. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by School management for accuracy and completeness. Questioned Costs: Not applicable. Context: Not applicable. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation for all expense reimbursement submittals.
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.
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.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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). Condition During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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). Condition During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-002 Federal Program Title: National Bioterrorism Hospital Preparedness Program Federal Assistance Listing Number: 93.889 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 U3REP190604-03-00; Fiscal Year 2021-22 Name of Department: Department of Health Services Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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). Condition During our audit of the Department of Health Services? (DHS) compliance with the reporting requirement for the National Bioterrorism Hospital Preparedness Program, we noted that DHS was not able to demonstrate it submitted the required FFAFTA reports timely for seventeen (17) of its subawards. Furthermore, DHS did not submit a FFAFTA report for one (1) of its subaward. See Schedule of Findings and Questioned Costs for chart/table. Cause DHS was unable to access the submittal history for the reports because the previous employee responsible for FFATA reporting was no longer a DHS employee. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Eighteen (18) subawards requiring the submission of a FFATA report were selected from a total population of seventy eight (78) subawards. For seventeen (17) subawards, we were unable to determine whether the reports were submitted timely; and one (1) subaward was not reported. The sample was not a statistically valid sample. Recommendation We recommend that the DHS strengthen its report submission process to ensure all reports are submitted by the defined due date and retain documentation evidencing submission of the report.
Reference Number: 2022-010 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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). Condition During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the HIV Prevention Activities Health Department Based program, we noted that DPH did not submit a FFATA report for nine (9) of its subawards. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Nine (9) subawards requiring the submission of a FFATA report were selected for testing from a total population of fifty two (52) subrecipient awards, and reports were not submitted for all nine (9) subawards selected. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date, and retain documentation evidencing submission of the report.
Reference Number: 2022-010 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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). Condition During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the HIV Prevention Activities Health Department Based program, we noted that DPH did not submit a FFATA report for nine (9) of its subawards. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Nine (9) subawards requiring the submission of a FFATA report were selected for testing from a total population of fifty two (52) subrecipient awards, and reports were not submitted for all nine (9) subawards selected. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date, and retain documentation evidencing submission of the report.
Reference Number: 2022-008 Federal Program Title: Sexually Transmitted Diseases (STD) Prevention and Control Grants Federal Assistance Listing Number: 93.977 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NH25PS005130-03-03; Year 2021 6 NH25PS005130-04-01; Year 2022 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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). Condition During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the Sexually Transmitted Diseases (STD) Prevention and Control Grants program, we noted that DPH did not submit a FFATA report for one (1) of its subawards. See Schedule of Findings and Questioned Costs for chart/table. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context One (1) subaward requiring the submission of a FFATA report was selected from a total population of two (2) subrecipient awards, and a report was not submitted for that one (1) subaward. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date and retain documentation evidencing submission of the report.
Reference Number: 2022-008 Federal Program Title: Sexually Transmitted Diseases (STD) Prevention and Control Grants Federal Assistance Listing Number: 93.977 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NH25PS005130-03-03; Year 2021 6 NH25PS005130-04-01; Year 2022 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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). Condition During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the Sexually Transmitted Diseases (STD) Prevention and Control Grants program, we noted that DPH did not submit a FFATA report for one (1) of its subawards. See Schedule of Findings and Questioned Costs for chart/table. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context One (1) subaward requiring the submission of a FFATA report was selected from a total population of two (2) subrecipient awards, and a report was not submitted for that one (1) subaward. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date and retain documentation evidencing submission of the report.
2022-001 COVID-19 Education Stabilization Fund ? Assistance Listing No. 84.425; Grant period ? Year ended June 30, 2022 Criteria and Condition: 2 CFR 200.303 requires the non-federal entity to establish and maintain effective internal controls over compliance with Federal statues, regulations, and the terms and conditions of the Federal award including proper tracking of grant expenditures or compliance. The District?s processes over approving allowable costs could be enhanced as costs were charged to the Education Stabilization Fund grant that were not allowable in accordance with the Kentucky Department of Education?s ESSER I, ESSER II, and ARP ESSER Funding Matrix. Cause: Certain internal controls were not in place to prevent unallowable costs from being charged to the grant. Effect: The cost of the assistance may be disallowed. Questioned Costs: $20,552 Context: A sample of 60 checks totaling $558,621 were selected for audit from a population of 520 checks totaling $1,108,883 that were transferred to the Education Stabilization Fund grant via a journal entry. The test found six checks that were not in compliance with questioned costs totaling $20,552. Our sample was a statistically valid sample. Recommendation: The District should verify the allowability of costs prior to being transferred or charged to the grant. Views of Responsible Officials and Planned Corrective Actions: The District concurs with the finding, see corrective action plan.
