Program: Community Development Block Grants (CDBG)/Entitlement Grants Cluster Federal Financial Assistance Listing No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Reporting Grant Award Number: All Type of Finding: Instances of Noncompliance, Material Weakness 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain Federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subaward equal to or greater than $30,000. Condition Found: As a result of our audit procedures, we noted that 3 out of 5 first tier sub-awards tested were not reported in the FFATA Subaward Reporting System (FSRS), totaling $966,768 in exceptions noted to sub-awardees. Cause: The County did not have internal controls to ensure sub-award information was submitted in accordance with FFATA. In addition, the County did not have proper segregation of duties over the preparation and review of program related performance reports. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: None reported. Context/Sampling: For the FFATA reports, a nonstatistical sample of 5 subawards out of 30 sub-awards were tested. Exceptions were taken for 3 out of the 5 subawards for not having been submitted in accordance with FFATA. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 5 $2,268,972 Not Reported 2 $888,941 Not Timely 3 $966,768 Obligation Incorrect 2 $888,941 Missing Key Elements 2 $888,941 Repeat Finding from Prior Year(s): Yes, prior year finding 2021-012. Recommendation: We recommend that the County implement policies and procedures to ensure compliance with the program?s special FFATA reporting requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Community Development Block Grants (CDBG)/Entitlement Grants Cluster Federal Financial Assistance Listing No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Reporting Grant Award Number: All Type of Finding: Instances of Noncompliance, Material Weakness 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain Federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subaward equal to or greater than $30,000. Condition Found: As a result of our audit procedures, we noted that 3 out of 5 first tier sub-awards tested were not reported in the FFATA Subaward Reporting System (FSRS), totaling $966,768 in exceptions noted to sub-awardees. Cause: The County did not have internal controls to ensure sub-award information was submitted in accordance with FFATA. In addition, the County did not have proper segregation of duties over the preparation and review of program related performance reports. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: None reported. Context/Sampling: For the FFATA reports, a nonstatistical sample of 5 subawards out of 30 sub-awards were tested. Exceptions were taken for 3 out of the 5 subawards for not having been submitted in accordance with FFATA. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 5 $2,268,972 Not Reported 2 $888,941 Not Timely 3 $966,768 Obligation Incorrect 2 $888,941 Missing Key Elements 2 $888,941 Repeat Finding from Prior Year(s): Yes, prior year finding 2021-012. Recommendation: We recommend that the County implement policies and procedures to ensure compliance with the program?s special FFATA reporting requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Community Development Block Grants (CDBG)/Entitlement Grants Cluster Federal Financial Assistance Listing No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Reporting Grant Award Number: All Type of Finding: Instances of Noncompliance, Material Weakness 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain Federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subaward equal to or greater than $30,000. Condition Found: As a result of our audit procedures, we noted that 3 out of 5 first tier sub-awards tested were not reported in the FFATA Subaward Reporting System (FSRS), totaling $966,768 in exceptions noted to sub-awardees. Cause: The County did not have internal controls to ensure sub-award information was submitted in accordance with FFATA. In addition, the County did not have proper segregation of duties over the preparation and review of program related performance reports. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: None reported. Context/Sampling: For the FFATA reports, a nonstatistical sample of 5 subawards out of 30 sub-awards were tested. Exceptions were taken for 3 out of the 5 subawards for not having been submitted in accordance with FFATA. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 5 $2,268,972 Not Reported 2 $888,941 Not Timely 3 $966,768 Obligation Incorrect 2 $888,941 Missing Key Elements 2 $888,941 Repeat Finding from Prior Year(s): Yes, prior year finding 2021-012. Recommendation: We recommend that the County implement policies and procedures to ensure compliance with the program?s special FFATA reporting requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Community Development Block Grants (CDBG)/Entitlement Grants Cluster Federal Financial Assistance Listing No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Reporting Grant Award Number: All Type of Finding: Instances of Noncompliance, Material Weakness 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain Federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subaward equal to or greater than $30,000. Condition Found: As a result of our audit procedures, we noted that 3 out of 5 first tier sub-awards tested were not reported in the FFATA Subaward Reporting System (FSRS), totaling $966,768 in exceptions noted to sub-awardees. Cause: The County did not have internal controls to ensure sub-award information was submitted in accordance with FFATA. In addition, the County did not have proper segregation of duties over the preparation and review of program related performance reports. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: None reported. Context/Sampling: For the FFATA reports, a nonstatistical sample of 5 subawards out of 30 sub-awards were tested. Exceptions were taken for 3 out of the 5 subawards for not having been submitted in accordance with FFATA. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 5 $2,268,972 Not Reported 2 $888,941 Not Timely 3 $966,768 Obligation Incorrect 2 $888,941 Missing Key Elements 2 $888,941 Repeat Finding from Prior Year(s): Yes, prior year finding 2021-012. Recommendation: We recommend that the County implement policies and procedures to ensure compliance with the program?s special FFATA reporting requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Community Development Block Grants (CDBG)/Entitlement Grants Cluster Federal Financial Assistance Listing No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Reporting Grant Award Number: All Type of Finding: Instances of Noncompliance, Material Weakness 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain Federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subaward equal to or greater than $30,000. Condition Found: As a result of our audit procedures, we noted that 3 out of 5 first tier sub-awards tested were not reported in the FFATA Subaward Reporting System (FSRS), totaling $966,768 in exceptions noted to sub-awardees. Cause: The County did not have internal controls to ensure sub-award information was submitted in accordance with FFATA. In addition, the County did not have proper segregation of duties over the preparation and review of program related performance reports. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: None reported. Context/Sampling: For the FFATA reports, a nonstatistical sample of 5 subawards out of 30 sub-awards were tested. Exceptions were taken for 3 out of the 5 subawards for not having been submitted in accordance with FFATA. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 5 $2,268,972 Not Reported 2 $888,941 Not Timely 3 $966,768 Obligation Incorrect 2 $888,941 Missing Key Elements 2 $888,941 Repeat Finding from Prior Year(s): Yes, prior year finding 2021-012. Recommendation: We recommend that the County implement policies and procedures to ensure compliance with the program?s special FFATA reporting requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Community Development Block Grants (CDBG)/Entitlement Grants Cluster Federal Financial Assistance Listing No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Reporting Grant Award Number: All Type of Finding: Instances of Noncompliance, Material Weakness 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain Federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subaward equal to or greater than $30,000. Condition Found: As a result of our audit procedures, we noted that 3 out of 5 first tier sub-awards tested were not reported in the FFATA Subaward Reporting System (FSRS), totaling $966,768 in exceptions noted to sub-awardees. Cause: The County did not have internal controls to ensure sub-award information was submitted in accordance with FFATA. In addition, the County did not have proper segregation of duties over the preparation and review of program related performance reports. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: None reported. Context/Sampling: For the FFATA reports, a nonstatistical sample of 5 subawards out of 30 sub-awards were tested. Exceptions were taken for 3 out of the 5 subawards for not having been submitted in accordance with FFATA. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 5 $2,268,972 Not Reported 2 $888,941 Not Timely 3 $966,768 Obligation Incorrect 2 $888,941 Missing Key Elements 2 $888,941 Repeat Finding from Prior Year(s): Yes, prior year finding 2021-012. Recommendation: We recommend that the County implement policies and procedures to ensure compliance with the program?s special FFATA reporting requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Community Development Block Grants (CDBG)/Entitlement Grants Cluster Federal Financial Assistance Listing No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Reporting Grant Award Number: All Type of Finding: Instances of Noncompliance, Material Weakness 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain Federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subaward equal to or greater than $30,000. Condition Found: As a result of our audit procedures, we noted that 3 out of 5 first tier sub-awards tested were not reported in the FFATA Subaward Reporting System (FSRS), totaling $966,768 in exceptions noted to sub-awardees. Cause: The County did not have internal controls to ensure sub-award information was submitted in accordance with FFATA. In addition, the County did not have proper segregation of duties over the preparation and review of program related performance reports. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: None reported. Context/Sampling: For the FFATA reports, a nonstatistical sample of 5 subawards out of 30 sub-awards were tested. Exceptions were taken for 3 out of the 5 subawards for not having been submitted in accordance with FFATA. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 5 $2,268,972 Not Reported 2 $888,941 Not Timely 3 $966,768 Obligation Incorrect 2 $888,941 Missing Key Elements 2 $888,941 Repeat Finding from Prior Year(s): Yes, prior year finding 2021-012. Recommendation: We recommend that the County implement policies and procedures to ensure compliance with the program?s special FFATA reporting requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Community Development Block Grants (CDBG)/Entitlement Grants Cluster Federal Financial Assistance Listing No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Reporting Grant Award Number: All Type of Finding: Instances of Noncompliance, Material Weakness 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain Federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subaward equal to or greater than $30,000. Condition Found: As a result of our audit procedures, we noted that 3 out of 5 first tier sub-awards tested were not reported in the FFATA Subaward Reporting System (FSRS), totaling $966,768 in exceptions noted to sub-awardees. Cause: The County did not have internal controls to ensure sub-award information was submitted in accordance with FFATA. In addition, the County did not have proper segregation of duties over the preparation and review of program related performance reports. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: None reported. Context/Sampling: For the FFATA reports, a nonstatistical sample of 5 subawards out of 30 sub-awards were tested. Exceptions were taken for 3 out of the 5 subawards for not having been submitted in accordance with FFATA. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 5 $2,268,972 Not Reported 2 $888,941 Not Timely 3 $966,768 Obligation Incorrect 2 $888,941 Missing Key Elements 2 $888,941 Repeat Finding from Prior Year(s): Yes, prior year finding 2021-012. Recommendation: We recommend that the County implement policies and procedures to ensure compliance with the program?s special FFATA reporting requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Community Development Block Grants (CDBG)/Entitlement Grants Cluster Federal Financial Assistance Listing No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Reporting Grant Award Number: All Type of Finding: Instances of Noncompliance, Material Weakness 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain Federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subaward equal to or greater than $30,000. Condition Found: As a result of our audit procedures, we noted that 3 out of 5 first tier sub-awards tested were not reported in the FFATA Subaward Reporting System (FSRS), totaling $966,768 in exceptions noted to sub-awardees. Cause: The County did not have internal controls to ensure sub-award information was submitted in accordance with FFATA. In addition, the County did not have proper segregation of duties over the preparation and review of program related performance reports. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: None reported. Context/Sampling: For the FFATA reports, a nonstatistical sample of 5 subawards out of 30 sub-awards were tested. Exceptions were taken for 3 out of the 5 subawards for not having been submitted in accordance with FFATA. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 5 $2,268,972 Not Reported 2 $888,941 Not Timely 3 $966,768 Obligation Incorrect 2 $888,941 Missing Key Elements 2 $888,941 Repeat Finding from Prior Year(s): Yes, prior year finding 2021-012. Recommendation: We recommend that the County implement policies and procedures to ensure compliance with the program?s special FFATA reporting requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Community Development Block Grants (CDBG)/Entitlement Grants Cluster Federal Financial Assistance Listing No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Reporting Grant Award Number: All Type of Finding: Instances of Noncompliance, Material Weakness 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain Federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subaward equal to or greater than $30,000. Condition Found: As a result of our audit procedures, we noted that 3 out of 5 first tier sub-awards tested were not reported in the FFATA Subaward Reporting System (FSRS), totaling $966,768 in exceptions noted to sub-awardees. Cause: The County did not have internal controls to ensure sub-award information was submitted in accordance with FFATA. In addition, the County did not have proper segregation of duties over the preparation and review of program related performance reports. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: None reported. Context/Sampling: For the FFATA reports, a nonstatistical sample of 5 subawards out of 30 sub-awards were tested. Exceptions were taken for 3 out of the 5 subawards for not having been submitted in accordance with FFATA. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 5 $2,268,972 Not Reported 2 $888,941 Not Timely 3 $966,768 Obligation Incorrect 2 $888,941 Missing Key Elements 2 $888,941 Repeat Finding from Prior Year(s): Yes, prior year finding 2021-012. Recommendation: We recommend that the County implement policies and procedures to ensure compliance with the program?s special FFATA reporting requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Community Development Block Grants (CDBG)/Entitlement Grants Cluster Federal Financial Assistance Listing No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Reporting Grant Award Number: All Type of Finding: Instances of Noncompliance, Material Weakness 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain Federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subaward equal to or greater than $30,000. Condition Found: As a result of our audit procedures, we noted that 3 out of 5 first tier sub-awards tested were not reported in the FFATA Subaward Reporting System (FSRS), totaling $966,768 in exceptions noted to sub-awardees. Cause: The County did not have internal controls to ensure sub-award information was submitted in accordance with FFATA. In addition, the County did not have proper segregation of duties over the preparation and review of program related performance reports. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: None reported. Context/Sampling: For the FFATA reports, a nonstatistical sample of 5 subawards out of 30 sub-awards were tested. Exceptions were taken for 3 out of the 5 subawards for not having been submitted in accordance with FFATA. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 5 $2,268,972 Not Reported 2 $888,941 Not Timely 3 $966,768 Obligation Incorrect 2 $888,941 Missing Key Elements 2 $888,941 Repeat Finding from Prior Year(s): Yes, prior year finding 2021-012. Recommendation: We recommend that the County implement policies and procedures to ensure compliance with the program?s special FFATA reporting requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Community Development Block Grants (CDBG)/Entitlement Grants Cluster Federal Financial Assistance Listing No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Reporting Grant Award Number: All Type of Finding: Instances of Noncompliance, Material Weakness 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain Federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subaward equal to or greater than $30,000. Condition Found: As a result of our audit procedures, we noted that 3 out of 5 first tier sub-awards tested were not reported in the FFATA Subaward Reporting System (FSRS), totaling $966,768 in exceptions noted to sub-awardees. Cause: The County did not have internal controls to ensure sub-award information was submitted in accordance with FFATA. In addition, the County did not have proper segregation of duties over the preparation and review of program related performance reports. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: None reported. Context/Sampling: For the FFATA reports, a nonstatistical sample of 5 subawards out of 30 sub-awards were tested. Exceptions were taken for 3 out of the 5 subawards for not having been submitted in accordance with FFATA. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 5 $2,268,972 Not Reported 2 $888,941 Not Timely 3 $966,768 Obligation Incorrect 2 $888,941 Missing Key Elements 2 $888,941 Repeat Finding from Prior Year(s): Yes, prior year finding 2021-012. Recommendation: We recommend that the County implement policies and procedures to ensure compliance with the program?s special FFATA reporting requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: Community Development Block Grants (CDBG)/Entitlement Grants Cluster Federal Financial Assistance Listing No.: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: N/A Award Year: 2021-2022 Compliance Requirement: Reporting Grant Award Number: All Type of Finding: Instances of Noncompliance, Material Weakness 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain Federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subaward equal to or greater than $30,000. Condition Found: As a result of our audit procedures, we noted that 3 out of 5 first tier sub-awards tested were not reported in the FFATA Subaward Reporting System (FSRS), totaling $966,768 in exceptions noted to sub-awardees. Cause: The County did not have internal controls to ensure sub-award information was submitted in accordance with FFATA. In addition, the County did not have proper segregation of duties over the preparation and review of program related performance reports. Effect: The lack of adequate policies governing report preparation and submission resulted in FFATA special reports not being filed as required by the program. Questioned Costs: None reported. Context/Sampling: For the FFATA reports, a nonstatistical sample of 5 subawards out of 30 sub-awards were tested. Exceptions were taken for 3 out of the 5 subawards for not having been submitted in accordance with FFATA. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 5 $2,268,972 Not Reported 2 $888,941 Not Timely 3 $966,768 Obligation Incorrect 2 $888,941 Missing Key Elements 2 $888,941 Repeat Finding from Prior Year(s): Yes, prior year finding 2021-012. Recommendation: We recommend that the County implement policies and procedures to ensure compliance with the program?s special FFATA reporting requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases, (ELC) Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Year: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment Grant Award Number: COVID-19 ELC39 and COVID-19 ELC97 Type of Finding: Material Noncompliance, Material Weakness in Internal Control over Compliance Criteria: Procurement: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: ? Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors? performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. ? Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. ? Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements [Davis-Bacon Act]). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). ? For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). ? Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). ? Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, ?Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.? Suspension and Debarment: 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) and available at SAM.gov/Home, (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). Condition Found: As a result of our audit procedures, we noted the following: Procurement: ? 4 out of 8 transactions tested did not have documentation that full and open competition, price analysis, or rationale to limit competition in those cases where competition was limited. ? 2 out of 8 transactions tested did not have documentation of the rationale for the method of procurement, selection of contract type, basis for contractor selection and the basis for the contract price in accordance with the Uniform Guidance, section 318(i) and 48 CFR part 44 and section 52.244-2. ? 8 out of 8 did not include the applicable provisions required by Appendix II to 2 CFR Part 200. Suspension and Debarment: ? 6 out of 8 covered transactions tested did not have evidence that management checked for suspension and debarment during the scope of this audit; by management either not verifying the SAM?s.gov website, not obtaining a certification, or not adding a clause or condition to the covered transaction. Cause: Not following the County?s own official policies and procedures over procurement and suspension and debarment. Effect: Not following the County?s procurement policies and procedures that are in place and required by the Uniform Guidance resulted in noncompliance with the requirements of the program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 vendor contracts from a population of 38 were tested totaling $1,670,639 out of $9,5334,251 of federal program expenditures. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-009. Recommendation: We recommend that the County enforce its official policies and procedures over procurement and suspension and debarment. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases, (ELC) Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Year: 2021-2022 Compliance Requirement: Procurement and Suspension and Debarment Grant Award Number: COVID-19 ELC39 and COVID-19 ELC97 Type of Finding: Material Noncompliance, Material Weakness in Internal Control over Compliance Criteria: Procurement: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-federal entity must: ? Meet the general procurement standards in 2 CFR section 200.318, which include oversight of contractors? performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. ? Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. ? Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) (1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements [Davis-Bacon Act]). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b)). ? For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR section 200.320(b); the competitive proposals method under the conditions specified in 2 CFR section 200.320((b) (2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR section 200.320(c)). ? Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR section 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR section 200.323(b)). ? Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR section 200.326. These provisions are described in Appendix II to 2 CFR Part 200, ?Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.? Suspension and Debarment: 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) and available at SAM.gov/Home, (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). Condition Found: As a result of our audit procedures, we noted the following: Procurement: ? 4 out of 8 transactions tested did not have documentation that full and open competition, price analysis, or rationale to limit competition in those cases where competition was limited. ? 2 out of 8 transactions tested did not have documentation of the rationale for the method of procurement, selection of contract type, basis for contractor selection and the basis for the contract price in accordance with the Uniform Guidance, section 318(i) and 48 CFR part 44 and section 52.244-2. ? 8 out of 8 did not include the applicable provisions required by Appendix II to 2 CFR Part 200. Suspension and Debarment: ? 6 out of 8 covered transactions tested did not have evidence that management checked for suspension and debarment during the scope of this audit; by management either not verifying the SAM?s.gov website, not obtaining a certification, or not adding a clause or condition to the covered transaction. Cause: Not following the County?s own official policies and procedures over procurement and suspension and debarment. Effect: Not following the County?s procurement policies and procedures that are in place and required by the Uniform Guidance resulted in noncompliance with the requirements of the program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 8 vendor contracts from a population of 38 were tested totaling $1,670,639 out of $9,5334,251 of federal program expenditures. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-009. Recommendation: We recommend that the County enforce its official policies and procedures over procurement and suspension and debarment. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separate corrective action plan.
2022?001 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Fund CFDA Numbers: 84.425 Higher Education Emergency Relief Fund Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: Noncompliance with institutional reporting requirements under HEERF. Questioned costs: None Context: CLA noted that lost revenue was included twice on the March 31, 2022, institutional quarterly report; once in the Replacing lost revenue from academic sources category, and also included in the Other uses of (a)(1) Institutional Portion Funds category. Cause: The University?s policies and procedures did not comply with the reporting requirements under HEERF. Effect: Inaccurate reporting of certain information as noted in the Context above. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate reporting. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
2022?001 Higher Education Emergency Relief Fund (HEERF) Reporting Federal Agency: Department of Education Federal Program: Higher Education Emergency Relief Fund CFDA Numbers: 84.425 Higher Education Emergency Relief Fund Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Other Matters Finding Related to Compliance and Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.303, non-Federal entities receiving Federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. Condition: Noncompliance with institutional reporting requirements under HEERF. Questioned costs: None Context: CLA noted that lost revenue was included twice on the March 31, 2022, institutional quarterly report; once in the Replacing lost revenue from academic sources category, and also included in the Other uses of (a)(1) Institutional Portion Funds category. Cause: The University?s policies and procedures did not comply with the reporting requirements under HEERF. Effect: Inaccurate reporting of certain information as noted in the Context above. Repeat Finding: No. Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate reporting. Views of responsible officials and planned corrective actions: See Corrective Action Pan prepared by the University.
