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.
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.
Entity: Eugenio Maria de Hostos 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 Fund 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: 223-21-0837 ESSER and 225-21-0837 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 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). 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.
Entity: Eugenio Maria de Hostos 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 Fund 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: 223-21-0837 ESSER and 225-21-0837 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 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). 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.
Entity: Eugenio Maria de Hostos 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 Fund 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: 223-21-0837 ESSER and 225-21-0837 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 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). 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.
Entity: Eugenio Maria de Hostos 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 Fund 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: 223-21-0837 ESSER and 225-21-0837 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 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). 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.
Entity: Eugenio Maria de Hostos 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 Fund 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: 223-21-0837 ESSER and 225-21-0837 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 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). 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.
Entity: Eugenio Maria de Hostos 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 Fund 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: 223-21-0837 ESSER and 225-21-0837 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 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). 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.
Entity: Eugenio Maria de Hostos 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 Fund 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: 223-21-0837 ESSER and 225-21-0837 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 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). 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.
2024-002 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A233410, P033A233410, P063P232032, P268K24032 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1) an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and returned funds late. Context: During our testing, we identified 3 out of 40 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, 2 out of 40 of the R2T4 selections had funds that were not returned timely (after 45 days). Questioned costs: None. Cause: The College input the incorrect dates when completing R2T4 calculations. Effect: The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Views of responsible officials: Management agrees with the finding.
2024-002 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A233410, P033A233410, P063P232032, P268K24032 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1) an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and returned funds late. Context: During our testing, we identified 3 out of 40 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, 2 out of 40 of the R2T4 selections had funds that were not returned timely (after 45 days). Questioned costs: None. Cause: The College input the incorrect dates when completing R2T4 calculations. Effect: The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Views of responsible officials: Management agrees with the finding.
2024-002 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A233410, P033A233410, P063P232032, P268K24032 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1) an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and returned funds late. Context: During our testing, we identified 3 out of 40 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, 2 out of 40 of the R2T4 selections had funds that were not returned timely (after 45 days). Questioned costs: None. Cause: The College input the incorrect dates when completing R2T4 calculations. Effect: The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Views of responsible officials: Management agrees with the finding.
2024-002 Special Tests and Provisions Federal agency: U.S Department of Education Federal program title: Student Financial Assistance Cluster Assistant Listing Number: 84.007/84.033/84.063/84.268 Federal Award Identification Number: P007A233410, P033A233410, P063P232032, P268K24032 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Per 34 CFR 668.22(j)(1) an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College used the incorrect withdrawal date when calculating Return to Title IV (R2T4) calculation and returned funds late. Context: During our testing, we identified 3 out of 40 R2T4 calculations used an incorrect withdrawal date in their calculation. Also, 2 out of 40 of the R2T4 selections had funds that were not returned timely (after 45 days). Questioned costs: None. Cause: The College input the incorrect dates when completing R2T4 calculations. Effect: The College could return incorrect amounts based off of their calculations, which could affect student repayment amounts based off of amount earned. Repeat Finding: No. Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately and federal funds are returned timely. Views of responsible officials: Management agrees with the finding.
2024-003 Allowable Costs Federal agency: U.S Department of Education & Department of Health and Human Services Federal program title: Career and Technical Education - Basic Grant to States & Child Care and Development Block Grant Assistant Listing Number: 84.048 & 93.575 Federal Award Identification Number: V048A220030-2024 and 2101ILccc5-2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.430(g)(1) states charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not have proper documentation of Time and Effort reporting. Context: During our testing, we identified that time and effort reports were not documented properly to track hours worked on federal grant and did not have documentation of formal review. Questioned costs: None. Cause: The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect: The College could potentially expense incorrect amount to federal grants. Repeat Finding: No. Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Views of responsible officials: Management agrees with the finding.
2024-003 Allowable Costs Federal agency: U.S Department of Education & Department of Health and Human Services Federal program title: Career and Technical Education - Basic Grant to States & Child Care and Development Block Grant Assistant Listing Number: 84.048 & 93.575 Federal Award Identification Number: V048A220030-2024 and 2101ILccc5-2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Material Weakness in Internal Control over Compliance Criteria or specific requirement: Per 2 CFR 200.430(g)(1) states charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not have proper documentation of Time and Effort reporting. Context: During our testing, we identified that time and effort reports were not documented properly to track hours worked on federal grant and did not have documentation of formal review. Questioned costs: None. Cause: The College did not have proper procedures in place to track time and effort for personnel on federal grants. Effect: The College could potentially expense incorrect amount to federal grants. Repeat Finding: No. Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Views of responsible officials: Management agrees with the finding.