2022-001 COVID-19 Education Stabilization Fund ? Assistance Listing No. 84.425; Grant period ? Year ended June 30, 2022 Criteria and Condition: 2 CFR 200.303 requires the non-federal entity to establish and maintain effective internal controls over compliance with Federal statues, regulations, and the terms and conditions of the Federal award including proper tracking of grant expenditures or compliance. The District?s processes over approving allowable costs could be enhanced as costs were charged to the Education Stabilization Fund grant that were not allowable in accordance with the Kentucky Department of Education?s ESSER I, ESSER II, and ARP ESSER Funding Matrix. Cause: Certain internal controls were not in place to prevent unallowable costs from being charged to the grant. Effect: The cost of the assistance may be disallowed. Questioned Costs: $20,552 Context: A sample of 60 checks totaling $558,621 were selected for audit from a population of 520 checks totaling $1,108,883 that were transferred to the Education Stabilization Fund grant via a journal entry. The test found six checks that were not in compliance with questioned costs totaling $20,552. Our sample was a statistically valid sample. Recommendation: The District should verify the allowability of costs prior to being transferred or charged to the grant. Views of Responsible Officials and Planned Corrective Actions: The District concurs with the finding, see corrective action plan.
FA 2022-001 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $195,559 Description: The School District made cash drawdowns in excess of the immediate cash needs of the Elementary and Secondary School Emergency Relief Fund program. Background Information: The School District may request Elementary and Secondary School Emergency Relief (ESSER) Fund program funds from the Georgia Department of Education (GaDOE) once per month. GaDOE requires the School District to submit DE-0147 ? Requests for Reimbursement of Monthly Cash Disbursements through the Grants Accounting Online Reporting System to receive program funds. When a DE-0147 request is submitted and approved, the ESSER program funds are typically disbursed to the School District through an electronic payment process the next week. The School District submitted DE-0147 requests to receive a total of $4,407,030 in ESSER program funds from GaDOE for the fiscal year under review. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance Section 200.305(b) state that for ?For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from? the pass-through entity and the disbursement by the non-Federal entity.? In addition, the Uniform Guidance Section 200.302(b)(6) requires that the entity develop written cash management procedures. Condition: Upon testing ESSER program revenues and expenditures recorded on the financial statements, potential deficiencies in the cash management process were identified. Therefore, a review of all cash drawdowns and disbursements related to the ESSER program was performed to determine if any excessive drawdowns were made during the year under review. Excessive drawdown requests totaling $195,559 were identified. Cause: Drawdowns in excess of expenditures were caused by an error made by School District personnel when requesting ESSER funds. These excessive drawdowns were primarily the result of the School District requesting reimbursement for expenditures that had not been incurred by year end. Effect: The School District was not in compliance with the Uniform Guidance and GaDOE guidance. In addition, the School District could potentially accrue an interest liability that would be owed back to the federal government. Furthermore, when the School District cannot meet the requirement to minimize the time elapsing between the transfer of funds and disbursement of those funds, provisions included in the Uniform Guidance allow GaDOE to change the method by which the School District is transferred funds and delay the School District?s receipt of these funds. This may include requirement by GaDOE to submit invoices prior to being reimbursed for ESSER program expenditures. Recommendation: The School District should establish procedures to accurately forecast the cash needs of the ESSER program and minimize the time elapsing between the transfer of funds from GaDOE and the disbursement of such funds by the School District. In addition, these procedures should be documented in writing in accordance with the Uniform Guidance Section 200.302(b)(6). Furthermore, management should develop and implement a monitoring process to ensure that these procedures are followed. Views of Responsible Officials: We concur with this finding.
