2022-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010 Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Preschool Grants ALN: 84.173A Education Stabilization Fund COVID-19: Governor?s Emergency Education relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief - Homeless Children and Youth ALN: 84.425W United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster COVID-19: School Breakfast Program (SSO) ALN: 10.553 National School Lunch Program ALN: 10.555 COVID-19: National School Lunch Program ALN: 10.555 COVID-19: Summer Food Service Program for Children ALN: 10.559 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance, federal awards recipients must maintain written documentation of internal control policies and procedures, such as procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: Staffing constraints have limited the District?s ability to perform a timely review of its existing policies and written procedures. Effect: Having insufficient or non-compliant written policies and procedures weaken internal controls over the federal awards received, increasing the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding from the previous audit referenced 2021-001. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District?s Assistant Superintendent for Business will work on updating all policies and procedures relating to US Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.
2022-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010 Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Preschool Grants ALN: 84.173A Education Stabilization Fund COVID-19: Governor?s Emergency Education relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief - Homeless Children and Youth ALN: 84.425W United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster COVID-19: School Breakfast Program (SSO) ALN: 10.553 National School Lunch Program ALN: 10.555 COVID-19: National School Lunch Program ALN: 10.555 COVID-19: Summer Food Service Program for Children ALN: 10.559 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance, federal awards recipients must maintain written documentation of internal control policies and procedures, such as procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: Staffing constraints have limited the District?s ability to perform a timely review of its existing policies and written procedures. Effect: Having insufficient or non-compliant written policies and procedures weaken internal controls over the federal awards received, increasing the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding from the previous audit referenced 2021-001. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District?s Assistant Superintendent for Business will work on updating all policies and procedures relating to US Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.
2022-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010 Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Preschool Grants ALN: 84.173A Education Stabilization Fund COVID-19: Governor?s Emergency Education relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief - Homeless Children and Youth ALN: 84.425W United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster COVID-19: School Breakfast Program (SSO) ALN: 10.553 National School Lunch Program ALN: 10.555 COVID-19: National School Lunch Program ALN: 10.555 COVID-19: Summer Food Service Program for Children ALN: 10.559 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance, federal awards recipients must maintain written documentation of internal control policies and procedures, such as procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: Staffing constraints have limited the District?s ability to perform a timely review of its existing policies and written procedures. Effect: Having insufficient or non-compliant written policies and procedures weaken internal controls over the federal awards received, increasing the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding from the previous audit referenced 2021-001. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District?s Assistant Superintendent for Business will work on updating all policies and procedures relating to US Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.
2022-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010 Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Preschool Grants ALN: 84.173A Education Stabilization Fund COVID-19: Governor?s Emergency Education relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief - Homeless Children and Youth ALN: 84.425W United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster COVID-19: School Breakfast Program (SSO) ALN: 10.553 National School Lunch Program ALN: 10.555 COVID-19: National School Lunch Program ALN: 10.555 COVID-19: Summer Food Service Program for Children ALN: 10.559 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance, federal awards recipients must maintain written documentation of internal control policies and procedures, such as procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: Staffing constraints have limited the District?s ability to perform a timely review of its existing policies and written procedures. Effect: Having insufficient or non-compliant written policies and procedures weaken internal controls over the federal awards received, increasing the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding from the previous audit referenced 2021-001. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District?s Assistant Superintendent for Business will work on updating all policies and procedures relating to US Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.
2022-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010 Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Preschool Grants ALN: 84.173A Education Stabilization Fund COVID-19: Governor?s Emergency Education relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief - Homeless Children and Youth ALN: 84.425W United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster COVID-19: School Breakfast Program (SSO) ALN: 10.553 National School Lunch Program ALN: 10.555 COVID-19: National School Lunch Program ALN: 10.555 COVID-19: Summer Food Service Program for Children ALN: 10.559 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance, federal awards recipients must maintain written documentation of internal control policies and procedures, such as procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: Staffing constraints have limited the District?s ability to perform a timely review of its existing policies and written procedures. Effect: Having insufficient or non-compliant written policies and procedures weaken internal controls over the federal awards received, increasing the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding from the previous audit referenced 2021-001. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District?s Assistant Superintendent for Business will work on updating all policies and procedures relating to US Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.
2022-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010 Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Preschool Grants ALN: 84.173A Education Stabilization Fund COVID-19: Governor?s Emergency Education relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief - Homeless Children and Youth ALN: 84.425W United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster COVID-19: School Breakfast Program (SSO) ALN: 10.553 National School Lunch Program ALN: 10.555 COVID-19: National School Lunch Program ALN: 10.555 COVID-19: Summer Food Service Program for Children ALN: 10.559 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance, federal awards recipients must maintain written documentation of internal control policies and procedures, such as procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: Staffing constraints have limited the District?s ability to perform a timely review of its existing policies and written procedures. Effect: Having insufficient or non-compliant written policies and procedures weaken internal controls over the federal awards received, increasing the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding from the previous audit referenced 2021-001. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District?s Assistant Superintendent for Business will work on updating all policies and procedures relating to US Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.
2022-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010 Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Preschool Grants ALN: 84.173A Education Stabilization Fund COVID-19: Governor?s Emergency Education relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief - Homeless Children and Youth ALN: 84.425W United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster COVID-19: School Breakfast Program (SSO) ALN: 10.553 National School Lunch Program ALN: 10.555 COVID-19: National School Lunch Program ALN: 10.555 COVID-19: Summer Food Service Program for Children ALN: 10.559 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance, federal awards recipients must maintain written documentation of internal control policies and procedures, such as procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: Staffing constraints have limited the District?s ability to perform a timely review of its existing policies and written procedures. Effect: Having insufficient or non-compliant written policies and procedures weaken internal controls over the federal awards received, increasing the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding from the previous audit referenced 2021-001. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District?s Assistant Superintendent for Business will work on updating all policies and procedures relating to US Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.