2024-001 Reporting Federal agency: U.S Department of Commerce Federal program title: Investments for Public Works and Economic Development Facilities Assistant Listing Number: 11.300 Federal Award Identification Number: 05-79-06232 - 2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: Compliance, Other Matters Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are formally reviewed by someone who did not prepare the report to verify the correct information and data is submitted. Additionally, per 2 CFR 200.328(c) the recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Condition: The College did not have a formal review process in place as well as submit report timely. Context: During our testing, we identified 2 out of 2 financial reports did not have documentation of formal review. Additionally, 1 of the 2 reports was not submitted within the required timeframe. Questioned costs: None. Cause: Supervisory review and approval is currently undocumented, and is only communicated verbally. Effect: Improper data could be submitted to the awarding agency. Repeat Finding: No. Recommendation: The College should implement formal review procedures to document review and approvals over required reports in addition to procedures to ensure reports are being submitted timely. Views of responsible officials: Management agrees with the finding.
2024-005: U.S. Department of Education Passed through State of Nevada Department of Education Supporting Effective Instruction State Grants, 84.367 Matching, Level of Effort, and Earmarking Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing number 84.367 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Underlying supporting documentation that the Elko County School District compiled to monitor local compliance with level of effort requirements was not maintained. Cause: Elko County School District did not have sufficient internal controls to ensure level of effort tracking was maintained and reviewed. Effect: Noncompliance with level of effort requirements may not be detected. Questioned Costs: None Context/Sampling: Underlying supporting documentation for monitoring was not maintained. A recalculation of the level of effort requirements, as applicable, for the fiscal year ending June 30, 2024, was performed and no issues of noncompliance were noted. Repeat Finding from Prior Year(s): No Recommendation: We recommend Elko County School District enhance internal controls to ensure information used in the level of effort monitoring is maintained. Views of Responsible Officials: Management agrees with the finding.
2024-005: U.S. Department of Education Passed through State of Nevada Department of Education Supporting Effective Instruction State Grants, 84.367 Matching, Level of Effort, and Earmarking Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing number 84.367 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Underlying supporting documentation that the Elko County School District compiled to monitor local compliance with level of effort requirements was not maintained. Cause: Elko County School District did not have sufficient internal controls to ensure level of effort tracking was maintained and reviewed. Effect: Noncompliance with level of effort requirements may not be detected. Questioned Costs: None Context/Sampling: Underlying supporting documentation for monitoring was not maintained. A recalculation of the level of effort requirements, as applicable, for the fiscal year ending June 30, 2024, was performed and no issues of noncompliance were noted. Repeat Finding from Prior Year(s): No Recommendation: We recommend Elko County School District enhance internal controls to ensure information used in the level of effort monitoring is maintained. Views of Responsible Officials: Management agrees with the finding.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and eligibility compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation's management establish an internal control process to review the updates to the annual adjustments to the Income Eligibility Guidelines made to the food service software to determine eligibility to ensure updated guidelines are accurate and complete. This review should be documented on annual basis to confirm management’s oversight and monitoring of eligibility determinations. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation's management establish an internal control process to review the updates to the annual adjustments to the Income Eligibility Guidelines made to the food service software to determine eligibility to ensure updated guidelines are accurate and complete. This review should be documented on annual basis to confirm management’s oversight and monitoring of eligibility determinations. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with eligibility requirements. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. Identification as a repeat finding, if applicable: No. Recommendation: We recommend that the School Corporation's management establish an internal control process to review the updates to the annual adjustments to the Income Eligibility Guidelines made to the food service software to determine eligibility to ensure updated guidelines are accurate and complete. This review should be documented on annual basis to confirm management’s oversight and monitoring of eligibility determinations. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Condition: During our audit we noted that management did not have approval controls over invoices reimbursed by the federal program and approval of subrecipient monitoring reports. Criteria: The Organization must establish and maintain effective internal controls over the financial award that provides reasonable assurance that the non-Federal entity is managing the Federal Award in compliance with Federal statutes, regulations and the terms and conditions of the federal award per CFR 200.303. These requirements detail the information that must be included in the Organization's internal control. Cause: Management did not design and implement internal controls to document approval of invoices reimbursed by the federal program and subrecipient monitoring reports. Approvals were obtained verbally and were not documented. Effect: The absence of controls over disbursements and subrecipient monitoring incurred lead to an increased risk of errors and noncompliance in the financial statements, which could misrepresent the Organization's financial statements Recommendation: We recommend that the Organization implements a process to ensure that management documents all approvals and that approvals are occurring by proper personal.
Department of Housing and Urban Development 14.871 Housing Voucher Cluster Internal Control Finding - Eligibility Repeat Finding: No Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The PHA must have sufficient internal controls in place to ensure the proper administration of HUD funding. Condition and Context: We tested a sample of 25 HAP contracts and found 2 tenants where the tenant affidavit for rental assistance benefits was not signed by a housing specialist. Therefore, these two selections did not have evidence that the tenant information was reviewed. Cause: The City does not have a proper policy in place to ensure documentation of review procedures. Effect or Potential Effect: The City could potentially create a HAP contract with a tenant that is ineligible for rental assistance. Questioned Costs: Unknown. Recommendation: We recommend that tenant evaluations and annual re-evaluations are reviewed by a supervisor prior to creating a HAP contract or renewing an existing contract to ensure tenant files are properly reviewed and documented. Views of Responsible Officials: The City agrees with the finding. See Section V for the corrective action plan.
