Internal Control over Compliance and Compliance with the Reporting Compliance Requirement Identification of the Federal Program: United States Agency for International Development (USAID) Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Award Number: 720BHA24GR00016 Award Period: December 15, 2023 through December 31, 2026 Criteria or Specific Requirement: In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. In accordance with the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The prime awardee is required to file a Transparency Act sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant granter than or equal to $30,000. Condition: During BDO’s testing of the FFATA reporting, we tested the only subrecipient in the major program. ChildFund entered into the subaward agreement with the entity in January 2024, however ChildFund did not report activity in the FSRS system until October 2024. Cause: There was turnover at ChildFund in the personnel who is responsible for the Transparency Act reports and it was not initially identified that someone had not assumed that responsibility until our audit procedures identified the missing report. Effect: Failure to properly track all Transparency Act reporting requirements impacts the Federal agency from obtaining performance information required to assess award performance on a macro level. Questioned Costs: There are no questioned costs as the items outlined above are all matters relate to late submission of required reports. Context: This is a condition identified during BDO’s testing of Transparency Act reports. We tested the only required FFATA report submission for the year ended June 30, 2024. Repeat Finding: This finding is not a repeat finding. Recommendation: To facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, BDO recommends management implement a process by which approvals, submission considerations and supporting documentation for programmatic reports and Transparency Act reports is maintained in a centralized location. Views of Responsible Officials: Management agrees with the finding. Please see Appendix B for Management’s Corrective Action Plan.
Assistance Listing Number, Federal Agency, and Program Name - 97.039, Department of Homeland Security, FEMA Hazard Mitigation Grant Federal Award Identification Number and Year - Not applicable Pass through Entity - Michigan State Police Finding Type - Material weakness and material noncompliance with laws and regulations Criteria - Per 2 CFR 200.303(a) - The recipient and subrecipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - There is no evidence of review of the reports submitted to the funding agency. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - Based on the grant award date, the City submitted three quarterly reports. There was no evidence that the reports were reviewed prior to submission. Cause and Effect - The reports were not reviewed for completeness and accuracy prior to submission, and, as a result, the year end quarterly report included costs that were estimated to be 25 percent of the grant award rather than the actual costs incurred to date. Recommendation - The City should implement controls to ensure that reports are reviewed for completeness and accuracy prior to submission to the funding agency. Views of Responsible Officials and Corrective Action Plan - The City has implemented controls to have a secondary review of reports prior to submission to the funding agency.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P234721, P268K244721 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per the NSLDS Enrollment Reporting Guide, Published Program Length should be reported to NSLDS based on the definition of “normal time” to completion in the regulations at 34 CFR 668.41(a), as follows: • If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published. • If the school has not published a program length and the program is an associate or bachelor’s degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the program makes it longer or shorter than typical. • For all other programs for which the school has not published a program length, the program length is based on the school’s determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete. Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Questioned costs: None Context: The condition occurred for 4 out of the 22 students tested. Cause: The college uses the National Student Clearinghouse (NSC) to transmit transmitted over to the National Student Loan Data System (NSLDS). During the course of the year it was determined that information did not get calculated properly. Effect: Program length was misreported to NSLDS. Repeat Finding: No. Recommendation: We recommend the College report associate degree program length to NSLDS as two years. Views of Responsible Officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Aid Cluster Assistance Listing Number: 84.063, 84.268 Federal Award Identification Number: P063P234721, P268K244721 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Internal Control - Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance – Per the NSLDS Enrollment Reporting Guide, Published Program Length should be reported to NSLDS based on the definition of “normal time” to completion in the regulations at 34 CFR 668.41(a), as follows: • If the school has published, in its catalog, on its website, or in any promotional materials, the length of the program in weeks, months, or years, the program length reported must be the same as the program length that the school has published. • If the school has not published a program length and the program is an associate or bachelor’s degree program, the program length to be reported should be two years (associate) or four years (bachelor), respectively, unless the academic design of the program makes it longer or shorter than typical. • For all other programs for which the school has not published a program length, the program length is based on the school’s determination of how long, in weeks, months, or years, the program is designed for a full-time student to complete. Condition: The associate degree programs were not reported as two years per the recommendation in the NSLDS enrollment reporting guide. Questioned costs: None Context: The condition occurred for 4 out of the 22 students tested. Cause: The college uses the National Student Clearinghouse (NSC) to transmit transmitted over to the National Student Loan Data System (NSLDS). During the course of the year it was determined that information did not get calculated properly. Effect: Program length was misreported to NSLDS. Repeat Finding: No. Recommendation: We recommend the College report associate degree program length to NSLDS as two years. Views of Responsible Officials: There is no disagreement with the audit finding.