2022-002 Activities Allowed or Unallowed, Allowable Costs/Cost Principles Medical Assistance Program ? CFDA No. 93.778 ? Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Condition: Hours from payroll timesheets were incorrectly entered into the payroll allocation spreadsheet for five pay periods for one sampled employee. These errors were not detected and corrected after-the-fact. Criteria: According to 2 CFR 200.303(a), non-Federal entities 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. Per 2 CFR 200.430(i)(1), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated Cause: The Organization?s established internal controls over payroll cost allocation did not operate as intended. Effect: Payroll costs that are not allowable per the terms and conditions of the grant, or improper payroll costs could be charged to the grant. Recommendation: The Organization should strengthen their policies and procedures to support a system of internal control able to prevent and/or detect and correct errors timely ensuring payroll costs are accurate, allowable, and properly allocated. Views of Responsible Officials and Planned Corrective Actions: Adult Care Management, Inc. (ACMI) agrees with the finding of Taylor Roth & Company, PLLC, in the fiscal year 2022 Single Audit (SEFA) that the established internal controls over payroll cost allocation did not operate as intended to ensure appropriate allocation of payroll costs across all programs in the five (5) of the twenty-four sampled payroll periods for one (1) individual. Effective March 10, 2023, the internal control practices of ACMI will be strengthened to support a review system able to prevent and/or detect and correct errors in a timely manner to ensure payroll costs are accurate, allowable, and properly allocated. Specifically, management?s monthly review of all cost allocations will include a review of the data entry hours from payroll timesheets into the payroll allocation spreadsheet of no less than 10% of total reporting employees, with a priority focus on employees reporting time to more than one program / cost center.
Finding 2022-003 Department of Education Education Stabilization Fund - Higher Education Emergency Relief Fund ? Student Federal Financial Assistance Listing #84.425E P425E200919-20B Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Criteria: The Organization is required to have procedures in place to ensure that federal awards are expended only for allowable costs in accordance with Subpart E ? Cost Principles of the Uniform Guidance. Allowable costs are supported by appropriate documentation and correctly charged as to account, amount, and period. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.430(i) establishes the standards for documentation of personnel expenses including charges to Federal awards for salaries and wages. Condition: The University over-awarded Higher Education Emergency Relief Fund (HEERF) funding to one student based on its determination over eligibility of the student portion of HEERF funding, which is awarded based on (1) expected family contribution and (2) enrollment status. The student was awarded based on fulltime enrollment; however, the student?s enrollment status was part-time. Cause: The student listing, prepared by the registrar?s office and used by the financial aid office to determine the allocation of student funding improperly counted credit hours more than once for certain students. Effect: Ineffective controls over this area of compliance could result in a reasonable possibility that disallowed expenditures will be charged to the federal award. Questioned Costs: No questioned costs (students were overpaid) Context: A nonstatistical sample of 60 ($82,250) students out of a total of approximately 1,270 ($1,627,825) students were tested. Repeat Finding from Prior Year: No Recommendation: We recommend that management review procedures and control processes to comply with the federal requirements noted above. Views of Responsible Officials: Management agrees with the finding and the recommendation.
Finding 2022-004 Department of Education Education Stabilization Fund - Higher Education Emergency Relief Fund ? Institutional Federal Financial Assistance Listing #84.425F P425F200756-20A and P425F200756-20B Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition: The University?s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the University did not retain documentation to support the procedures it performed to ensure compliance with procurement, suspension, and debarment. Cause: The University does not typically use federal financial assistance to procure goods and services; consequently, certain elements required by the Uniform Guidance were missing. Effect: Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with procurement, suspension, and debarment could result in procurements that do not conform with Uniform Guidance. Questioned Costs: None reported Context: A non-statistical sample of 4 ($291,493) out of 21 ($392,941) purchases / contracts with expenditures over the micropurchase threshold of $3,000 were tested for procurement. In addition, suspension and debarment was applicable to two vendors. Repeat Finding from Prior Year: Yes, prior year finding 2021-003 Recommendation: We recommend that management develop a written procurement policy that conforms with Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements. Views of Responsible Officials: Management agrees with the finding and the recommendation.
