Federal Agency US Department of Education Federal Program Name Higher Education Institutional Aid Assistance Listing Number 84.031S Federal Award Identification Number and Year P031S200249 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Allowable Costs and Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material known questioned costs-therefore we will document as a SD. Additionally the client provided narrative response documents that the project directors complete, but do not quantify actual hours charged to the grant. based on expenditure of grant funds and activities in narrative responses and performance reports the grant work is being adequately completed, but the quantified hour tracking is not present. As such, based on these factors we will consider this to be a significant deficiency. Compliance Not Material Document judgment for your assessment See line 28 for more detailed response Criteria or specific requirement "Per 2 CFR 200.430(g)(1)(vi), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records should support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Per 2 CFR 200.303, nonfederal 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." Condition The University did not have proper documentation of Time and Effort reporting. Questioned costs: N/A Known 12,965.60 Likely 333907.5 Context During our testing of 40 Payroll transactions, we identified 38 time and effort reports that were not documented properly to track hours worked on federal grant and did not have a documentation of review. Additionally during our testing of 1 key personnel with Level of Effort provisions in the grant award notification, we identified the key personnel did not have documentation to track hours for level of effort required by the Federal agency. Cause The University did not have proper procedures in place to track time and effort for personnel on federal grants. Effect The University could potentially expense incorrect amount to federal grants. Repeat Finding No Recommendation We recommend the University review policies and procedures to ensure all personnel on federal grants documented time and effort reports as stated in federal regulations. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Higher Education Institutional Aid Assistance Listing Number 84.031S Federal Award Identification Number and Year P031S200249 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Allowable Costs Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance N/A - I/C Finding Only Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement Per Uniform Guidance 2 CFR 200.303, nonfederal 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. Condition The University did not review scholarship awards made with federal program funds. Questioned costs: N/A Known Likely Context During our testing of 8 scholarship transactions, we observed 8 instances where scholarship awards did not have evidence of review prior to the award of funds to students. Cause The University did adhere to existing controls in place to review the federal program scholarship awards. Effect Scholarships may be awarded that are disallowed from program funds and may go undetected for substantial periods of time. Repeat Finding No Recommendation We recommend the University adhere to their existing internal control policy regarding scholarship awards made from federal award funds. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Eligibility Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "The Code of Federal Regulations (34 CFR § 668.34(a)) requires institutions to establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under Title IV, HEA programs. Per 2 CFR 200.303, nonfederal 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." Condition The University did not properly place a student on SAP suspension or an academic plan who was beyond the 150% of credits needed to complete degree requirement. Questioned costs: N/A Known Likely Context During our testing of 40 students, we noted one student who was beyond the 150% requirement. This student was not placed on SAP suspension or an academic plan. Cause When the student began enrollment at the University, not all transfer credits were entered into the stystem. Effect Failure to properly identify students in violation of SAP could result in ineligible students receiving Title IV funds Repeat Finding No Recommendation We recommend the University review internal controls related to Eligibility and ensure appropriate checks are in place to identify students who are not meeting the University's qualitative and quantitative criteria for maintaining SAP. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Material Weakness Document judgment for your assessment OPSU was evaluating students with modular courses incorrectly and R2T4 calculations were not being performed during Fall and Spring terms. Compliance Material Document judgment for your assessment Appears to be systemic. Criteria or specific requirement "34 CFR 668.21(a) states that the institution must return all title IV, HEA program funds that were credited to the student's account at the instituion or disbursed directly to the student for th payment period. The instituion must return those funds no later than 30 days after the date that the instituion becomes aware that the student will not or has not begun attendance. Per 2 CFR 200.303, nonfederal 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." Condition The University did not properly evaluate students in need of Return of Title IV (R2T4) calculations. Questioned costs: Known $5,095.00 Likely See Questioned Cost Tab Context "During our testing of 8 R2T4 calculations, we noted that 6 students were incorrectly evaluated as a withdrawal exemption and no R2T4 calculation was performed. For these 6 students, all 6 should have had an R2T4 calculation, and 3 should have had returned funds. Additionally, one R2T4 calculation did not have documentation of review." Cause The University incorrectly evaluated procedures related to module courses and R2T4 calculation exemptions, leading to necessary calculations not being performed. Effect The University could return incorrect amounts based off of their calculations and incorrect calculations could effect student repayment amounts based off of amount earned. Repeat Finding Yes Recommendation We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Views of Responsible Officials Agree
Federal Agency US Department of Education Federal Program Name Student Financial Assistance Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year P007A233438 - 2024, P033A233438 - 2024, P063P232047 - 2024, P268K242047 - 2024 Pass-Through Agency (if applicable) N/A Pass-Through Number(s) (if applicable) N/A Award Period 7/1/2023-6/30/2024 Compliance Requirement Affected Special Tests and Provisions Type of Finding Internal Control Significant Deficiency Document judgment for your assessment Control finding did not result in material questioned costs-therefore we will document as a SD. Additionally qualitatively failure did not have material impact on compliance. Compliance Not Material Document judgment for your assessment Not greater than 5% and not a systemic failure Criteria or specific requirement "Per Uniform Guidance 2 CFR 200.303, nonfederal 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. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. The Code of Federal Regulations, 34 CFR 685.309(b), states the school is required to report changes in the student’s enrollment status, the effective date of the status, and an anticipated completion date. " Condition The University did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Questioned costs: N/A Known Likely Context "During our testing of 60 students, we noted that 5 students had enrollment status changes that were not reported to NSLDS. We also noted that 6 students had effective dates reported for Program-level NSLDS that did not align with effective dates per Instition records. We also noted 1 student for whom the University could not provide institutional records to substantiate the effective date reported to NSLDS. We also noted 3 students who were incorrectly reported as withdrawals to NSLDS that earned an F grade. " Cause The University didn't have proper procedures in place to verify students' status in NSLDS matched the institutions records accurately or in a timely manner. Effect The University was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat Finding Yes Recommendation We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Views of Responsible Officials Agree
Internal Control over Compliance and Compliance with the Reporting Compliance Requirement Identification of the Federal Program: United States Agency for International Development (USAID) Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Award Number: 720BHA24GR00016 Award Period: December 15, 2023 through December 31, 2026 Criteria or Specific Requirement: In accordance with §200.303(a), Internal Controls, 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. In accordance with the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The prime awardee is required to file a Transparency Act sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant granter than or equal to $30,000. Condition: During BDO’s testing of the FFATA reporting, we tested the only subrecipient in the major program. ChildFund entered into the subaward agreement with the entity in January 2024, however ChildFund did not report activity in the FSRS system until October 2024. Cause: There was turnover at ChildFund in the personnel who is responsible for the Transparency Act reports and it was not initially identified that someone had not assumed that responsibility until our audit procedures identified the missing report. Effect: Failure to properly track all Transparency Act reporting requirements impacts the Federal agency from obtaining performance information required to assess award performance on a macro level. Questioned Costs: There are no questioned costs as the items outlined above are all matters relate to late submission of required reports. Context: This is a condition identified during BDO’s testing of Transparency Act reports. We tested the only required FFATA report submission for the year ended June 30, 2024. Repeat Finding: This finding is not a repeat finding. Recommendation: To facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, BDO recommends management implement a process by which approvals, submission considerations and supporting documentation for programmatic reports and Transparency Act reports is maintained in a centralized location. Views of Responsible Officials: Management agrees with the finding. Please see Appendix B for Management’s Corrective Action Plan.