FA 2022-001 Improve Controls over Cash Management Compliance Requirement: Cash Management Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $195,559 Description: The School District made cash drawdowns in excess of the immediate cash needs of the Elementary and Secondary School Emergency Relief Fund program. Background Information: The School District may request Elementary and Secondary School Emergency Relief (ESSER) Fund program funds from the Georgia Department of Education (GaDOE) once per month. GaDOE requires the School District to submit DE-0147 ? Requests for Reimbursement of Monthly Cash Disbursements through the Grants Accounting Online Reporting System to receive program funds. When a DE-0147 request is submitted and approved, the ESSER program funds are typically disbursed to the School District through an electronic payment process the next week. The School District submitted DE-0147 requests to receive a total of $4,407,030 in ESSER program funds from GaDOE for the fiscal year under review. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance Section 200.305(b) state that for ?For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from? the pass-through entity and the disbursement by the non-Federal entity.? In addition, the Uniform Guidance Section 200.302(b)(6) requires that the entity develop written cash management procedures. Condition: Upon testing ESSER program revenues and expenditures recorded on the financial statements, potential deficiencies in the cash management process were identified. Therefore, a review of all cash drawdowns and disbursements related to the ESSER program was performed to determine if any excessive drawdowns were made during the year under review. Excessive drawdown requests totaling $195,559 were identified. Cause: Drawdowns in excess of expenditures were caused by an error made by School District personnel when requesting ESSER funds. These excessive drawdowns were primarily the result of the School District requesting reimbursement for expenditures that had not been incurred by year end. Effect: The School District was not in compliance with the Uniform Guidance and GaDOE guidance. In addition, the School District could potentially accrue an interest liability that would be owed back to the federal government. Furthermore, when the School District cannot meet the requirement to minimize the time elapsing between the transfer of funds and disbursement of those funds, provisions included in the Uniform Guidance allow GaDOE to change the method by which the School District is transferred funds and delay the School District?s receipt of these funds. This may include requirement by GaDOE to submit invoices prior to being reimbursed for ESSER program expenditures. Recommendation: The School District should establish procedures to accurately forecast the cash needs of the ESSER program and minimize the time elapsing between the transfer of funds from GaDOE and the disbursement of such funds by the School District. In addition, these procedures should be documented in writing in accordance with the Uniform Guidance Section 200.302(b)(6). Furthermore, management should develop and implement a monitoring process to ensure that these procedures are followed. Views of Responsible Officials: We concur with this finding.
Assistance Listings numbers and names 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Aid Portion 84.425F COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Institutional Portion 84.425L COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Minority Serving Institutions (MSIs) Award numbers and years P425E200055, April 20, 2020 through June 30, 2023; P425F201359, May 6, 2020 through June 30, 2023; P245L200182, June 2, 2020 through June 30, 2023 Federal agency U.S. Department of Education Compliance requirement Reporting Questioned costs Not applicable Condition?Contrary to federal regulations and guidance, the District?s Grant Services Department and the Financial Aid and Scholarships Department failed to make complete and accurate quarterly reports publicly available on the District?s website for the program?s student, institutional, and MSIs portions (Assistance Listings numbers 84.425E, 84.245F, and 84.425L, respectively). Specifically, the District did not complete and publicly post reports for the quarters ended March 31, 2022 and June 30, 2022, until January 2023, which was after we notified the District that the reports were missing from its website. In addition, for 2 of 3 reports we tested, the District overreported and underreported program expenditures by $1,558,400 and $9,806, respectively, for the student and MSIs portions (Assistance Listings numbers 84.425E and 84.425L). Further, the District did not retain documentation supporting the amounts it reported. Effect?The District?s failure to make complete and accurate quarterly reports available on the District?s website resulted in a lack of transparency to the public for how it spent federal COVID-19 Educational Stabilization Fund monies for program purposes. Cause?The personnel who had been administering the program left the District, and the new employees responsible for administering the program reported that they were not aware of the federal reporting requirement to post the reports on the District?s website and, therefore, did not properly coordinate the reporting requirements between the Grant Services Department and Financial Aid and Scholarships Department as both were responsible for the report. Further, the District did not follow the Grant Services Department?s written policies and procedures to track federal program reporting requirements to ensure that all reports were completed accurately and on time. Finally, an independent review was not performed for each section of the reports to ensure that they were complete and accurate. Criteria?Federal agency guidance requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the Education Stabilization Fund no later than 10 days after the calendar quarter.1 In addition, the federal Uniform Guidance requires the District to maintain program financial and accounting records and supporting documents relating to federal programs for at least 3 years from the date of the final expenditure report (2 Code of Federal Regulations [CFR] ?200.334). Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should: 1. Follow the Grant Services Department?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. b. Require a review and approval of all reports by an independent employee to ensure they are accurate. c. Retain all documentation supporting program expenditures reported in the federal grant reports. 2. Coordinate completing federal reports when more than 1 department is responsible for contributing information to the report to ensure the report is submitted on time. 3. Complete and publish on the District?s website the required quarterly grant reports for the Education Stabilization Fund no later than 10 days after the end of the quarter. 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. 1 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3) (OMB Paperwork Reduction Act Form Control Number 1840-0849). Retrieved 1/13/2023 from https://www2.ed.gov/about/offices/list/ope/arpheerfiiiqaurterlyreporting.pdf.