Criteria or Specific Requirement: Compliance ? Per Federal Register Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees dated 5/13/21, institutions are required to submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from the HEERF. The Department further requires institutions to post all quarterly reports to their website in a publicly accessible location. Internal 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 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: Various errors were noted in reports either due to inaccurate or missing information, timeliness of reporting, and record retention requirements. Questioned Costs: None Context: Out of 4 quarterly student reports, 2 quarterly institutional reports, and 1 annual report selected for testing, the following reporting errors were identified: Type of Report Time Period for Reporting Specific Condition(s) Related to Inaccurate or Missing Information Quarterly Student June 2021 Missing required elements #1 and #4. Quarterly Student March 2022 Missing required elements #1 and #4. Quarterly Institutional September 2021 Improperly reported zero expenditures for the quarter. Related to Timeliness of Reporting Quarterly Student June 2021 Report not posted timely (Due 10 days after quarter-end, posted 8/26/21) Quarterly Student March 2022 Report not posted timely (Due 10 days after quarter-end, posted 4/11/22) Quarterly Institutional September 2021 Report not posted timely (Due 10 days after quarter-end, posted 10/19/21) Annual Report Annual Report not submitted timely (Due 5/6/22, submitted 5/11/22) Related to Other Conditions Quarterly Student September 2021 Quarterly report missing from website Quarterly Student December 2021 Quarterly report missing from website Cause: The College did not have appropriate controls in place to ensure documentation was maintained and retention requirements were met. Effect: The institution is not meeting the reporting and information-sharing requirements determined by the Department of Education. As a result, the institution may be subject to additional enforcement actions by the Department of Education including a delay in funding for additional HEERF programs and possibly being determined ineligible for other program funding. Repeat Finding: Yes, prior year finding 2021-001. Recommendation: We recommend the College review the reporting requirements and implement procedures to ensure that all required reports are issued/posted in an accurate and timely manner. Views of Responsible Officials: There is no disagreement with the audit finding.
Criteria or Specific Requirement: Compliance ? Per Federal Register Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees dated 5/13/21, institutions are required to submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from the HEERF. The Department further requires institutions to post all quarterly reports to their website in a publicly accessible location. Internal 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 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: Various errors were noted in reports either due to inaccurate or missing information, timeliness of reporting, and record retention requirements. Questioned Costs: None Context: Out of 4 quarterly student reports, 2 quarterly institutional reports, and 1 annual report selected for testing, the following reporting errors were identified: Type of Report Time Period for Reporting Specific Condition(s) Related to Inaccurate or Missing Information Quarterly Student June 2021 Missing required elements #1 and #4. Quarterly Student March 2022 Missing required elements #1 and #4. Quarterly Institutional September 2021 Improperly reported zero expenditures for the quarter. Related to Timeliness of Reporting Quarterly Student June 2021 Report not posted timely (Due 10 days after quarter-end, posted 8/26/21) Quarterly Student March 2022 Report not posted timely (Due 10 days after quarter-end, posted 4/11/22) Quarterly Institutional September 2021 Report not posted timely (Due 10 days after quarter-end, posted 10/19/21) Annual Report Annual Report not submitted timely (Due 5/6/22, submitted 5/11/22) Related to Other Conditions Quarterly Student September 2021 Quarterly report missing from website Quarterly Student December 2021 Quarterly report missing from website Cause: The College did not have appropriate controls in place to ensure documentation was maintained and retention requirements were met. Effect: The institution is not meeting the reporting and information-sharing requirements determined by the Department of Education. As a result, the institution may be subject to additional enforcement actions by the Department of Education including a delay in funding for additional HEERF programs and possibly being determined ineligible for other program funding. Repeat Finding: Yes, prior year finding 2021-001. Recommendation: We recommend the College review the reporting requirements and implement procedures to ensure that all required reports are issued/posted in an accurate and timely manner. Views of Responsible Officials: There is no disagreement with the audit finding.
FINDING 2022-002 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-009-PN01, 21611-009-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation is a member of the Exceptional Children's Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. There was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The non-public proportionate share expenditures for the 20611-009-PN01 and 21611-009-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The non-public proportionate share expenditures were determined by applying a percentage to the non-public school budgeted expenditures. These were the amounts reported to the IDOE. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance was isolated to the 20611-009-PN01 and 21611-009-PN01 grant awards. 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 The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreements and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with 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 Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-009-PN01, 21611-009-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation is a member of the Exceptional Children's Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. There was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The non-public proportionate share expenditures for the 20611-009-PN01 and 21611-009-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The non-public proportionate share expenditures were determined by applying a percentage to the non-public school budgeted expenditures. These were the amounts reported to the IDOE. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance was isolated to the 20611-009-PN01 and 21611-009-PN01 grant awards. 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 The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreements and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with 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 2022-003 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had four annual data reports due during the audit period. All four reports were submitted as required; however, none of the reports were supported by the School Corporation's records. The Elementary and Secondary School Emergency Relief (ESSER I), the Elementary and Secondary School Emergency Relief (ESSER II), and the American Rescue Plan-Elementary and Secondary School Emergency Relief (ARP ESSER), year 1 annual data reports overstated total expenditures made during the reporting period. The ESSER I, year 2 annual data report understated total expenditures made during the reporting period. The lack of internal controls and noncompliance were systemic issues 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). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not developed a system of internal controls that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with 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 Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had four annual data reports due during the audit period. All four reports were submitted as required; however, none of the reports were supported by the School Corporation's records. The Elementary and Secondary School Emergency Relief (ESSER I), the Elementary and Secondary School Emergency Relief (ESSER II), and the American Rescue Plan-Elementary and Secondary School Emergency Relief (ARP ESSER), year 1 annual data reports overstated total expenditures made during the reporting period. The ESSER I, year 2 annual data report understated total expenditures made during the reporting period. The lack of internal controls and noncompliance were systemic issues 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). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not developed a system of internal controls that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with 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 Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had four annual data reports due during the audit period. All four reports were submitted as required; however, none of the reports were supported by the School Corporation's records. The Elementary and Secondary School Emergency Relief (ESSER I), the Elementary and Secondary School Emergency Relief (ESSER II), and the American Rescue Plan-Elementary and Secondary School Emergency Relief (ARP ESSER), year 1 annual data reports overstated total expenditures made during the reporting period. The ESSER I, year 2 annual data report understated total expenditures made during the reporting period. The lack of internal controls and noncompliance were systemic issues 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). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?? 