2022-005 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly. Condition: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded. Questioned Costs: None Context: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period. Repeat findings: 2021-007 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-007 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Standards for Safeguarding Customer Information, required by the Gramm-Leach-Bliley Act (GLBA) (16 CFR 314.4 (b)), requires customers to identify reasonable foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risk in each relevant area of operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other system failures. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures for timely review of the Information Security Program and proper documentation of the risk assessments. Condition: As a requirement under the College's Program Participation Agreement with the Department of Education, the College must protect student financial aid information. However, during our testing, we noted the College had not properly conducted a risk assessment identifying all internal and external risks to the security, confidentiality, and the integrity of the students? information. Questioned Costs: None Context: As a requirement under the College's Program Participation Agreement with the Department of Education, the College must protect student financial aid information. However, during our testing, we noted the College had not properly conducted a risk assessment identifying all internal and external risks to the security, confidentiality, and the integrity of the students? information. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Without documentation of a proper risk assessment, the College is at risk of noncompliance with the GLBA. In addition, there is a risk the College?s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. Repeat findings: 2021-010 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. After year end, the College engaged CLA to assist with the GLBA process for the next fiscal year. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-005 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly. Condition: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. In addition, the enrollment reports do not have a documented review before they are uploaded. Questioned Costs: None Context: Throughout the 2021-22 award year, we noted error records were being returned on the enrollment reporting rosters that were sent to National Student Loan Data System (NSLDS) and those error records were not being corrected and resubmitted within the required 10 days. Out of the eight students, from a statistically valid sample, we noted five (5) students status changes were reported after the 60-day reporting requirement. We also noted for the same five students that enrollment was not certified 60 days. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: If the NSLDS system is not updated with the student information, over awards could occur should the student transfer to another institution and the students may not properly enter the repayment period. Repeat findings: 2021-007 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-007 Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063, 84.268 Federal Award Identification Number and Year: P063P218567-2022, P268K228567-2022 Award Periods: July 1, 2021 through June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control Over Compliance ? Other Matters Criteria or specific requirement: The Standards for Safeguarding Customer Information, required by the Gramm-Leach-Bliley Act (GLBA) (16 CFR 314.4 (b)), requires customers to identify reasonable foreseeable internal and external risks to the security, confidentiality, and integrity of customer information that could result in the unauthorized disclosure, misuse, alteration, destruction or other compromise of such information, and assess the sufficiency of any safeguards in place to control these risks. At a minimum, such a risk assessment should include consideration of risk in each relevant area of operations, including: 1. Employee training and management; 2. Information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3. Detecting, preventing, and responding to attacks, intrusions, or other system failures. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures for timely review of the Information Security Program and proper documentation of the risk assessments. Condition: As a requirement under the College's Program Participation Agreement with the Department of Education, the College must protect student financial aid information. However, during our testing, we noted the College had not properly conducted a risk assessment identifying all internal and external risks to the security, confidentiality, and the integrity of the students? information. Questioned Costs: None Context: As a requirement under the College's Program Participation Agreement with the Department of Education, the College must protect student financial aid information. However, during our testing, we noted the College had not properly conducted a risk assessment identifying all internal and external risks to the security, confidentiality, and the integrity of the students? information. Cause: The College did not have the appropriate resources and staffing in place to verify they were in compliance with all requirements. Effect: Without documentation of a proper risk assessment, the College is at risk of noncompliance with the GLBA. In addition, there is a risk the College?s information and systems could be vulnerable to attacks or intrusions, and these attacks may not be detected in a timely manner. Repeat findings: 2021-010 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. After year end, the College engaged CLA to assist with the GLBA process for the next fiscal year. Views of Responsible Officials: There is no disagreement with the audit finding.
2022-001 Federal Agency: U.S. Department of Treasury and U.S. Department of Agriculture Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) and Child Nutrition Cluster (CNC) Assistance Listing Number: 21.027 and 10,553, 555 559 Federal Award ID Number (FAIN) and Year: S425D2000005, 2021- 2024 (CLSFRF), and 2022 (CNC) Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 21176201, 21189901, 21181601, 21187301, 21177401, 21188801, 21184001(CSLFRF) and CNC: none Award Period: March 3, 2021, through - December 31, 2024 (CSLFRF) and July 1, 2021, through June 30, 2022 (CNC) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). 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: During our testing, we noted the schools did not maintain documentation to support vendor?s suspension and debarment status. The school?s procurement procedures and annual procurement updates advise employees to verify the vendor?s suspension and debarment status, but evidence of the review is not maintained. CLA was not able to determine if the vendor was not suspended or debarred prior to contracting with the schools. We were able to confirm that the vendor was not identified as suspended or debarred via SAMs.gov during the audit. Questioned costs: None Context: During our testing, two of the five CNC vendors and four of the four CSLFRF vendors did not have documentation of their suspension or debarment status prior to the school?s contracting with the vendor. Cause: The client was aware of the requirement and ensured communication of the requirement was provided to the schools? employees but did not maintain documentation of the review. Effect: The schools did not have adequate monitoring controls to provide evidence of compliance with the requirement. Repeat Finding: No Recommendation: We recommend that the schools develop internal controls and procedures to ensure that documentation of vendor?s suspension and debarment status is maintained in accordance with the required retention policy. Views of responsible officials: There is no disagreement with the audit finding.
2022-001 Federal Agency: U.S. Department of Treasury and U.S. Department of Agriculture Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) and Child Nutrition Cluster (CNC) Assistance Listing Number: 21.027 and 10,553, 555 559 Federal Award ID Number (FAIN) and Year: S425D2000005, 2021- 2024 (CLSFRF), and 2022 (CNC) Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 21176201, 21189901, 21181601, 21187301, 21177401, 21188801, 21184001(CSLFRF) and CNC: none Award Period: March 3, 2021, through - December 31, 2024 (CSLFRF) and July 1, 2021, through June 30, 2022 (CNC) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). 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: During our testing, we noted the schools did not maintain documentation to support vendor?s suspension and debarment status. The school?s procurement procedures and annual procurement updates advise employees to verify the vendor?s suspension and debarment status, but evidence of the review is not maintained. CLA was not able to determine if the vendor was not suspended or debarred prior to contracting with the schools. We were able to confirm that the vendor was not identified as suspended or debarred via SAMs.gov during the audit. Questioned costs: None Context: During our testing, two of the five CNC vendors and four of the four CSLFRF vendors did not have documentation of their suspension or debarment status prior to the school?s contracting with the vendor. Cause: The client was aware of the requirement and ensured communication of the requirement was provided to the schools? employees but did not maintain documentation of the review. Effect: The schools did not have adequate monitoring controls to provide evidence of compliance with the requirement. Repeat Finding: No Recommendation: We recommend that the schools develop internal controls and procedures to ensure that documentation of vendor?s suspension and debarment status is maintained in accordance with the required retention policy. Views of responsible officials: There is no disagreement with the audit finding.