Assistance Listings numbers and names 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Aid Portion 84.425F COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Institutional Portion 84.425L COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Minority Serving Institutions (MSIs) Award numbers and years P425E200055, April 20, 2020 through June 30, 2023; P425F201359, May 6, 2020 through June 30, 2023; P245L200182, June 2, 2020 through June 30, 2023 Federal agency U.S. Department of Education Compliance requirement Reporting Questioned costs Not applicable Condition?Contrary to federal regulations and guidance, the District?s Grant Services Department and the Financial Aid and Scholarships Department failed to make complete and accurate quarterly reports publicly available on the District?s website for the program?s student, institutional, and MSIs portions (Assistance Listings numbers 84.425E, 84.245F, and 84.425L, respectively). Specifically, the District did not complete and publicly post reports for the quarters ended March 31, 2022 and June 30, 2022, until January 2023, which was after we notified the District that the reports were missing from its website. In addition, for 2 of 3 reports we tested, the District overreported and underreported program expenditures by $1,558,400 and $9,806, respectively, for the student and MSIs portions (Assistance Listings numbers 84.425E and 84.425L). Further, the District did not retain documentation supporting the amounts it reported. Effect?The District?s failure to make complete and accurate quarterly reports available on the District?s website resulted in a lack of transparency to the public for how it spent federal COVID-19 Educational Stabilization Fund monies for program purposes. Cause?The personnel who had been administering the program left the District, and the new employees responsible for administering the program reported that they were not aware of the federal reporting requirement to post the reports on the District?s website and, therefore, did not properly coordinate the reporting requirements between the Grant Services Department and Financial Aid and Scholarships Department as both were responsible for the report. Further, the District did not follow the Grant Services Department?s written policies and procedures to track federal program reporting requirements to ensure that all reports were completed accurately and on time. Finally, an independent review was not performed for each section of the reports to ensure that they were complete and accurate. Criteria?Federal agency guidance requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the Education Stabilization Fund no later than 10 days after the calendar quarter.1 In addition, the federal Uniform Guidance requires the District to maintain program financial and accounting records and supporting documents relating to federal programs for at least 3 years from the date of the final expenditure report (2 Code of Federal Regulations [CFR] ?200.334). Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should: 1. Follow the Grant Services Department?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. b. Require a review and approval of all reports by an independent employee to ensure they are accurate. c. Retain all documentation supporting program expenditures reported in the federal grant reports. 2. Coordinate completing federal reports when more than 1 department is responsible for contributing information to the report to ensure the report is submitted on time. 3. Complete and publish on the District?s website the required quarterly grant reports for the Education Stabilization Fund no later than 10 days after the end of the quarter. 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. 1 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3) (OMB Paperwork Reduction Act Form Control Number 1840-0849). Retrieved 1/13/2023 from https://www2.ed.gov/about/offices/list/ope/arpheerfiiiqaurterlyreporting.pdf.
Assistance Listings numbers and names 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Aid Portion 84.425F COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Institutional Portion 84.425L COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Minority Serving Institutions (MSIs) Award numbers and years P425E200055, April 20, 2020 through June 30, 2023; P425F201359, May 6, 2020 through June 30, 2023; P245L200182, June 2, 2020 through June 30, 2023 Federal agency U.S. Department of Education Compliance requirement Reporting Questioned costs Not applicable Condition?Contrary to federal regulations and guidance, the District?s Grant Services Department and the Financial Aid and Scholarships Department failed to make complete and accurate quarterly reports publicly available on the District?s website for the program?s student, institutional, and MSIs portions (Assistance Listings numbers 84.425E, 84.245F, and 84.425L, respectively). Specifically, the District did not complete and publicly post reports for the quarters ended March 31, 2022 and June 30, 2022, until January 2023, which was after we notified the District that the reports were missing from its website. In addition, for 2 of 3 reports we tested, the District overreported and underreported program expenditures by $1,558,400 and $9,806, respectively, for the student and MSIs portions (Assistance Listings numbers 84.425E and 84.425L). Further, the District did not retain documentation supporting the amounts it reported. Effect?The District?s failure to make complete and accurate quarterly reports available on the District?s website resulted in a lack of transparency to the public for how it spent federal COVID-19 Educational Stabilization Fund monies for program purposes. Cause?The personnel who had been administering the program left the District, and the new employees responsible for administering the program reported that they were not aware of the federal reporting requirement to post the reports on the District?s website and, therefore, did not properly coordinate the reporting requirements between the Grant Services Department and Financial Aid and Scholarships Department as both were responsible for the report. Further, the District did not follow the Grant Services Department?s written policies and procedures to track federal program reporting requirements to ensure that all reports were completed accurately and on time. Finally, an independent review was not performed for each section of the reports to ensure that they were complete and accurate. Criteria?Federal agency guidance requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the Education Stabilization Fund no later than 10 days after the calendar quarter.1 In addition, the federal Uniform Guidance requires the District to maintain program financial and accounting records and supporting documents relating to federal programs for at least 3 years from the date of the final expenditure report (2 Code of Federal Regulations [CFR] ?200.334). Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should: 1. Follow the Grant Services Department?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. b. Require a review and approval of all reports by an independent employee to ensure they are accurate. c. Retain all documentation supporting program expenditures reported in the federal grant reports. 2. Coordinate completing federal reports when more than 1 department is responsible for contributing information to the report to ensure the report is submitted on time. 3. Complete and publish on the District?s website the required quarterly grant reports for the Education Stabilization Fund no later than 10 days after the end of the quarter. 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. 1 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3) (OMB Paperwork Reduction Act Form Control Number 1840-0849). Retrieved 1/13/2023 from https://www2.ed.gov/about/offices/list/ope/arpheerfiiiqaurterlyreporting.pdf.