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause Management had not developed a system of internal controls that would have ensured compliance with the Reporting compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Reporting compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance and comply with 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 2022-002 Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion 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 Special Tests and Provisions - Wage Rate Requirements. INDIANA STATE BOARD OF ACCOUNTS 18 FRANKTON-LAPEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation did not have adequate policies or procedures to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. For the one contract, with the Masonry by M&S for $110,12, tested, the required prevailing wage rate clause was not included in the contract, nor were certified payrolls submitted by the contractor. The lack of internal controls and noncompliance were systemic issues 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). . . ." 29 CFR 5.5 states in part: "(a) The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in ? 5.1, the following clauses . . . (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics. . . . INDIANA STATE BOARD OF ACCOUNTS 19 FRANKTON-LAPEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) Payrolls and basic records. . . . (ii)(A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). . . ." 2 CFR 200 Appendix II states in part: "In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non- Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, 'Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction'). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. . . ." Cause Management had not designed, nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect The failure to establish an effective internal control system prevented the determination of the School Corporation's compliance with the Special Tests and Provisions - Wage Rate Requirements 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 and comply with the grant agreement and the Special Tests and Provisions - Wage Rate 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: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion 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 Special Tests and Provisions - Wage Rate Requirements. INDIANA STATE BOARD OF ACCOUNTS 18 FRANKTON-LAPEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation did not have adequate policies or procedures to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. For the one contract, with the Masonry by M&S for $110,12, tested, the required prevailing wage rate clause was not included in the contract, nor were certified payrolls submitted by the contractor. The lack of internal controls and noncompliance were systemic issues 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). . . ." 29 CFR 5.5 states in part: "(a) The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in ? 5.1, the following clauses . . . (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics. . . . INDIANA STATE BOARD OF ACCOUNTS 19 FRANKTON-LAPEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) Payrolls and basic records. . . . (ii)(A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). . . ." 2 CFR 200 Appendix II states in part: "In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non- Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, 'Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction'). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. . . ." Cause Management had not designed, nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect The failure to establish an effective internal control system prevented the determination of the School Corporation's compliance with the Special Tests and Provisions - Wage Rate Requirements 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 and comply with the grant agreement and the Special Tests and Provisions - Wage Rate 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: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion 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 Special Tests and Provisions - Wage Rate Requirements. INDIANA STATE BOARD OF ACCOUNTS 18 FRANKTON-LAPEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation did not have adequate policies or procedures to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. For the one contract, with the Masonry by M&S for $110,12, tested, the required prevailing wage rate clause was not included in the contract, nor were certified payrolls submitted by the contractor. The lack of internal controls and noncompliance were systemic issues 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). . . ." 29 CFR 5.5 states in part: "(a) The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in ? 5.1, the following clauses . . . (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics. . . . INDIANA STATE BOARD OF ACCOUNTS 19 FRANKTON-LAPEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) Payrolls and basic records. . . . (ii)(A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). . . ." 2 CFR 200 Appendix II states in part: "In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non- Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, 'Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction'). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. . . ." Cause Management had not designed, nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect The failure to establish an effective internal control system prevented the determination of the School Corporation's compliance with the Special Tests and Provisions - Wage Rate Requirements 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 and comply with the grant agreement and the Special Tests and Provisions - Wage Rate 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: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Modified Opinion 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 Special Tests and Provisions - Wage Rate Requirements. INDIANA STATE BOARD OF ACCOUNTS 18 FRANKTON-LAPEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation did not have adequate policies or procedures to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. For the one contract, with the Masonry by M&S for $110,12, tested, the required prevailing wage rate clause was not included in the contract, nor were certified payrolls submitted by the contractor. The lack of internal controls and noncompliance were systemic issues 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). . . ." 29 CFR 5.5 states in part: "(a) The Agency head shall cause or require the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part from Federal funds or in accordance with guarantees of a Federal agency or financed from funds obtained by pledge of any contract of a Federal agency to make a loan, grant or annual contribution (except where a different meaning is expressly indicated), and which is subject to the labor standards provisions of any of the acts listed in ? 5.1, the following clauses . . . (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics. . . . INDIANA STATE BOARD OF ACCOUNTS 19 FRANKTON-LAPEL COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (3) Payrolls and basic records. . . . (ii)(A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). . . ." 2 CFR 200 Appendix II states in part: "In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non- Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, 'Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction'). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. . . ." Cause Management had not designed, nor implemented a system of internal controls that would have ensured compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect The failure to establish an effective internal control system prevented the determination of the School Corporation's compliance with the Special Tests and Provisions - Wage Rate Requirements 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 and comply with the grant agreement and the Special Tests and Provisions - Wage Rate compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children?. The Act further states that the ?Indian tribe or tribal organization may employ individuals in those positions only if the individuals? meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children?. The Act further states that the ?Indian tribe or tribal organization may employ individuals in those positions only if the individuals? meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children?. The Act further states that the ?Indian tribe or tribal organization may employ individuals in those positions only if the individuals? meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children?. The Act further states that the ?Indian tribe or tribal organization may employ individuals in those positions only if the individuals? meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children?. The Act further states that the ?Indian tribe or tribal organization may employ individuals in those positions only if the individuals? meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children?. The Act further states that the ?Indian tribe or tribal organization may employ individuals in those positions only if the individuals? meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children?. The Act further states that the ?Indian tribe or tribal organization may employ individuals in those positions only if the individuals? meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children?. The Act further states that the ?Indian tribe or tribal organization may employ individuals in those positions only if the individuals? meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children?. The Act further states that the ?Indian tribe or tribal organization may employ individuals in those positions only if the individuals? meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 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. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children?. The Act further states that the ?Indian tribe or tribal organization may employ individuals in those positions only if the individuals? meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