2022-001 Federal Agency: U.S. Department of Treasury and U.S. Department of Agriculture Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) and Child Nutrition Cluster (CNC) Assistance Listing Number: 21.027 and 10,553, 555 559 Federal Award ID Number (FAIN) and Year: S425D2000005, 2021- 2024 (CLSFRF), and 2022 (CNC) Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 21176201, 21189901, 21181601, 21187301, 21177401, 21188801, 21184001(CSLFRF) and CNC: none Award Period: March 3, 2021, through - December 31, 2024 (CSLFRF) and July 1, 2021, through June 30, 2022 (CNC) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). 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: During our testing, we noted the schools did not maintain documentation to support vendor?s suspension and debarment status. The school?s procurement procedures and annual procurement updates advise employees to verify the vendor?s suspension and debarment status, but evidence of the review is not maintained. CLA was not able to determine if the vendor was not suspended or debarred prior to contracting with the schools. We were able to confirm that the vendor was not identified as suspended or debarred via SAMs.gov during the audit. Questioned costs: None Context: During our testing, two of the five CNC vendors and four of the four CSLFRF vendors did not have documentation of their suspension or debarment status prior to the school?s contracting with the vendor. Cause: The client was aware of the requirement and ensured communication of the requirement was provided to the schools? employees but did not maintain documentation of the review. Effect: The schools did not have adequate monitoring controls to provide evidence of compliance with the requirement. Repeat Finding: No Recommendation: We recommend that the schools develop internal controls and procedures to ensure that documentation of vendor?s suspension and debarment status is maintained in accordance with the required retention policy. Views of responsible officials: There is no disagreement with the audit finding.
2022-001 Federal Agency: U.S. Department of Treasury and U.S. Department of Agriculture Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) and Child Nutrition Cluster (CNC) Assistance Listing Number: 21.027 and 10,553, 555 559 Federal Award ID Number (FAIN) and Year: S425D2000005, 2021- 2024 (CLSFRF), and 2022 (CNC) Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 21176201, 21189901, 21181601, 21187301, 21177401, 21188801, 21184001(CSLFRF) and CNC: none Award Period: March 3, 2021, through - December 31, 2024 (CSLFRF) and July 1, 2021, through June 30, 2022 (CNC) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). 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: During our testing, we noted the schools did not maintain documentation to support vendor?s suspension and debarment status. The school?s procurement procedures and annual procurement updates advise employees to verify the vendor?s suspension and debarment status, but evidence of the review is not maintained. CLA was not able to determine if the vendor was not suspended or debarred prior to contracting with the schools. We were able to confirm that the vendor was not identified as suspended or debarred via SAMs.gov during the audit. Questioned costs: None Context: During our testing, two of the five CNC vendors and four of the four CSLFRF vendors did not have documentation of their suspension or debarment status prior to the school?s contracting with the vendor. Cause: The client was aware of the requirement and ensured communication of the requirement was provided to the schools? employees but did not maintain documentation of the review. Effect: The schools did not have adequate monitoring controls to provide evidence of compliance with the requirement. Repeat Finding: No Recommendation: We recommend that the schools develop internal controls and procedures to ensure that documentation of vendor?s suspension and debarment status is maintained in accordance with the required retention policy. Views of responsible officials: There is no disagreement with the audit finding.
2022-001 Federal Agency: U.S. Department of Treasury and U.S. Department of Agriculture Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) and Child Nutrition Cluster (CNC) Assistance Listing Number: 21.027 and 10,553, 555 559 Federal Award ID Number (FAIN) and Year: S425D2000005, 2021- 2024 (CLSFRF), and 2022 (CNC) Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 21176201, 21189901, 21181601, 21187301, 21177401, 21188801, 21184001(CSLFRF) and CNC: none Award Period: March 3, 2021, through - December 31, 2024 (CSLFRF) and July 1, 2021, through June 30, 2022 (CNC) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). 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: During our testing, we noted the schools did not maintain documentation to support vendor?s suspension and debarment status. The school?s procurement procedures and annual procurement updates advise employees to verify the vendor?s suspension and debarment status, but evidence of the review is not maintained. CLA was not able to determine if the vendor was not suspended or debarred prior to contracting with the schools. We were able to confirm that the vendor was not identified as suspended or debarred via SAMs.gov during the audit. Questioned costs: None Context: During our testing, two of the five CNC vendors and four of the four CSLFRF vendors did not have documentation of their suspension or debarment status prior to the school?s contracting with the vendor. Cause: The client was aware of the requirement and ensured communication of the requirement was provided to the schools? employees but did not maintain documentation of the review. Effect: The schools did not have adequate monitoring controls to provide evidence of compliance with the requirement. Repeat Finding: No Recommendation: We recommend that the schools develop internal controls and procedures to ensure that documentation of vendor?s suspension and debarment status is maintained in accordance with the required retention policy. Views of responsible officials: There is no disagreement with the audit finding.