Assistance Listings numbers and names 84.425E COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Student Aid Portion 84.425F COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Institutional Portion 84.425L COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Minority Serving Institutions (MSIs) Award numbers and years P425E200055, April 20, 2020 through June 30, 2023; P425F201359, May 6, 2020 through June 30, 2023; P245L200182, June 2, 2020 through June 30, 2023 Federal agency U.S. Department of Education Compliance requirement Reporting Questioned costs Not applicable Condition?Contrary to federal regulations and guidance, the District?s Grant Services Department and the Financial Aid and Scholarships Department failed to make complete and accurate quarterly reports publicly available on the District?s website for the program?s student, institutional, and MSIs portions (Assistance Listings numbers 84.425E, 84.245F, and 84.425L, respectively). Specifically, the District did not complete and publicly post reports for the quarters ended March 31, 2022 and June 30, 2022, until January 2023, which was after we notified the District that the reports were missing from its website. In addition, for 2 of 3 reports we tested, the District overreported and underreported program expenditures by $1,558,400 and $9,806, respectively, for the student and MSIs portions (Assistance Listings numbers 84.425E and 84.425L). Further, the District did not retain documentation supporting the amounts it reported. Effect?The District?s failure to make complete and accurate quarterly reports available on the District?s website resulted in a lack of transparency to the public for how it spent federal COVID-19 Educational Stabilization Fund monies for program purposes. Cause?The personnel who had been administering the program left the District, and the new employees responsible for administering the program reported that they were not aware of the federal reporting requirement to post the reports on the District?s website and, therefore, did not properly coordinate the reporting requirements between the Grant Services Department and Financial Aid and Scholarships Department as both were responsible for the report. Further, the District did not follow the Grant Services Department?s written policies and procedures to track federal program reporting requirements to ensure that all reports were completed accurately and on time. Finally, an independent review was not performed for each section of the reports to ensure that they were complete and accurate. Criteria?Federal agency guidance requires the District to publish on its website complete and accurate quarterly reports of its expenditures and other information for the Education Stabilization Fund no later than 10 days after the calendar quarter.1 In addition, the federal Uniform Guidance requires the District to maintain program financial and accounting records and supporting documents relating to federal programs for at least 3 years from the date of the final expenditure report (2 Code of Federal Regulations [CFR] ?200.334). Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that the federal program is being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should: 1. Follow the Grant Services Department?s written policies and procedures for completing federal grant reports to ensure compliance with federal program requirements, including processes to: a. Track when each federal grant program report is required to be completed and submit/post reports by the designated due dates. b. Require a review and approval of all reports by an independent employee to ensure they are accurate. c. Retain all documentation supporting program expenditures reported in the federal grant reports. 2. Coordinate completing federal reports when more than 1 department is responsible for contributing information to the report to ensure the report is submitted on time. 3. Complete and publish on the District?s website the required quarterly grant reports for the Education Stabilization Fund no later than 10 days after the end of the quarter. 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. 1 Federal laws and guidance issued by the U.S. Department of Education (ED) require the reporting for the Education Stabilization Fund?s programs related to the Higher Education Emergency Relief Fund: (CARES Act of 2020, sec. 18004 (Public Law [P.L.] 116-136), CRRSAA Act of 2020, sec. 314 (P.L. 116-260), and ARP Act of 2021, sec. 2003 (P.L. 117-2). ED?s guidance for the quarterly reports are contained in the prescribed report?s instructions, as outlined in the Quarterly Budget and Expenditure Reporting for HEERF I, II, and III (a)(1) Institutional Portion, (a)(2), and (a)(3) (OMB Paperwork Reduction Act Form Control Number 1840-0849). Retrieved 1/13/2023 from https://www2.ed.gov/about/offices/list/ope/arpheerfiiiqaurterlyreporting.pdf.
2022 ? 003: Reporting Federal agency: U.S. Department of Education Federal program title: Education Stabilization Fund: Higher Education Emergency Relief Fund Student Portion and Institutional Portion ALN Number: 84.425E, 84.425F Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with Federal Statutes, regulations, and the terms and conditions of the Federal awards. 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The University should have internal controls designed to ensure compliance with those provisions. Condition: During our testing of reporting for the Educational Stabilization Fund, it was noted that there was no formal documentation of review. Questioned costs: None Context: The University did not have documentation of review of student disbursements or reporting for the Education Stabilization Fund. Cause: Due to staffing turnover, the process and documented review was not completed for these areas. Effect: While performing audit procedures, no instances of noncompliance with the provisions of reporting were noted; however, the lack of internal controls and document review items in these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-004. Recommendation: We recommend the University design controls to ensure an adequate review and approval process is in place and documented.