FINDING 2022-002 Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-021-PN01, 20611-021PN01, 20619-021-PN01, 21611-021-N01, 21619-021-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition and Context The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal year 2020-2021, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. The Cooperative was a planning district whose purpose was to provide free appropriate public education to students identified as disabled in accordance with state statute who were legal residents and/or have been accepted through means of open enrollment, or other legal means of transfer to the participating member school corporations in Tippecanoe County. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. The Cooperative did not have adequate internal controls in place to ensure all activities and costs were allowed. One Cooperative employee prepared the payroll benefit disbursements without oversight or review. The lack of internal controls was isolated to the 2020-2021 fiscal year. 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 The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective internal controls system placed the School Corporation at risk of noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. 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: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-021-PN01, 20611-021-PN01, 20619-021-PN01, 21611-021-PN01, 21619-021-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 19 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal year 2020-2021, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. The Cooperative was a planning district whose purpose was to provide free appropriate public education to students identified as disabled in accordance with state statute who were legal residents and/or have been accepted through means of open enrollment, or other legal means of transfer to the participating member school corporations in Tippecanoe County. The School Corporation did not have internal controls in place to ensure compliance with the suspension and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure all applicable vendors were not suspended or debarred. Therefore, vendors with contracts over $25,000 were not verified to ensure they were not excluded or disqualified from participation in federal awards programs. The lack of effective internal controls and noncompliance were systemic issues isolated to the 2020-2021 fiscal year. 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 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." INDIANA STATE BOARD OF ACCOUNTS 20 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could have resulted in the loss of federal 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 Procurement and Suspension and Debarment 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 2022-004 Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-021-PN01, 20611-21-PN01, 20619-21-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2020-2021 and 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The Cooperative was a planning district whose purpose was to provide free appropriate public education to students identified as disabled in accordance with state statute who were legal residents and/or have been accepted through means of open enrollment, or other legal means of transfer to the participating member school corporations in Tippecanoe County. INDIANA STATE BOARD OF ACCOUNTS 21 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 19611-21-PN01, 20611-21-PN01, and 20619-21-PN01 grant awards could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools on a percentage basis. These allocations were the amounts reported to the IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance were isolated to the 19611-21-PN01, 20611-21-PN01, and 20619-21-PN01 grant awards. 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 The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 22 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with 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 2022-004 Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-021-PN01, 20611-21-PN01, 20619-21-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2020-2021 and 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The Cooperative was a planning district whose purpose was to provide free appropriate public education to students identified as disabled in accordance with state statute who were legal residents and/or have been accepted through means of open enrollment, or other legal means of transfer to the participating member school corporations in Tippecanoe County. INDIANA STATE BOARD OF ACCOUNTS 21 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 19611-21-PN01, 20611-21-PN01, and 20619-21-PN01 grant awards could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools on a percentage basis. These allocations were the amounts reported to the IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance were isolated to the 19611-21-PN01, 20611-21-PN01, and 20619-21-PN01 grant awards. 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 The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 22 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with 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 Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-021-PN01, 20611-021PN01, 20619-021-PN01, 21611-021-N01, 21619-021-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Condition and Context The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal year 2020-2021, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. The Cooperative was a planning district whose purpose was to provide free appropriate public education to students identified as disabled in accordance with state statute who were legal residents and/or have been accepted through means of open enrollment, or other legal means of transfer to the participating member school corporations in Tippecanoe County. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. The Cooperative did not have adequate internal controls in place to ensure all activities and costs were allowed. One Cooperative employee prepared the payroll benefit disbursements without oversight or review. The lack of internal controls was isolated to the 2020-2021 fiscal year. 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 The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Effect The failure to establish an effective internal controls system placed the School Corporation at risk of noncompliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance with the grant agreement and the Activities Allowed or Unallowed and the Allowable Costs/Cost Principles compliance requirements. 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: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-021-PN01, 20611-021-PN01, 20619-021-PN01, 21611-021-PN01, 21619-021-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 19 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal year 2020-2021, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Procurement and Suspension and Debarment compliance requirement. The Cooperative was a planning district whose purpose was to provide free appropriate public education to students identified as disabled in accordance with state statute who were legal residents and/or have been accepted through means of open enrollment, or other legal means of transfer to the participating member school corporations in Tippecanoe County. The School Corporation did not have internal controls in place to ensure compliance with the suspension and debarment requirement. The Cooperative did not have adequate internal controls in place to ensure all applicable vendors were not suspended or debarred. Therefore, vendors with contracts over $25,000 were not verified to ensure they were not excluded or disqualified from participation in federal awards programs. The lack of effective internal controls and noncompliance were systemic issues isolated to the 2020-2021 fiscal year. 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 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." INDIANA STATE BOARD OF ACCOUNTS 20 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect The failure to establish an effective system of internal controls enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement could have resulted in the loss of federal 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 Procurement and Suspension and Debarment 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 2022-004 Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-021-PN01, 20611-21-PN01, 20619-21-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2020-2021 and 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The Cooperative was a planning district whose purpose was to provide free appropriate public education to students identified as disabled in accordance with state statute who were legal residents and/or have been accepted through means of open enrollment, or other legal means of transfer to the participating member school corporations in Tippecanoe County. INDIANA STATE BOARD OF ACCOUNTS 21 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 19611-21-PN01, 20611-21-PN01, and 20619-21-PN01 grant awards could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools on a percentage basis. These allocations were the amounts reported to the IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance were isolated to the 19611-21-PN01, 20611-21-PN01, and 20619-21-PN01 grant awards. 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 The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 22 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with 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.