2022-001 Federal Agency: U.S. Department of Treasury and U.S. Department of Agriculture Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) and Child Nutrition Cluster (CNC) Assistance Listing Number: 21.027 and 10,553, 555 559 Federal Award ID Number (FAIN) and Year: S425D2000005, 2021- 2024 (CLSFRF), and 2022 (CNC) Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 21176201, 21189901, 21181601, 21187301, 21177401, 21188801, 21184001(CSLFRF) and CNC: none Award Period: March 3, 2021, through - December 31, 2024 (CSLFRF) and July 1, 2021, through June 30, 2022 (CNC) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). 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: During our testing, we noted the schools did not maintain documentation to support vendor?s suspension and debarment status. The school?s procurement procedures and annual procurement updates advise employees to verify the vendor?s suspension and debarment status, but evidence of the review is not maintained. CLA was not able to determine if the vendor was not suspended or debarred prior to contracting with the schools. We were able to confirm that the vendor was not identified as suspended or debarred via SAMs.gov during the audit. Questioned costs: None Context: During our testing, two of the five CNC vendors and four of the four CSLFRF vendors did not have documentation of their suspension or debarment status prior to the school?s contracting with the vendor. Cause: The client was aware of the requirement and ensured communication of the requirement was provided to the schools? employees but did not maintain documentation of the review. Effect: The schools did not have adequate monitoring controls to provide evidence of compliance with the requirement. Repeat Finding: No Recommendation: We recommend that the schools develop internal controls and procedures to ensure that documentation of vendor?s suspension and debarment status is maintained in accordance with the required retention policy. Views of responsible officials: There is no disagreement with the audit finding.
United States Department of the Treasury Reference Number: 2022-008 Program: 21.023 COVID-19 Emergency Rental Assistance Federal Award Number: ERA-2101123208 & ERAE0280 Type of Finding: Noncompliance; Significant Deficiency in Internal Controls over Compliance Compliance Requirement: Reporting & Special Tests and Provisions Condition: The following conditions were found during audit testing of four monthly reports and one quarterly report for ERA 1 and ERA 2: DSHA internal procedures over the reporting did not require a secondary review prior to submission of the reports. 2. Supporting documentation was not retained for information reported on the reports selected for testing. We were unable to reconcile amounts reported on monthly and quarterly reports submitted to the U.S. Treasury to underlying records. Additionally, audit testing found the differences noted below between the reports submitted and records obtained during the audit: a. The ERA 1 report for the quarter ended June 30, 2022, reported program spending and obligations totaling $166,277,794. Actual ERA 1 expenditures through June 30, 2022, totaled approximately $93,350,000. Program obligations were not tracked or reported. b. We found the following differences in Federal Funding Accountability and Transparency Act reporting on the quarterly reports submitted to the U.S. Treasury: One subrecipient?s TIN number was appeared incorrectly in the subrecipients section of the quarterly report. ii. DSHA could not provide evidence that two program subrecipients were correctly included in the quarterly report. The following U.S. Treasury required reports were not submitted timely: Reports for the quarter ended September 30, 2021 were due on October 29, 2021 and were submitted on December 28, 2021. Reports for the quarter ended June 30, 2022, Were due to the U.S. Treasury on July 15, 2022 and were submitted on August 15, 2022. Criteria: United States Department of the Treasury ERA Program Reporting Guidance version 3.2 was issued March 29, 2022. The following sections of the Reporting guidance contain the key criteria: Pages 10 and 11 detail monthly and quarterly reporting deadlines for the entire period of performance. Page 38 includes the text of the Report Certification and Submission representation that includes the following: ?I certify that the information provided is accurate and complete after reasonable inquiry of people, systems, and other information available to the ERA Recipient. ??. CFR ? 200.303 - Internal controls requires the non-federal entity to establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Questioned Costs: None. Context: . Monthly and Quarterly reports were required to be submitted for both ERA1 and ERA2. Effect: Reports required by the U.S. Treasury were not submitted timely and, accurately, and were not supported by contemporaneously prepared supporting documentation. Information necessary for the U.S. Treasury to calculate the required reallocations was not accurately reported on the quarterly reports submitted.
SD 2022-001: PERIOD OF PERFORMANCE Assistance Listing No. 59.075 Shuttered Venue Operators Grant Program 2022 Funding U.S. Small Business Administration Criteria: The Uniform Guidance specifies that a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance. Guidance is found under Standards for Financial and Program Management (200.309). Recipients of the supplemental award can spend all award funds (both initial and supplemental phase awards) received over an 18-month period after the initial phase award issuance date for eligible and allowable costs incurred between March 1, 2020 and June 30, 2022. Pre-award costs can be charged if they are authorized by the federal awarding agency or pass-through entity (200.458). Additionally, under 2 CFR 200.303, non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with the Uniform Guidance. Condition: Grant funds were disbursed for marketing expenses incurred prior to the start of the funding period without approval of the granting agency. Marketing expenses incurred prior to March 1, 2020 were applied to the grant as they related to producing a theatrical or live performing arts productions that were scheduled to occur during March and April of 2020 but cancelled due to the impacts of COVID-19. Cause: The control did not operate effectively as the reviewer did not have a sufficient understanding of the grant requirements. Perspective: There was initially $9,344 of expenses applied to the grant. Effect: Shuttered venue operators grant funding was applied to expenses incurred outside the period of availability. Prior to the report being filed the Center utilized other expenses that were within the period of availability. Questioned Costs: $0 Recommendation: Only allowable costs incurred during the period of performance should be charged to the federal award. Supporting documentation should be reviewed in conjunction with the grant agreement and other applicable compliance requirements including statutes and uniform reporting requirements for restrictions, limitations, and conditions pertaining to the grant to minimize the amount of disallowed costs. Management Response: Management concurs with the suggestion. Grant personnel has been reminded to review supporting documentation in conjunction with the grant agreement and other applicable compliance requirements including statutes and uniform reporting requirements for restrictions, limitations, and conditions pertaining to the grant to minimize the amount of disallowed costs.