Department of Housing and Urban Development 14.871 Housing Voucher Cluster Internal Control Finding - Eligibility Repeat Finding: No Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The PHA must have sufficient internal controls in place to ensure the proper administration of HUD funding. Condition and Context: We tested a sample of 25 HAP contracts and found 2 tenants where the tenant affidavit for rental assistance benefits was not signed by a housing specialist. Therefore, these two selections did not have evidence that the tenant information was reviewed. Cause: The City does not have a proper policy in place to ensure documentation of review procedures. Effect or Potential Effect: The City could potentially create a HAP contract with a tenant that is ineligible for rental assistance. Questioned Costs: Unknown. Recommendation: We recommend that tenant evaluations and annual re-evaluations are reviewed by a supervisor prior to creating a HAP contract or renewing an existing contract to ensure tenant files are properly reviewed and documented. Views of Responsible Officials: The City agrees with the finding. See Section V for the corrective action plan.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
Department of Housing and Urban Development Continuum of Care, Federal Financial Assistance Listing 14.267, Affects all grant awards included under Federal Financial Assistance Listing 14.267 on the Schedule Procurement, Suspension, and Debarment Material Weakness in Internal Control Over Compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. Condition: Catholic Charities has documented procurement procedures that conform to applicable federal standards regarding testing vendors for suspension and debarment; however, the procedures were not followed for four vendors selected for testing. Cause: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding testing vendors for suspension and debarment were followed. Effect: Payments could be made to recipients who were suspended or debarred. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 13 transactions out of 68 total transactions were selected for testing. Four vendors did not have support showing the search for suspension and debarment was performed which made up $60,537 of $796,282 federal awards. Repeat Finding from Prior Year(s): Yes, 2023-001 Recommendation: We recommend Catholic Charities enhance internal control procedures to ensure all suspension and debarment verification procedures are performed prior to entering into the transactions. Views of Responsible Officials: Management agrees with the finding.
2024 – 001: Return of Title IV Funds Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2023, to June 30, 2024 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Return of Title IV funds, the College did not return Title IV funds within 45 days of the College’s determination date Context: During our testing of 40 student's Return of Title IV (R2T4) calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Questioned costs: None Cause: The College has not implemented precise controls to ensure timely return of funds related to withdrawals Effect: The College was not in compliance with the requirements to properly return refunds within the 45 day requirement. Repeat finding: Yes; prior year finding number was 2023-002. Recommendation: CLA recommends the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
2024 – 001: Return of Title IV Funds Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2023, to June 30, 2024 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 668.22(j)(1), states that an institution must return the amount of title IV funds for which it is responsible as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: During testing of Return of Title IV funds, the College did not return Title IV funds within 45 days of the College’s determination date Context: During our testing of 40 student's Return of Title IV (R2T4) calculations, we noted 3 with refunds that were not returned within the 45-day requirement. Questioned costs: None Cause: The College has not implemented precise controls to ensure timely return of funds related to withdrawals Effect: The College was not in compliance with the requirements to properly return refunds within the 45 day requirement. Repeat finding: Yes; prior year finding number was 2023-002. Recommendation: CLA recommends the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2023, to June 30, 2024 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control Over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates. Questioned costs: None Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: Yes; prior year finding number 2023-003 Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2023, to June 30, 2024 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control Over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates. Questioned costs: None Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: Yes; prior year finding number 2023-003 Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2023, to June 30, 2024 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control Over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates. Questioned costs: None Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: Yes; prior year finding number 2023-003 Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.
Federal Agency: US Department of Education Federal Program Title: Student Financial Assistance Cluster Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Federal Award Identification Number and Year: Various Award Period: July 1, 2023, to June 30, 2024 Type of Finding: • Compliance, Other Matter • Material Weakness in Internal Control Over Compliance Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The Code of Federal Regulations, 34 CFR 682.610, states that institutions must report accurately the enrollment status of all students regardless of if they receive aid from the institution or not. Changes to said status are required to be reported within 30 days of becoming aware of the status change, or with the next scheduled transmission of statuses if the scheduled transmission is within 60 days. Condition: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 60 students, we identified 15 students with enrollment changes submitted past 60 days, 4 students had incorrect effective dates on campus enrollment, 5 were not certified at least every 60 days, 3 had program enrollment effective dates that did not match institutional records, 1 had incorrect program enrollment statuses, 1 student's enrollment change was never reported on campus enrollment and 4 had incorrect program begin dates. Questioned costs: None Cause: The College did not have proper procedures in place to verify students’ status in NSLDS matched the institutions records in a timely manner. Effect: The College was not in compliance with the requirements to properly report student enrollment data correctly. Incorrect dates submitted to NSLDS may be used to determine the grace period for the repayment and interest of outstanding Title IV student loans. Repeat finding: Yes; prior year finding number 2023-003 Recommendation: CLA recommends the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. View of responsible official: Management agrees with the finding and has already implemented a corrective plan.