Assistance Listing Number, Federal Agency, and Program Name - 97.039, Department of Homeland Security, FEMA Hazard Mitigation Grant Federal Award Identification Number and Year - Not applicable Pass through Entity - Michigan State Police Finding Type - Material weakness and material noncompliance with laws and regulations Criteria - Per 2 CFR 200.303(a) - The recipient and subrecipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the 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 - There is no evidence of review of the reports submitted to the funding agency. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Based on the grant award date, the City submitted three quarterly reports. There was no evidence that the reports were reviewed prior to submission. Cause and Effect - The reports were not reviewed for completeness and accuracy prior to submission, and, as a result, the year end quarterly report included costs that were estimated to be 25 percent of the grant award rather than the actual costs incurred to date. Recommendation - The City should implement controls to ensure that reports are reviewed for completeness and accuracy prior to submission to the funding agency. Views of Responsible Officials and Corrective Action Plan - The City has implemented controls to have a secondary review of reports prior to submission to the funding agency.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P234721, P268K244721 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: 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). Compliance – Per the NSLDS Enrollment Reporting Guide, Published Program Length should be reported to NSLDS based on the definition of “normal time” to completion in the regulations at 34 CFR 668.41(a), as follows: • If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published. • If the school has not published a program length and the program is an associate or bachelor’s degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the program makes it longer or shorter than typical. • For all other programs for which the school has not published a program length, the program length is based on the school’s determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete. Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Questioned costs: None Context: The condition occurred for 4 out of the 22 students tested. Cause: The college uses the National Student Clearinghouse (NSC) to transmit transmitted over to the National Student Loan Data System (NSLDS). During the course of the year it was determined that information did not get calculated properly. Effect: Program length was misreported to NSLDS. Repeat Finding: No. Recommendation: We recommend the College report associate degree program length to NSLDS as two years. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P234721, P268K244721 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: 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). Compliance – Per the NSLDS Enrollment Reporting Guide, Published Program Length should be reported to NSLDS based on the definition of “normal time” to completion in the regulations at 34 CFR 668.41(a), as follows: • If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published. • If the school has not published a program length and the program is an associate or bachelor’s degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the program makes it longer or shorter than typical. • For all other programs for which the school has not published a program length, the program length is based on the school’s determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete. Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Questioned costs: None Context: The condition occurred for 4 out of the 22 students tested. Cause: The college uses the National Student Clearinghouse (NSC) to transmit transmitted over to the National Student Loan Data System (NSLDS). During the course of the year it was determined that information did not get calculated properly. Effect: Program length was misreported to NSLDS. Repeat Finding: No. Recommendation: We recommend the College report associate degree program length to NSLDS as two years. Views of Responsible Officials: There is no disagreement with the audit finding.
FINDING 2024-003 Information on the federal program: Subject: Education Stabilization Fund - Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the activities allowed or unallowed and allowable costs/cost principle compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: $9,498 Context: Two vouchers, in a sample of twenty-one vouchers selected for testing, were for an unallowable activity and unallowable costs. The vouchers related to transportation for students to Kings Island as an incentive for students who demonstrated that they were proficient in workplace skills such as attendance, emotion management, other soft skills. The two Kings Island vouchers tested were the only Kings Island vouchers in the population. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the activities allowed or unallowed and allowable costs/cost principle compliance requirements to ensure only allowable costs are charged to the grant award. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on Federal Programs U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program (passed through the North Dakota Division of Community Services, # 4995-LIHEAP21- 30, 5138-LIHEAP-ARPA-30, and 5195-LIHEAP23-30) U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program – Emergency Furnace Repair (passed through the North Dakota Division of Community Services, Award #5131-LIHEAPEF22-30 and 5055-LIHEAPEF-ARPA-30) AL# 93.568 Criteria – Section 2 CFR sections 200.303 requires that the auditee establish and maintain internal control over federal awards to provide reasonable assurance that the auditee is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition – For the year ended June 30, 2024, we requested supporting documentation to test the review and approval of a sample of costs charged to the LIHEAP grant. In a sample of 60 expenditures, we noted one instance where a journal entry which allocated expenses to the grant was not approved. Cause – Internal controls were updated mid-year to require the review of all journal entries charged to and reimbursed under federal grants. Effect or Potential Effect – Federal expenditures may not be in accordance with the allowable cost/cost principles standards under Uniform Guidance. Questioned Costs – Undeterminable Context – The expenditure selected for testing was a journal entry allocated costs but occurred prior to the change in the internal control requiring review of all journal entries. Repeat Finding – This is a new finding. Recommendation – The auditee should review all journal entries that were charged to federal grants and approve retroactively and document in a memo. Any errors noted should be correcting with the appropriate granting agencies.