Condition: The District did not have procedures in place to review the reporting required by the grant for accuracy nor for verification of completion of the reporting requirements in a timely manner. Errors were noted in the June 30, 2022 institutional portion report identified as being the final report with all amounts expended at year-end while there was approximately $82,000 remaining to be spent. In addition, it was noted that one of two quarterly reports sampled were uploaded late by three days. Criteria: The U.S. Department of Education requires institutions that received Higher Education Emergency Relief Funds (HEERF) to publicly post certain information accurately on their website related to the student aid and institutional portions of the funds within 10 days of the end of each quarter. 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Effect: By not having a review process in place to verify the reports were accurate and uploaded timely, the reports were not available to the public within the allowed time after quarter-end. Cause: The District had limited employees involved in the disbursement of the HEERF funds resulting in only one person being able to prepare and review the reports. It is unclear why the quarter reviewed was uploaded late. Recommendation: We recommend implementing a process for a secondary review of the reports being prepared as well as a process for verifying reports are uploaded to the website accurately and timely. Views of Responsible Officials and Planned Corrective Action: The District will implement new procedures to verify reports are accurate and uploaded timely in the future.
Condition: The District did not have procedures in place to review the reporting required by the grant for accuracy nor for verification of completion of the reporting requirements in a timely manner. Errors were noted in the June 30, 2022 institutional portion report identified as being the final report with all amounts expended at year-end while there was approximately $82,000 remaining to be spent. In addition, it was noted that one of two quarterly reports sampled were uploaded late by three days. Criteria: The U.S. Department of Education requires institutions that received Higher Education Emergency Relief Funds (HEERF) to publicly post certain information accurately on their website related to the student aid and institutional portions of the funds within 10 days of the end of each quarter. 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Effect: By not having a review process in place to verify the reports were accurate and uploaded timely, the reports were not available to the public within the allowed time after quarter-end. Cause: The District had limited employees involved in the disbursement of the HEERF funds resulting in only one person being able to prepare and review the reports. It is unclear why the quarter reviewed was uploaded late. Recommendation: We recommend implementing a process for a secondary review of the reports being prepared as well as a process for verifying reports are uploaded to the website accurately and timely. Views of Responsible Officials and Planned Corrective Action: The District will implement new procedures to verify reports are accurate and uploaded timely in the future.
Condition: While testing controls, a group of employees were identified that the District missed when completing their triannual procedures related to obtaining time and effort or personnel activity reports from employees paid from grants. Criteria: 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Effect: In this instance, the District performed time and effort and personnel activity reports as a control procedure not specifically required by the grant, due to the type of payroll. This could have been a much more significant issue if it had been associated with certain other grants. Cause: The grant administrator indicated the employees were likely missed due to timing of posting payroll to the project and the reclassification of costs between projects during the year due to changes from the state level associated with accounting for the Education Stabilization Funds. Recommendation: The District should implement and document standardized processes and procedures to identify employees throughout the District who are required to keep time and effort or personnel activity reports during the year. We also recommend general training be completed for all staff regarding this requirement. Views of Responsible Officials and Planned Corrective Action: The District will consider implementation of more standardized requirements associated with time and effort and personnel activity reporting requirements. The District will also consider additional training associated with these requirements for all grant related staff.
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
Federal Program: Child Nutrition Cluster awarded by the U.S. Department of Agriculture under assistance listing numbers 10.553 ? School Breakfast Program (SBP); 10.555 ? National School Lunch Program (NSLP); and 10.559 ? (Summer Food Service Program for Children (SFSP) under award numbers 21N1199 (Federal Award Year 2021) and 22N1099 (Federal Award Year 2022). Passed through the Illinois State Board of Education under award numbers 31045046022A1, 22-4210-00, 22-4210-SC, 21-4210-00, 21-4210-BT, 21-4210-SN, 22-4220-00, 21-4220-00, and 21-4225-00. Condition: The District procured $4,666,376 of food commodities from a vendor without publicizing the procurement opportunity or obtaining sealed bids or competitive proposals. Instead, the District obtained the commodities under a group purchasing agreement through a group purchasing organization in which the District participates. The District also procured $18,797 of goods from a vendor and was unable to provide documentation of how the vendor was selected for the procurement or that the vendor was properly reviewed to determine the vendor was not debarred. Criteria: Uniform Grant Guidance (2 CFR 200.320(b)) states good or services which exceed the simplified acquisition threshold (which in 2022 was $250,000) must be acquired via competitive selection using sealed bids or proposals received in response to a publicized procurement opportunity. The U.S. Department of Agriculture memo SP-05-2017 ?Q&A: Purchasing Goods and Services Using Cooperative Agreements, Agents, and Third-Party Services? states child nutrition program operators must publish procurement opportunities which are over the simplified acquisition threshold for goods available through a group purchasing organization and must evaluate the group purchasing organization?s response compared to those of the other responders. Uniform Grant Guidance (2 CFR 200.320(a)(2)) states if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The District?s procurement policy sets its small purchase threshold at $1,500. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonable ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained. Cause: The District was unaware that procurement through a group purchasing organization would not meet the competitive selection criteria of Uniform Guidance. The District also experienced turnover in its procurement and food services departments which lead to its inability to locate some information. Questioned Cost: The difference between the amount paid and what would have been paid if competitive bids/proposals were received in response to a publicized procurement opportunity for the procurement that exceeded $4 million in response to a publicized procurement opportunity. This amount is not quantifiable. Context: The District made procurements from 50 vendors during fiscal year 2022 that met either the small purchase threshold or the simplified acquisition threshold. The samples tested were not intended to be, and were not, statistically valid samples. Recommendation: We recommend the District review its procurement procedures for when purchases are made with federal funds from group purchasing organizations and retain quotes and other information used when selecting a vendor in the associated procurement file. District?s Response: The District accepts the auditor?s finding and has created a corrective action plan. Potential Effect: Not publicizing procurement opportunities for large purchases could result in the District not receiving the best price available while not retaining documentation of how procurements were awarded and evaluated could lead to the District approving payments to vendors that do not meet federal requirements. (Finding Code No. 2022-001)
2022-001 - Significant Deficiency in Internal Control - Review and Approval of Allowable Costs Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing Number: 93.498 Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: N/A Award Number: N/A Award Year: 2020 and 2021 Compliance Requirement: Allowable Cost/Cost Principles and Activities Allowed or Unallowed Questioned Costs: None noted Criteria: Nonfederal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context: During the testing of expenditures related to increased nurse agency costs and benefits allocation calculations, we observed that for 2 of the 2 calculations tested did not contain a review and approval prior to submission to detect potential errors in the calculations. Effect: The Corporation lacks proper documentation of review with respect to the calculations of increased nurse agency costs and benefits allocations, which could result in errors in these calculations. As a result of the lack of proper documentation of review, noncompliance due to error or fraud could occur without being detected and corrected timely. Cause: The Corporation lacks a formal review policy related to the calculations of increased nurse agency costs and benefits allocations. Recommendation: Management should implement and document a review process for these calculations. View of Responsible Officials: Beginning with reporting period 4, the Organization will begin formally documenting the review of all calculations as part of the submission review process.
Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the District, as a recipient of Federal funds, must establish and maintain effective internal controls 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. In addition, under 2 CFR 200.430, it states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (I) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, (2) be incorporated into the official records of the non-Federal entity, (3) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, and (4) support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award or a federal award and non-Federal award. Condition: During our review of payroll charged to the grant, we noted two employees who did not have documentation to support the distribution of the employee's time spent on grant activities. Cause: Administrative oversight. Effect: The District did not have adequate documentation to support the distribution of the employee's wages paid using grant funds. Questioned Costs: $52,911 Repeat Finding: No Recommendation: We recommend that documentation be retained to support the distribution of salaries and wages for all employees paid using grant funds. Views of Responsible Officials: Management's views and corrective action plan is included at the end of this report.
Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the District, as a recipient of Federal funds, must establish and maintain effective internal controls 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. In addition, under 2 CFR 200.430, it states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must (I) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, (2) be incorporated into the official records of the non-Federal entity, (3) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, and (4) support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award or a federal award and non-Federal award. Condition: During our review of payroll charged to the grant, we noted two employees who did not have documentation to support the distribution of the employee's time spent on grant activities. Cause: Administrative oversight. Effect: The District did not have adequate documentation to support the distribution of the employee's wages paid using grant funds. Questioned Costs: $52,911 Repeat Finding: No Recommendation: We recommend that documentation be retained to support the distribution of salaries and wages for all employees paid using grant funds. Views of Responsible Officials: Management's views and corrective action plan is included at the end of this report.
Department of the Treasury Federal Financial Assistance Listing #21.027 Coronavirus State and Local Fiscal Recovery Funds Reporting Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Health Center does not have an internal control system designed to provide for review and approval of required reporting by an individual separate from the preparer. Cause: The Health Center did not have an internal control process in place to ensure a review and approval of the reports submitted for the federal program by someone other than the preparer of the report Effect: There is a potential risk that the reporting submitted for the federal program could contain errors. Questioned Costs: None reported Context: Sampling was not used Repeat Finding from Prior Years: No Recommendation: We recommend that the Health Center implement a control process which includes a documented secondary review and approval of required reports to be submitted for the federal program prior to submission. Views of Responsible Officials: Management agrees with the finding.
2022-003 Federal Agency: U.S. Department of Education Federal Programs: Title I Grants to Local Education Agencies Assistance Listing Number: 84.010 Federal Award Identification Number and Year: S010A210039 - 2022 Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 2725117.02.201 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Verify that the LEA (Local Educational Agency) maintains appropriate written documentation to support the removal of a student from the regulatory adjusted cohort. 2 CFR 200.303 states 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: For 28 of 40 individuals selected for testing, the School Department could not provide appropriate written documentation. Questioned Costs: None Context: Although the School Department did not have a policy in place in conformity with the federal uniform guidance criteria, the School Department did follow their procedures as it relates to requesting formal documentation for all students who withdrew from the district. Cause: The School Department does not have policies and procedures designed to ensure that appropriate written documentation is maintained for all students who withdraw from the district. Effect: The City?s graduation rate may not be properly calculated. Recommendation: We recommend that the School Department develop policies and procedures to ensure that appropriate written documentation is maintained for all students who withdraw from the district. Views of Responsible Officials: There is no disagreement with the audit finding.