2022 ? 003: Reporting Federal agency: U.S. Department of Education Federal program title: Education Stabilization Fund: Higher Education Emergency Relief Fund Student Portion and Institutional Portion ALN Number: 84.425E, 84.425F Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The 2 CFR Section 200.303 require that nonfederal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with Federal Statutes, regulations, and the terms and conditions of the Federal awards. 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The University should have internal controls designed to ensure compliance with those provisions. Condition: During our testing of reporting for the Educational Stabilization Fund, it was noted that there was no formal documentation of review. Questioned costs: None Context: The University did not have documentation of review of student disbursements or reporting for the Education Stabilization Fund. Cause: Due to staffing turnover, the process and documented review was not completed for these areas. Effect: While performing audit procedures, no instances of noncompliance with the provisions of reporting were noted; however, the lack of internal controls and document review items in these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-004. Recommendation: We recommend the University design controls to ensure an adequate review and approval process is in place and documented.
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.
Reference Number: 2022-027 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: COVID-19 ? Governor?s Emergency Education Relief Fund COVID-19 ? Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 ? Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public Schools (CRRSA EANS) COVID-19 ? American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425C, 84.425D, 84.425R, 84.425U Award Number and Year: S425D200011 (4/29/2020 ? 9/30/2021) S425D210011 (1/5/2021 ? 9/30/2022) S425C200009 (5/6/2020 ? 9/30/2021) S425C210009 (1/8/2021 ? 9/30/2022) S425U210011 (3/24/2021 ? 9/30/2023) S425R210033 (2/23/2021 ? 9/30/2022) S425W210047 (4/23/2021 ? 9/30/2023) S425V210033 (1/21/2021 ? 9/30/2023) Compliance Requirement: Cash Management 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. 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 drawn down for the program 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 drawn down for the program as compared to expenditures it had incurred and reported on the Schedule of Expenditures of Federal Awards (SEFA). Auditors noted that total draws were $7.4 million (approximately 10%) 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 draw population provided for testing was 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 cash management to ensure that cash draws 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: 2022-029 Prior Year Finding: 2021-018 Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: COVID-19 ? Governor?s Emergency Education Relief Fund COVID-19 ? Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 ? American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425C, 84.425D, 84.425U Award Number and Year: S425D210011 (1/5/2021 ? 9/30/2022) S425U210011 (3/24/2021 ? 9/30/2023) 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 to FSRS or were not reported timely. Context: Ten of thirty-two subawards selected for testing were not in compliance with FFATA reporting requirements. The following exceptions were noted: ? 2 of 32 subawards were not reported to FSRS. ? 5 of 32 subawards were issued amendments to the original subaward, but the amendments were not reported to FSRS. ? 2 of 32 subawards were not reported timely to FSRS. ? 1 of 32 subawards were issued amendments to the original subaward, but the 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 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: 2022-026 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: COVID-19 ? Governor?s Emergency Education Relief Fund COVID-19 ? Elementary and Secondary School Emergency Relief Fund (ESSER) Assistance Listing Number: 84.425C, 84.425D Award Number and Year: S425D200011 (4/29/2020 ? 9/30/2021) S425D210011 (1/5/2021 ? 9/30/2022) S425C200009 (5/6/2020 ? 9/30/2021) S425C210009 (1/8/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Participation of Private School Children Type of Finding Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: For programs under ESSER I and GEER I (Assistance Listing 84.425C and D), an LEA that receives funds under one or both of those programs must provide equitable services in the same manner as provided under section 1117 of Title I, Part A of the ESEA (20 USC 6320) (Assistance Listing 84.010) to students and teachers in private schools as determined in consultation with private school officials (section 18005(a) of the CARES Act). To meet this requirement, a Local Education Agency (LEA) must determine the proportional share of ESSER I or GEER I funds available for equitable services in accordance with section 1117(a)(4)(A) of the ESEA (20 USC 6320(a)(4)(A)). 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 the calculation of Participation of Private School Children set-aside amounts. Context: For 12 of 12 LEAs selected for testing, the Agency was unable to provide support to validate that the set-aside amounts for private school children had been determined appropriately. The total set asides were determined at the school district level and support was maintained at the LEA and not at the non-public (independent) school level. Therefore, auditors could not verify the accuracy of the set-aside calculations. Cause: The Agency?s procedures and internal controls were not sufficient to ensure it maintained documentation supporting private school set-aside calculations. Effect: Auditors were unable to verify that set-aside calculations were accurate and determined properly. Questioned costs: Undetermined. Recommendation: We recommend the Agency review and enhance internal controls and procedures over participation of private school children and that documentation supporting set-aside calculations is maintained and available for auditor review. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-027 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: COVID-19 ? Governor?s Emergency Education Relief Fund COVID-19 ? Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 ? Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public Schools (CRRSA EANS) COVID-19 ? American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425C, 84.425D, 84.425R, 84.425U Award Number and Year: S425D200011 (4/29/2020 ? 9/30/2021) S425D210011 (1/5/2021 ? 9/30/2022) S425C200009 (5/6/2020 ? 9/30/2021) S425C210009 (1/8/2021 ? 9/30/2022) S425U210011 (3/24/2021 ? 9/30/2023) S425R210033 (2/23/2021 ? 9/30/2022) S425W210047 (4/23/2021 ? 9/30/2023) S425V210033 (1/21/2021 ? 9/30/2023) Compliance Requirement: Cash Management 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. 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 drawn down for the program 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 drawn down for the program as compared to expenditures it had incurred and reported on the Schedule of Expenditures of Federal Awards (SEFA). Auditors noted that total draws were $7.4 million (approximately 10%) 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 draw population provided for testing was 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 cash management to ensure that cash draws 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: 2022-029 Prior Year Finding: 2021-018 Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: COVID-19 ? Governor?s Emergency Education Relief Fund COVID-19 ? Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 ? American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425C, 84.425D, 84.425U Award Number and Year: S425D210011 (1/5/2021 ? 9/30/2022) S425U210011 (3/24/2021 ? 9/30/2023) 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 to FSRS or were not reported timely. Context: Ten of thirty-two subawards selected for testing were not in compliance with FFATA reporting requirements. The following exceptions were noted: ? 2 of 32 subawards were not reported to FSRS. ? 5 of 32 subawards were issued amendments to the original subaward, but the amendments were not reported to FSRS. ? 2 of 32 subawards were not reported timely to FSRS. ? 1 of 32 subawards were issued amendments to the original subaward, but the 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 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: 2022-027 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: COVID-19 ? Governor?s Emergency Education Relief Fund COVID-19 ? Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 ? Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public Schools (CRRSA EANS) COVID-19 ? American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425C, 84.425D, 84.425R, 84.425U Award Number and Year: S425D200011 (4/29/2020 ? 9/30/2021) S425D210011 (1/5/2021 ? 9/30/2022) S425C200009 (5/6/2020 ? 9/30/2021) S425C210009 (1/8/2021 ? 9/30/2022) S425U210011 (3/24/2021 ? 9/30/2023) S425R210033 (2/23/2021 ? 9/30/2022) S425W210047 (4/23/2021 ? 9/30/2023) S425V210033 (1/21/2021 ? 9/30/2023) Compliance Requirement: Cash Management 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. 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 drawn down for the program 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 drawn down for the program as compared to expenditures it had incurred and reported on the Schedule of Expenditures of Federal Awards (SEFA). Auditors noted that total draws were $7.4 million (approximately 10%) 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 draw population provided for testing was 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 cash management to ensure that cash draws 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: 2022-028 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: COVID-19 ? Governor?s Emergency Education Relief Fund Assistance Listing Number: 84.425C, 84.425R Award Number and Year: S425C200009 (5/6/2020 ? 9/30/2021) S425C210009 (1/8/2021 ? 9/30/2022) S425R210033 (2/23/2021 ? 9/30/2022) S425V210033 (1/21/2021 ? 9/30/2023) Compliance Requirement: Equipment/Real Property Management Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR section 200.313(b), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and procedures. Per 2 CFR section 200.313(d), procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. 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 unable to provide supporting documentation for equipment purchased with program funds. The Agency did not maintain an equipment ledger or track equipment in accordance with 2 CFR section 200.313. Context: When auditors conducted an initial risk assessment of the program, the Agency was unable to provide an equipment ledger or other supporting documentation of equipment purchased with program funds and, therefore, materiality could not be determined. The Agency conducted a manual assessment over all personal property/equipment purchased with federal program funding. This assessment determined that approximately $78,000 of equipment was purchased using GEER funding. While this amount is immaterial to total funding dollars, materiality could only be determined due to the additional assessments performed. Cause: The Agency?s procedures and internal controls were not sufficient to ensure it maintained documentation of equipment purchased with program funds. Effect: Equipment purchased with program funds was not managed and accounted for in accordance with State laws and procedures and in accordance with 2 CFR section 200.313. Questioned costs: Undetermined. Recommendation: We recommend the Agency review and enhance internal controls and procedures over equipment to ensure that it purchases and records equipment purchased with program funds in accordance with State laws and procedures and in accordance with 2 CFR section 200.313. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-026 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: COVID-19 ? Governor?s Emergency Education Relief Fund COVID-19 ? Elementary and Secondary School Emergency Relief Fund (ESSER) Assistance Listing Number: 84.425C, 84.425D Award Number and Year: S425D200011 (4/29/2020 ? 9/30/2021) S425D210011 (1/5/2021 ? 9/30/2022) S425C200009 (5/6/2020 ? 9/30/2021) S425C210009 (1/8/2021 ? 9/30/2022) Compliance Requirement: Special Tests and Provisions ? Participation of Private School Children Type of Finding Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: For programs under ESSER I and GEER I (Assistance Listing 84.425C and D), an LEA that receives funds under one or both of those programs must provide equitable services in the same manner as provided under section 1117 of Title I, Part A of the ESEA (20 USC 6320) (Assistance Listing 84.010) to students and teachers in private schools as determined in consultation with private school officials (section 18005(a) of the CARES Act). To meet this requirement, a Local Education Agency (LEA) must determine the proportional share of ESSER I or GEER I funds available for equitable services in accordance with section 1117(a)(4)(A) of the ESEA (20 USC 6320(a)(4)(A)). 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 the calculation of Participation of Private School Children set-aside amounts. Context: For 12 of 12 LEAs selected for testing, the Agency was unable to provide support to validate that the set-aside amounts for private school children had been determined appropriately. The total set asides were determined at the school district level and support was maintained at the LEA and not at the non-public (independent) school level. Therefore, auditors could not verify the accuracy of the set-aside calculations. Cause: The Agency?s procedures and internal controls were not sufficient to ensure it maintained documentation supporting private school set-aside calculations. Effect: Auditors were unable to verify that set-aside calculations were accurate and determined properly. Questioned costs: Undetermined. Recommendation: We recommend the Agency review and enhance internal controls and procedures over participation of private school children and that documentation supporting set-aside calculations is maintained and available for auditor review. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-027 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: COVID-19 ? Governor?s Emergency Education Relief Fund COVID-19 ? Elementary and Secondary School Emergency Relief Fund (ESSER) COVID-19 ? Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public Schools (CRRSA EANS) COVID-19 ? American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Assistance Listing Number: 84.425C, 84.425D, 84.425R, 84.425U Award Number and Year: S425D200011 (4/29/2020 ? 9/30/2021) S425D210011 (1/5/2021 ? 9/30/2022) S425C200009 (5/6/2020 ? 9/30/2021) S425C210009 (1/8/2021 ? 9/30/2022) S425U210011 (3/24/2021 ? 9/30/2023) S425R210033 (2/23/2021 ? 9/30/2022) S425W210047 (4/23/2021 ? 9/30/2023) S425V210033 (1/21/2021 ? 9/30/2023) Compliance Requirement: Cash Management 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. 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 drawn down for the program 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 drawn down for the program as compared to expenditures it had incurred and reported on the Schedule of Expenditures of Federal Awards (SEFA). Auditors noted that total draws were $7.4 million (approximately 10%) 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 draw population provided for testing was 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 cash management to ensure that cash draws 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: 2022-028 Prior Year Finding: No Federal Agency: U.S. Department of Education State Agency: Agency of Education (Agency) Federal Program: COVID-19 ? Governor?s Emergency Education Relief Fund Assistance Listing Number: 84.425C, 84.425R Award Number and Year: S425C200009 (5/6/2020 ? 9/30/2021) S425C210009 (1/8/2021 ? 9/30/2022) S425R210033 (2/23/2021 ? 9/30/2022) S425V210033 (1/21/2021 ? 9/30/2023) Compliance Requirement: Equipment/Real Property Management Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR section 200.313(b), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and procedures. Per 2 CFR section 200.313(d), procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. 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 unable to provide supporting documentation for equipment purchased with program funds. The Agency did not maintain an equipment ledger or track equipment in accordance with 2 CFR section 200.313. Context: When auditors conducted an initial risk assessment of the program, the Agency was unable to provide an equipment ledger or other supporting documentation of equipment purchased with program funds and, therefore, materiality could not be determined. The Agency conducted a manual assessment over all personal property/equipment purchased with federal program funding. This assessment determined that approximately $78,000 of equipment was purchased using GEER funding. While this amount is immaterial to total funding dollars, materiality could only be determined due to the additional assessments performed. Cause: The Agency?s procedures and internal controls were not sufficient to ensure it maintained documentation of equipment purchased with program funds. Effect: Equipment purchased with program funds was not managed and accounted for in accordance with State laws and procedures and in accordance with 2 CFR section 200.313. Questioned costs: Undetermined. Recommendation: We recommend the Agency review and enhance internal controls and procedures over equipment to ensure that it purchases and records equipment purchased with program funds in accordance with State laws and procedures and in accordance with 2 CFR section 200.313. Views of responsible officials: Management agrees with the finding.