Information on Federal Programs U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program (passed through the North Dakota Division of Community Services, # 4995-LIHEAP21- 30, 5138-LIHEAP-ARPA-30, and 5195-LIHEAP23-30) U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program – Emergency Furnace Repair (passed through the North Dakota Division of Community Services, Award #5131-LIHEAPEF22-30 and 5055-LIHEAPEF-ARPA-30) AL# 93.568 Criteria – Section 2 CFR sections 200.303 requires that the auditee establish and maintain internal control over federal awards to provide reasonable assurance that the auditee is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition – For the year ended June 30, 2024, we requested supporting documentation to test the review and approval of a sample of costs charged to the LIHEAP grant. In a sample of 60 expenditures, we noted one instance where a journal entry which allocated expenses to the grant was not approved. Cause – Internal controls were updated mid-year to require the review of all journal entries charged to and reimbursed under federal grants. Effect or Potential Effect – Federal expenditures may not be in accordance with the allowable cost/cost principles standards under Uniform Guidance. Questioned Costs – Undeterminable Context – The expenditure selected for testing was a journal entry allocated costs but occurred prior to the change in the internal control requiring review of all journal entries. Repeat Finding – This is a new finding. Recommendation – The auditee should review all journal entries that were charged to federal grants and approve retroactively and document in a memo. Any errors noted should be correcting with the appropriate granting agencies.
Information on Federal Programs U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program (passed through the North Dakota Division of Community Services, # 4995-LIHEAP21- 30, 5138-LIHEAP-ARPA-30, and 5195-LIHEAP23-30) U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program – Emergency Furnace Repair (passed through the North Dakota Division of Community Services, Award #5131-LIHEAPEF22-30 and 5055-LIHEAPEF-ARPA-30) AL# 93.568 Criteria – Section 2 CFR sections 200.303 requires that the auditee establish and maintain internal control over federal awards to provide reasonable assurance that the auditee is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition – For the year ended June 30, 2024, we requested supporting documentation to test the review and approval of a sample of costs charged to the LIHEAP grant. In a sample of 60 expenditures, we noted one instance where a journal entry which allocated expenses to the grant was not approved. Cause – Internal controls were updated mid-year to require the review of all journal entries charged to and reimbursed under federal grants. Effect or Potential Effect – Federal expenditures may not be in accordance with the allowable cost/cost principles standards under Uniform Guidance. Questioned Costs – Undeterminable Context – The expenditure selected for testing was a journal entry allocated costs but occurred prior to the change in the internal control requiring review of all journal entries. Repeat Finding – This is a new finding. Recommendation – The auditee should review all journal entries that were charged to federal grants and approve retroactively and document in a memo. Any errors noted should be correcting with the appropriate granting agencies.
U.S. Department of Health and Human Services Program Name: Maternal and Child Health Services Block Grant Federal Assistance Listing Number: 93.994 Significant Deficiency, Nonmaterial Noncompliance - Reporting Finding 2024-006 Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, 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. Per 2 CFR 200.334 the recipient must retain all Federal award records for three years from the date of submission of their final financial report. Condition: During the audit we tested 13 reports and noted the following: a) There were four (4) instances out of 13 reports tested where the submitted reports were unable to be provided, including the date of submission for the reports. b) There were 10 instances out of 13 reports tested where the County was unable to provide evidence the report was reviewed prior to submission. Questioned Costs: None. Effect: By not having the required documentation and underlying support, the County is not able to demonstrate compliance with the applicable requirements. Cause: The County did not have a formal policy to ensure documentation was retained to evidence review and submission of all reports. Recommendation: The County should consider creating a formalized policy to require all submitted reports and underlying data are retained in accordance with the Uniform Grant Guidance requirements. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: See Corrective Action Plan prepared by the County.
Information on the federal program: U.S. Department of Treasury, Assistance Listing No. 21.027 COVID-19 Coronavirus Fiscal Recovery Funds Criteria: 2 CFR 200.302 and 2 CFR 200.303 require entities to establish and maintain internal controls and financial management procedures to provide reasonable assurance the award is managed in compliance with statutes, regulations, and terms and conditions of the award and to ensure federal award expenditures are adequately supported by source documentation. Condition: We tested controls over disbursements to 11 hospitals during the year. For each hospital to receive funding they were to submit a staffing spreadsheet reporting their increased staffing costs due to COVID. Of the 11 tested, supporting documentation for 3 hospitals was not readily available. Additional information had to be obtained from the hospital to support the information reported by the hospital in the staffing spreadsheet. Cause: Salary information obtained in support of the staffing spreadsheet included Employees Quarterly Federal Tax Return (941) and payroll registers. Additional general ledger information had to be requested from the hospitals during the audit to reconcile to the amounts reported in the staffing spreadsheet. Effect: Internal Controls were not properly implemented to obtain source documentation to adequately support the amounts reported by the hospitals as additional staffing costs. Recommendation: We recommend the Organization strengthen its policies and procedures surrounding disbursements to hospitals to ensure the amounts reported were accurate and source documentation is retained to ensure compliance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the findings. See Management’s View and Corrective Action Plan included at the end of the report.
Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and conditions of the Federal award. Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, 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. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in Onesite. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year.rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial.
Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and conditions of the Federal award. Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, 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. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in Onesite. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year.rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial.
Federal Award Identification Number and Year: 121-HD080-NP-CMI - Federal Award Identification Number and Year: 121-HD080-NP-CMI - 2024 Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, 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. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year.
Federal Award Identification Number and Year: 121-HD080-NP-CMI - Federal Award Identification Number and Year: 121-HD080-NP-CMI - 2024 Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, 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. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD002-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, 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. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year. Repeat Finding: N/A
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD002-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, 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. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year. Repeat Finding: N/A
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD002-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, 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. Condition: Tenant rent computation was not calculated correctly. Questioned costs: None Context: As part of our testing, we noted an issue with a tenant's rent computation, which resulted in undercharged rent. The rent computation requires that all of the tenant's income and assets be included in the calculation of the tenant's rent. The error occurred due to excluding a tenant's asset and rental income. These exclusions collectively understated the rent that should have been charged to the tenant. Cause: Management oversight to address all of the tenant's assets and income on the rent computation form. Effect: Noncompliance results in possible over charges to the grant. Repeat Finding: N/A
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD002-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, 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. Condition: Tenant rent computation was not calculated correctly. Questioned costs: None Context: As part of our testing, we noted an issue with a tenant's rent computation, which resulted in undercharged rent. The rent computation requires that all of the tenant's income and assets be included in the calculation of the tenant's rent. The error occurred due to excluding a tenant's asset and rental income. These exclusions collectively understated the rent that should have been charged to the tenant. Cause: Management oversight to address all of the tenant's assets and income on the rent computation form. Effect: Noncompliance results in possible over charges to the grant. Repeat Finding: N/A
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD098-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, 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. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year. Repeat Finding: N/A
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD098-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, 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. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year. Repeat Finding: N/A
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD098-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, 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. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year. Repeat Finding: N/A
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
1. FINDING NUMBER: 2024 - 002 2. THIS FINDING IS: New 3. Federal Program Name and Year: Child Nutrition Cluster - 2024 4. Project No.: 24-4210-00, 24-4220-00 5. AL No.: 10.553, 10.555 6. Passed Through: Illinois State Board of Education 7. Federal Agency: U.S. Department of Agriculture 8. Criteria or specific requirement (including statutory, regulatory, or other citation): According to 2 CFR §200.303, non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 9. Condition: During our audit of the Child Nutrition Cluster, we identified that the District did not have adequate disbursement controls in place. Specifically, duplicate invoices on multiple occasions were entered into the District's software system due to typographical errors, resulting in payments being made twice to each vendor for the same service. 10. Questioned Costs: The duplicated invoices do not impact the reimbursement received by the District due to the Child Nutrition Cluster being an open-ended entitlement grant, meaning they provide reimbursements based on the number of eligible meals served rather than all food service expenditures incurred. As a result, no questioned costs were identified. 11. Context: During our audit of the Child Nutrition Cluster's allowable activities, two separate instances of duplicated invoices were identified from a stratified sample size of forty. The sample was deemed not statistically valid. 12. Effect: The District incurred unnecessary expenses by paying vendors twice for the same service, which could result in financial losses and potential non-compliance with Federal regulations. The finding does not impact the reimbursement the District receives. 13. Cause: The lack of proper review and approval processes for invoice entry and payment, combined with typographical errors, led to the duplication of invoices and subsequent duplicate payments. 14. Recommendation: We recommend that the District implement stronger internal controls over the disbursement process. This includes establishing a review and approval process for all invoices before payment, implementing software controls to detect duplicate invoices, and providing training to staff on proper invoice processing procedures to minimize typographical errors. 15. Management's response: Management agrees with the finding and has initiated steps to enhance disbursement controls. These steps include revising the invoice approval process, upgrading the software system to flag duplicate invoices, and conducting training sessions for staff on the new procedures to reduce typographical errors.