FINDING 2022-002 Subject: Special Education Grants to States - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Number and Year (or Other Identifying Number): 20611-130-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Proportionate share is an amount of funds that must be expended on special education/related services for parentally-placed private school and homeschooled students. The amount to be spent is automatically calculated within each grant application. The School Corporation had not designed, nor implemented, policies and procedures to ensure that the required level of expenditures for non-public students was met for each grant. The Non-Public Proportionate Share expenditures for the 20611-130-PN01 grant were not spent in full, and the School Corporation did not file a waiver which if approved would have allowed the funds to be moved and spent under the regular Part B special education scope. The lack of internal controls and noncompliance were isolated to the 20611-130-PN01 grant award. Criteria 2 CFR 200.303 states in part: "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). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement could result in the loss of future funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Special Education Grants to States - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Number and Year (or Other Identifying Number): 20611-130-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Proportionate share is an amount of funds that must be expended on special education/related services for parentally-placed private school and homeschooled students. The amount to be spent is automatically calculated within each grant application. The School Corporation had not designed, nor implemented, policies and procedures to ensure that the required level of expenditures for non-public students was met for each grant. The Non-Public Proportionate Share expenditures for the 20611-130-PN01 grant were not spent in full, and the School Corporation did not file a waiver which if approved would have allowed the funds to be moved and spent under the regular Part B special education scope. The lack of internal controls and noncompliance were isolated to the 20611-130-PN01 grant award. Criteria 2 CFR 200.303 states in part: "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). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement could result in the loss of future funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the grant agreement and the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001 Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. Eligibility for Title I was determined on the Eligible School Summary of the Title I application. Enrollment and Poverty numbers for the public school district were automatically pulled from Indiana Department of Education's Official Pupil Enrollment count for each school into the Eligible School Summary page of the Title I application. Enrollment and poverty numbers for any non-public schools were manually entered into the application by the School Corporation. These numbers were used to calculate Percent Poverty, which was then used to rank schools for Title I eligibility. The School Corporation had not designed, nor implemented policies and procedures to ensure that the information entered into the Eligible Schools Summary section in the Title I application for non-public schools was accurate. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "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). . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Eligibility compliance requirement. Effect The failure to design and implement a system of internal controls could have enabled noncompliance with the grant agreement and the Eligibility compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the grant agreement and the Eligibility compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-001 Subject: Title I Grants to Local Educational Agencies - Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A190014, S010A200014, S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Condition and Context An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Eligibility compliance requirement. Eligibility for Title I was determined on the Eligible School Summary of the Title I application. Enrollment and Poverty numbers for the public school district were automatically pulled from Indiana Department of Education's Official Pupil Enrollment count for each school into the Eligible School Summary page of the Title I application. Enrollment and poverty numbers for any non-public schools were manually entered into the application by the School Corporation. These numbers were used to calculate Percent Poverty, which was then used to rank schools for Title I eligibility. The School Corporation had not designed, nor implemented policies and procedures to ensure that the information entered into the Eligible Schools Summary section in the Title I application for non-public schools was accurate. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "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). . . ." Cause Management had not designed nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Eligibility compliance requirement. Effect The failure to design and implement a system of internal controls could have enabled noncompliance with the grant agreement and the Eligibility compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure compliance with the grant agreement and the Eligibility compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context An effective internal control system was not designed, nor implemented, at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor's Emergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "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). . . ." Cause Management had not designed, nor implemented, a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to design and implement an effective system of internal controls could have enabled noncompliance with the grant agreement and the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context An effective internal control system was not designed, nor implemented, at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor's Emergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "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). . . ." Cause Management had not designed, nor implemented, a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to design and implement an effective system of internal controls could have enabled noncompliance with the grant agreement and the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context An effective internal control system was not designed, nor implemented, at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor's Emergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "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). . . ." Cause Management had not designed, nor implemented, a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to design and implement an effective system of internal controls could have enabled noncompliance with the grant agreement and the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context An effective internal control system was not designed, nor implemented, at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor's Emergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "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). . . ." Cause Management had not designed, nor implemented, a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to design and implement an effective system of internal controls could have enabled noncompliance with the grant agreement and the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425C200018, S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context An effective internal control system was not designed, nor implemented, at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) and the Governor's Emergency Education Relief (GEER) annual Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "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). . . ." Cause Management had not designed, nor implemented, a system of internal controls that would have ensured compliance with the grant agreement and the Reporting compliance requirement. Effect The failure to design and implement an effective system of internal controls could have enabled noncompliance with the grant agreement and the Reporting compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Significant Deficiency: Identification of the Federal Program: Federal Assistance Listing Number 93.498 US Department of Health and Human Services COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control Over Compliance Reporting Significant Deficiency in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The terms and conditions of the CARES Act Provider Relief Fund (PRF) distributions state that funds are to only be used to prevent, prepare for, and respond to coronavirus, and that funds may only be used for healthcare related expenses or lost revenue that is attributable to the coronavirus. The Health Resources and Services Administration (HRSA) provided guidance on how an organization was to report usage of PRF distributions received. Period 1 and Period 2 reporting required an organization to illustrate how PRF funds received were used. An organization was allowed to include eligible expenditures from January 1, 2020 through December 31, 2021 depending on the period reporting. Condition: During the process of identifying expenses that were incurred to prevent, prepare for, or respond to the coronavirus pandemic, management included expenses incurred which were not related to preparing, preventing, or responding to coronavirus. Cause: Mosaic?s internal control processes did not ensure that eligible expenses followed applicable reporting guidance. Due to the amount of detailed information that was required to be compiled by management in order to enter data into the PRF reporting portal, management inadvertently included in eligible expenses amounts unrelated to preparing, preventing, and responding to the coronavirus. Effect: Management included amounts in the PRF reporting portal for expenditures which were not eligible based on the terms and conditions of the PRF distributions and subsequent HRSA guidance. Questioned Costs: None reported. Context: A nonstatistical sample of 60 transactions out of 3,016 total transactions were selected for testing, which accounted for $242,622 of $4,693,960 of federal program expenditures. Recommendation: We recommend that management continue to monitor and enhance its internal controls over federal award compliance to ensure that only eligible costs are included in reporting. Views of Responsible Officials: Management agrees with the noted finding. However, Mosaic also incurred and reported unreimbursed expenses attributable to coronavirus of $3,530,376 which could be used to replace the identified costs unrelated to coronavirus. Management will continue to refine its processes to more diligently review expenditures to ensure only those eligible costs incurred are included in future reporting.