Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None Noted Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recover Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not Available Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211851 Award Period: 3.3.2921-12.31.2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for one out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recover Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not Available Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211851 Award Period: 3.3.2921-12.31.2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for one out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recover Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not Available Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211851 Award Period: 3.3.2921-12.31.2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for one out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recover Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not Available Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211851 Award Period: 3.3.2921-12.31.2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with 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: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for one out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board’s procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors’ suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: No Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Federal Agency: U.S. Department of Agriculture Federal Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.559 Federal Award Identification Number and Year: Not Provided Pass-Through Agency: Maryland State Department of Education Pass-Through Number: Not Available Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Control: According to the Carroll County Board of Education's procurement policy, any contract valued at over $25,000 must obtain board approval. This ensures compliance with internal controls and procurement regulations as specified in their policy manual and 2 CFR section 200.303(a), which requires non-Federal entities to establish and maintain effective internal control over Federal awards. Condition/Context: For one of seven vendors selected for testing, the Carroll County Board of Education failed to obtain board approval for a contract valued at over $25,000, as required by their procurement policy. Questioned Costs: None Noted. Cause: The Board did not adhere to its established procedures for obtaining necessary approvals for this contract exceeding $25,000 because the initial purchase was intended to be below the approval threshold. However, the total value of the contract was not fully considered. Effect: Failure to comply with the board approval requirement may result in unauthorized procurement activities and potential mismanagement of federal funds. Repeat Finding: No Recommendation: We recommend that the Carroll County Board of Education enhance its internal control procedures to ensure adherence to its procurement policy. This includes establishing a clear and consistently enforced process whereby all contracts over $25,000 are submitted for board approval prior to execution. Views of responsible officials: There is no disagreement with the finding.
Assistance Listing Number, Federal Agency, and Program Name - ALN 97.036, Department of Homeland Security, Disaster Grants - Public Assistance (Presidentially Declared Disasters) (FEMA) Federal Award Identification Number and Year - PA-05-MI-4607-PW-00098(0) Pass-through Entity - Michigan State Police Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.303(a), a nonfederal entity 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 - The FEMA grant expenses are charged to various funds in the general ledger over several years but is managed and tracked by project in a manual spreadsheet that agrees to the amount of expenses reported on the fiscal year 2024 schedule of expenditures of federal awards (the "Schedule"). FEMA expenditures are reported on the Schedule when there is an award and expenditures. Given that the award is made subsequent to the expenditures being incurred, a manual spreadsheet is used to track expenditures being charged to the grant. There were instances of duplicated costs in the manual spreadsheet. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The FEMA projects have periods of performances that began prior to fiscal year 2024. As a result, the City used spreadsheets to accumulate costs to charge to the projects. Given that manual processes carry a higher risk of error due to their reliance on human input, in addition to our allowability sample, we performed an analysis of the spreadsheet, which listed all costs charged to the grant during fiscal year 2024, and found 11 instances of duplicate costs totaling $5,161. Of the $5,161 submitted, FEMA reimburses ninety percent of the amount, i.e., $4,645. Cause and Effect - A lack of effective controls over the spreadsheet did not identify $5,161 of duplicative costs. The schedule of expenditures of federal awards was initially overstated by this amount. These costs have been excluded from the Schedule for the year ended June 30, 2024. Recommendation - We recommend the City continue to evaluate its processes and controls when manual processes are utilized to accumulate costs charged to a grant, including risk assessing for gaps that can cause noncompliance. Based on the gaps identified, we recommend the City implement effective controls to address the risks. Views of Responsible Officials and Corrective Action Plan - Detroit Water and Sewer Department (DWSD) management recognizes the importance of maintaining effective controls to ensure the accuracy and completeness of reported expenditures. The identified duplicate cost was an isolated occurrence caused by an oversight during the spreadsheet preparation process. While existing controls are in place, management will perform a secondary review of the end to end process to enhance these controls.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient 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). The City is required to complete inspections of HOME assisted units to ensure they meet the HUD housing standards as outlined in 24 CFR 92.251(b) (viii). During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing 1 to 4 units, (b) every two years for projects containing 5 to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on site inspections of rental housing occupied by tenants receiving HOME/HOME ARP assisted tenant based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Per the City’s Home Program manual adopted on July 1, 2022, at least 20 percent of the HOME assisted units must be rented to households at or below 50 percent of the area median income. The City is required to perform the inspections under the housing quality standards for these units. Condition - The City’s on site inspections for compliance with the housing quality standards are triggered by the City’s process to audit developers for compliance with HOME eligibility requirements. This basis is more restrictive than federal requirements for housing quality inspections. At the end of an inspection cycle, a certificate of completion is completed and signed by the responsible inspector. The City did not have effective controls to ensure the certificate of completion is reviewed for completeness and accuracy. The City did not inspect 20 percent of the units, as required by its policy. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In the process of understanding the controls over compliance with housing quality standards requirement, we noted that the certificate of completion, which is completed at the end of an inspection cycle, was not consistently reviewed. In addition, in one out the three projects selected for testing for compliance with the housing quality standards, the City did not inspect 20 percent of the units at the property, as outlined in their Home Program manual. Cause and Effect - The controls in place to ensure the certificate of completion is reviewed for completeness and accuracy, including review to ensure 20 percent of the units are inspected, were not in place. The lack of controls resulted in a project not having adequate units reviewed. Furthermore, the lack of controls could result in an instance of noncompliance not being identified. Recommendation - We recommend the City ensure controls are in place to comply with the Home Program manual and federal regulations related to housing quality standards. Views of Responsible Officials and Planned Corrective Actions - The City will review its processes and implement additional controls to ensure certificates of completion are reviewed for completeness and accuracy and to verify 20 percent of the units are inspected to comply with the HOME Program manual and federal regulations related to housing quality standards.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient 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). The City is required to complete inspections of HOME assisted units to ensure they meet the HUD housing standards as outlined in 24 CFR 92.251(b) (viii). During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing 1 to 4 units, (b) every two years for projects containing 5 to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on site inspections of rental housing occupied by tenants receiving HOME/HOME ARP assisted tenant based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Per the City’s Home Program manual adopted on July 1, 2022, at least 20 percent of the HOME assisted units must be rented to households at or below 50 percent of the area median income. The City is required to perform the inspections under the housing quality standards for these units. Condition - The City’s on site inspections for compliance with the housing quality standards are triggered by the City’s process to audit developers for compliance with HOME eligibility requirements. This basis is more restrictive than federal requirements for housing quality inspections. At the end of an inspection cycle, a certificate of completion is completed and signed by the responsible inspector. The City did not have effective controls to ensure the certificate of completion is reviewed for completeness and accuracy. The City did not inspect 20 percent of the units, as required by its policy. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In the process of understanding the controls over compliance with housing quality standards requirement, we noted that the certificate of completion, which is completed at the end of an inspection cycle, was not consistently reviewed. In addition, in one out the three projects selected for testing for compliance with the housing quality standards, the City did not inspect 20 percent of the units at the property, as outlined in their Home Program manual. Cause and Effect - The controls in place to ensure the certificate of completion is reviewed for completeness and accuracy, including review to ensure 20 percent of the units are inspected, were not in place. The lack of controls resulted in a project not having adequate units reviewed. Furthermore, the lack of controls could result in an instance of noncompliance not being identified. Recommendation - We recommend the City ensure controls are in place to comply with the Home Program manual and federal regulations related to housing quality standards. Views of Responsible Officials and Planned Corrective Actions - The City will review its processes and implement additional controls to ensure certificates of completion are reviewed for completeness and accuracy and to verify 20 percent of the units are inspected to comply with the HOME Program manual and federal regulations related to housing quality standards.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient 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). The City is required to complete inspections of HOME assisted units to ensure they meet the HUD housing standards as outlined in 24 CFR 92.251(b) (viii). During the period of affordability (i.e., the period for which the nonfederal entity must maintain subsidized housing) for HOME assisted rental housing, the participating jurisdiction must perform on site inspections to determine compliance with property standards and verify the information submitted by the owners no less than (a) every three years for projects containing 1 to 4 units, (b) every two years for projects containing 5 to 25 units, and (c) every year for projects containing 26 or more units. The participating jurisdiction must perform on site inspections of rental housing occupied by tenants receiving HOME/HOME ARP assisted tenant based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). Per the City’s Home Program manual adopted on July 1, 2022, at least 20 percent of the HOME assisted units must be rented to households at or below 50 percent of the area median income. The City is required to perform the inspections under the housing quality standards for these units. Condition - The City’s on site inspections for compliance with the housing quality standards are triggered by the City’s process to audit developers for compliance with HOME eligibility requirements. This basis is more restrictive than federal requirements for housing quality inspections. At the end of an inspection cycle, a certificate of completion is completed and signed by the responsible inspector. The City did not have effective controls to ensure the certificate of completion is reviewed for completeness and accuracy. The City did not inspect 20 percent of the units, as required by its policy. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - In the process of understanding the controls over compliance with housing quality standards requirement, we noted that the certificate of completion, which is completed at the end of an inspection cycle, was not consistently reviewed. In addition, in one out the three projects selected for testing for compliance with the housing quality standards, the City did not inspect 20 percent of the units at the property, as outlined in their Home Program manual. Cause and Effect - The controls in place to ensure the certificate of completion is reviewed for completeness and accuracy, including review to ensure 20 percent of the units are inspected, were not in place. The lack of controls resulted in a project not having adequate units reviewed. Furthermore, the lack of controls could result in an instance of noncompliance not being identified. Recommendation - We recommend the City ensure controls are in place to comply with the Home Program manual and federal regulations related to housing quality standards. Views of Responsible Officials and Planned Corrective Actions - The City will review its processes and implement additional controls to ensure certificates of completion are reviewed for completeness and accuracy and to verify 20 percent of the units are inspected to comply with the HOME Program manual and federal regulations related to housing quality standards.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient 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 - The City is required to track and report program income within HUD’s Integrated Disbursement and Information System (IDIS) and the general ledger. The City reported fiscal 2024 program income in fiscal 2025. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The repayments of principal and interest provided to developers with HOME funds constitute program income. Approximately $2.2 million received in program income during fiscal year 2024 was reported within IDIS and the City’s general ledger in fiscal year 2025. Cause and Effect - The City has a process to reconcile program income received each month to the monthly bank statements; however, the controls in place did not ensure that program income was reported within IDIS and the general ledger in a timely manner. As a result, program income revenue for fiscal year 2024 was initially understated in the general ledger, which was subsequently corrected to be reflected in fiscal year 2024. Additionally, within IDIS, program income was not reported as available for fiscal year 2024 expenditures. Recommendation - We recommend the City ensure controls are in place to track and report program income in a timely manner, in both the general ledger and IDIS. Views of Responsible Officials and Planned Corrective Actions - Management understands the importance of timely reconciliation and reporting of program income to maintain compliance and ensure accurate financial reporting. The City will work to enhance controls and processes with the department stakeholders and monitor the process to ensure timely and consistent receipts of the program income and reconciliations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient 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 - The City is required to track and report program income within HUD’s Integrated Disbursement and Information System (IDIS) and the general ledger. The City reported fiscal 2024 program income in fiscal 2025. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The repayments of principal and interest provided to developers with HOME funds constitute program income. Approximately $2.2 million received in program income during fiscal year 2024 was reported within IDIS and the City’s general ledger in fiscal year 2025. Cause and Effect - The City has a process to reconcile program income received each month to the monthly bank statements; however, the controls in place did not ensure that program income was reported within IDIS and the general ledger in a timely manner. As a result, program income revenue for fiscal year 2024 was initially understated in the general ledger, which was subsequently corrected to be reflected in fiscal year 2024. Additionally, within IDIS, program income was not reported as available for fiscal year 2024 expenditures. Recommendation - We recommend the City ensure controls are in place to track and report program income in a timely manner, in both the general ledger and IDIS. Views of Responsible Officials and Planned Corrective Actions - Management understands the importance of timely reconciliation and reporting of program income to maintain compliance and ensure accurate financial reporting. The City will work to enhance controls and processes with the department stakeholders and monitor the process to ensure timely and consistent receipts of the program income and reconciliations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - Per 2 CFR 200.303, the recipient 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 - The City is required to track and report program income within HUD’s Integrated Disbursement and Information System (IDIS) and the general ledger. The City reported fiscal 2024 program income in fiscal 2025. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The repayments of principal and interest provided to developers with HOME funds constitute program income. Approximately $2.2 million received in program income during fiscal year 2024 was reported within IDIS and the City’s general ledger in fiscal year 2025. Cause and Effect - The City has a process to reconcile program income received each month to the monthly bank statements; however, the controls in place did not ensure that program income was reported within IDIS and the general ledger in a timely manner. As a result, program income revenue for fiscal year 2024 was initially understated in the general ledger, which was subsequently corrected to be reflected in fiscal year 2024. Additionally, within IDIS, program income was not reported as available for fiscal year 2024 expenditures. Recommendation - We recommend the City ensure controls are in place to track and report program income in a timely manner, in both the general ledger and IDIS. Views of Responsible Officials and Planned Corrective Actions - Management understands the importance of timely reconciliation and reporting of program income to maintain compliance and ensure accurate financial reporting. The City will work to enhance controls and processes with the department stakeholders and monitor the process to ensure timely and consistent receipts of the program income and reconciliations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - The HOME program has income targeting requirements such that only low income or very low income persons can receive housing assistance as prescribed by 24 CFR 92.216. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award 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 - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were reviewed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into an agreement with a contractor to perform eligibility reviews over developers’ determinations of income eligibility. While the City arranges for the contractor to perform the review of eligibility, the City is fully responsible for compliance with eligibility requirements. Testing revealed that the City contractor reviewed the developers’ income eligibility determinations of individuals and families living in HOME funded housing units. In 7 out of a sample of 10 projects, there was no evidence of the City’s review of the contractor’s work. Cause and Effect - In the current year, the City contracted with a contractor to perform eligibility reviews over developers’ determination of income eligibility. However, the City did not implement controls to ensure eligibility reviews performed by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor’s procedures to assess participant eligibility, ineligible participants could receive program benefits, resulting in material noncompliance and the need to repay the funder for such costs. Recommendation - We recommend the City develop oversight procedures to perform a documented review of the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, eligibility review. Views of Responsible Officials and Planned Corrective Actions - The City will implement a control for completeness and accuracy by hosting regular meetings with the contractor to review recent projects for which the contractor has documented their determinations of income eligibility. When a recently reviewed project is not due for an annual review, staff will still have timely insight into the income eligibility of properties in its HOME portfolio, thereby maintaining compliance with HOME program regulations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - The HOME program has income targeting requirements such that only low income or very low income persons can receive housing assistance as prescribed by 24 CFR 92.216. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award 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 - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were reviewed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into an agreement with a contractor to perform eligibility reviews over developers’ determinations of income eligibility. While the City arranges for the contractor to perform the review of eligibility, the City is fully responsible for compliance with eligibility requirements. Testing revealed that the City contractor reviewed the developers’ income eligibility determinations of individuals and families living in HOME funded housing units. In 7 out of a sample of 10 projects, there was no evidence of the City’s review of the contractor’s work. Cause and Effect - In the current year, the City contracted with a contractor to perform eligibility reviews over developers’ determination of income eligibility. However, the City did not implement controls to ensure eligibility reviews performed by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor’s procedures to assess participant eligibility, ineligible participants could receive program benefits, resulting in material noncompliance and the need to repay the funder for such costs. Recommendation - We recommend the City develop oversight procedures to perform a documented review of the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, eligibility review. Views of Responsible Officials and Planned Corrective Actions - The City will implement a control for completeness and accuracy by hosting regular meetings with the contractor to review recent projects for which the contractor has documented their determinations of income eligibility. When a recently reviewed project is not due for an annual review, staff will still have timely insight into the income eligibility of properties in its HOME portfolio, thereby maintaining compliance with HOME program regulations.
Assistance Listing Number, Federal Agency, and Program Name - ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program and COVID-19 Home Investment Partnerships Federal Award Identification Number and Year - M22-MC260202, M21-MP260202, Various Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - The HOME program has income targeting requirements such that only low income or very low income persons can receive housing assistance as prescribed by 24 CFR 92.216. Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award 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 - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were reviewed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into an agreement with a contractor to perform eligibility reviews over developers’ determinations of income eligibility. While the City arranges for the contractor to perform the review of eligibility, the City is fully responsible for compliance with eligibility requirements. Testing revealed that the City contractor reviewed the developers’ income eligibility determinations of individuals and families living in HOME funded housing units. In 7 out of a sample of 10 projects, there was no evidence of the City’s review of the contractor’s work. Cause and Effect - In the current year, the City contracted with a contractor to perform eligibility reviews over developers’ determination of income eligibility. However, the City did not implement controls to ensure eligibility reviews performed by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor’s procedures to assess participant eligibility, ineligible participants could receive program benefits, resulting in material noncompliance and the need to repay the funder for such costs. Recommendation - We recommend the City develop oversight procedures to perform a documented review of the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, eligibility review. Views of Responsible Officials and Planned Corrective Actions - The City will implement a control for completeness and accuracy by hosting regular meetings with the contractor to review recent projects for which the contractor has documented their determinations of income eligibility. When a recently reviewed project is not due for an annual review, staff will still have timely insight into the income eligibility of properties in its HOME portfolio, thereby maintaining compliance with HOME program regulations.
2024-001 Entity: Antonia Pantoja Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan - Elementary and Secondary Schools Emergency Relief Funds Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-1073 ESSER and 225-21-1073 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.
2024-001 Entity: Antonia Pantoja Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan - Elementary and Secondary Schools Emergency Relief Funds Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-1073 ESSER and 225-21-1073 ESSER Award Period: 03/13/2020 - 09/30/2024 ESSER Type of Finding: • Other Matter • Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand – Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation of Cash on Hand – Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update procedures to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.