Ill FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-01 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $104,640.00 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $7,151,713.18 were expended and reported on the Appling County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that payments were made to a janitorial company and a staffing services company utilized by the School District to provide ?retention? bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private companies. Per review of the contracts in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the companies and in the service of the School District for a stated period of time were not reflected within the associated contract. Therefore, expenditures totaling $104,640.00 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $104,640.00 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and approved by the local Board of Education; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding.
Ill FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-01 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $104,640.00 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $7,151,713.18 were expended and reported on the Appling County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that payments were made to a janitorial company and a staffing services company utilized by the School District to provide ?retention? bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private companies. Per review of the contracts in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the companies and in the service of the School District for a stated period of time were not reflected within the associated contract. Therefore, expenditures totaling $104,640.00 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $104,640.00 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and approved by the local Board of Education; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding.
Ill FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-01 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $104,640.00 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $7,151,713.18 were expended and reported on the Appling County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that payments were made to a janitorial company and a staffing services company utilized by the School District to provide ?retention? bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private companies. Per review of the contracts in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the companies and in the service of the School District for a stated period of time were not reflected within the associated contract. Therefore, expenditures totaling $104,640.00 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $104,640.00 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and approved by the local Board of Education; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding.
Finding 2022-002: Internal Controls (Material Weakness) Criteria A-102 Common Rule, OMB Circular A-110 and 2 CFR section 200.303 require that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.514 requires auditors to obtain an understanding of the non-Federal entity's internal control over Federal programs sufficient to plan the audit to support a low assessed level of control risk of noncompliance for major programs, and, unless internal control is likely to be ineffective, plan the testing of internal control over major programs to support a low assessed level of control risk for the assertions relevant to the compliance requirements for each major program and perform testing of internal control as planned. Condition As noted in finding 2022-001, we noted a lack of evidence to support the operation of internal controls for the fiscal year. Cause The Organization has experienced growth over the past couple of years, however has not evaluated and updated internal controls. Effect The Organization lacked internal controls to support a low assessed level of control risk for the assertions relevant to compliance requirements for the major program tested. Recommendation We recommend that the Organization institute a program to methodically identify and document its significant operational and accounting processes as they relate to Federal grants and compliance. Documenting a process involves identifying and gaining an understanding of the required compliance requirements, the automated or manual procedures used in performing the required process, the person(s) or position(s) responsible for performing the procedures, the source documents used or generated, the procedures for approval and review and correction of any errors detected, and the financial or operational entries or reports summarizing the result of the process. Views of Responsible Officials The Organization agrees with the auditor's findings. We have already begun to make adjustments to record all grants ahead of time in Quickbooks and deduct funding as we spend from these areas to directly show grant balances and that the restricted funding is spent in compliance with the funding received. We will also provide these findings to a certified public accountant to make sure they are adhered to correctly and meet the requirements of both state and federal funding.
Finding 2022-002: Internal Controls (Material Weakness) Criteria A-102 Common Rule, OMB Circular A-110 and 2 CFR section 200.303 require that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.514 requires auditors to obtain an understanding of the non-Federal entity's internal control over Federal programs sufficient to plan the audit to support a low assessed level of control risk of noncompliance for major programs, and, unless internal control is likely to be ineffective, plan the testing of internal control over major programs to support a low assessed level of control risk for the assertions relevant to the compliance requirements for each major program and perform testing of internal control as planned. Condition As noted in finding 2022-001, we noted a lack of evidence to support the operation of internal controls for the fiscal year. Cause The Organization has experienced growth over the past couple of years, however has not evaluated and updated internal controls. Effect The Organization lacked internal controls to support a low assessed level of control risk for the assertions relevant to compliance requirements for the major program tested. Recommendation We recommend that the Organization institute a program to methodically identify and document its significant operational and accounting processes as they relate to Federal grants and compliance. Documenting a process involves identifying and gaining an understanding of the required compliance requirements, the automated or manual procedures used in performing the required process, the person(s) or position(s) responsible for performing the procedures, the source documents used or generated, the procedures for approval and review and correction of any errors detected, and the financial or operational entries or reports summarizing the result of the process. Views of Responsible Officials The Organization agrees with the auditor's findings. We have already begun to make adjustments to record all grants ahead of time in Quickbooks and deduct funding as we spend from these areas to directly show grant balances and that the restricted funding is spent in compliance with the funding received. We will also provide these findings to a certified public accountant to make sure they are adhered to correctly and meet the requirements of both state and federal funding.