FINDING 2024-003 Information on the federal program: Subject: Education Stabilization Fund - Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the activities allowed or unallowed and allowable costs/cost principle compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: $9,498 Context: Two vouchers, in a sample of twenty-one vouchers selected for testing, were for an unallowable activity and unallowable costs. The vouchers related to transportation for students to Kings Island as an incentive for students who demonstrated that they were proficient in workplace skills such as attendance, emotion management, other soft skills. The two Kings Island vouchers tested were the only Kings Island vouchers in the population. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to the grant agreement and the activities allowed or unallowed and allowable costs/cost principle compliance requirements to ensure only allowable costs are charged to the grant award. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on Federal Programs U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program (passed through the North Dakota Division of Community Services, # 4995-LIHEAP21- 30, 5138-LIHEAP-ARPA-30, and 5195-LIHEAP23-30) U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program – Emergency Furnace Repair (passed through the North Dakota Division of Community Services, Award #5131-LIHEAPEF22-30 and 5055-LIHEAPEF-ARPA-30) AL# 93.568 Criteria – Section 2 CFR sections 200.303 requires that the auditee establish and maintain internal control over federal awards to provide reasonable assurance that the auditee is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition – For the year ended June 30, 2024, we requested supporting documentation to test the review and approval of a sample of costs charged to the LIHEAP grant. In a sample of 60 expenditures, we noted one instance where a journal entry which allocated expenses to the grant was not approved. Cause – Internal controls were updated mid-year to require the review of all journal entries charged to and reimbursed under federal grants. Effect or Potential Effect – Federal expenditures may not be in accordance with the allowable cost/cost principles standards under Uniform Guidance. Questioned Costs – Undeterminable Context – The expenditure selected for testing was a journal entry allocated costs but occurred prior to the change in the internal control requiring review of all journal entries. Repeat Finding – This is a new finding. Recommendation – The auditee should review all journal entries that were charged to federal grants and approve retroactively and document in a memo. Any errors noted should be correcting with the appropriate granting agencies.
Information on Federal Programs U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program (passed through the North Dakota Division of Community Services, # 4995-LIHEAP21- 30, 5138-LIHEAP-ARPA-30, and 5195-LIHEAP23-30) U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program – Emergency Furnace Repair (passed through the North Dakota Division of Community Services, Award #5131-LIHEAPEF22-30 and 5055-LIHEAPEF-ARPA-30) AL# 93.568 Criteria – Section 2 CFR sections 200.303 requires that the auditee establish and maintain internal control over federal awards to provide reasonable assurance that the auditee is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition – For the year ended June 30, 2024, we requested supporting documentation to test the review and approval of a sample of costs charged to the LIHEAP grant. In a sample of 60 expenditures, we noted one instance where a journal entry which allocated expenses to the grant was not approved. Cause – Internal controls were updated mid-year to require the review of all journal entries charged to and reimbursed under federal grants. Effect or Potential Effect – Federal expenditures may not be in accordance with the allowable cost/cost principles standards under Uniform Guidance. Questioned Costs – Undeterminable Context – The expenditure selected for testing was a journal entry allocated costs but occurred prior to the change in the internal control requiring review of all journal entries. Repeat Finding – This is a new finding. Recommendation – The auditee should review all journal entries that were charged to federal grants and approve retroactively and document in a memo. Any errors noted should be correcting with the appropriate granting agencies.
Information on Federal Programs U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program (passed through the North Dakota Division of Community Services, # 4995-LIHEAP21- 30, 5138-LIHEAP-ARPA-30, and 5195-LIHEAP23-30) U.S. Department of Health and Human Services – Low-Income Home Energy Assistance Program – Emergency Furnace Repair (passed through the North Dakota Division of Community Services, Award #5131-LIHEAPEF22-30 and 5055-LIHEAPEF-ARPA-30) AL# 93.568 Criteria – Section 2 CFR sections 200.303 requires that the auditee establish and maintain internal control over federal awards to provide reasonable assurance that the auditee is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition – For the year ended June 30, 2024, we requested supporting documentation to test the review and approval of a sample of costs charged to the LIHEAP grant. In a sample of 60 expenditures, we noted one instance where a journal entry which allocated expenses to the grant was not approved. Cause – Internal controls were updated mid-year to require the review of all journal entries charged to and reimbursed under federal grants. Effect or Potential Effect – Federal expenditures may not be in accordance with the allowable cost/cost principles standards under Uniform Guidance. Questioned Costs – Undeterminable Context – The expenditure selected for testing was a journal entry allocated costs but occurred prior to the change in the internal control requiring review of all journal entries. Repeat Finding – This is a new finding. Recommendation – The auditee should review all journal entries that were charged to federal grants and approve retroactively and document in a memo. Any errors noted should be correcting with the appropriate granting agencies.
U.S. Department of Health and Human Services Program Name: Maternal and Child Health Services Block Grant Federal Assistance Listing Number: 93.994 Significant Deficiency, Nonmaterial Noncompliance - Reporting Finding 2024-006 Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per 2 CFR 200.334 the recipient must retain all Federal award records for three years from the date of submission of their final financial report. Condition: During the audit we tested 13 reports and noted the following: a) There were four (4) instances out of 13 reports tested where the submitted reports were unable to be provided, including the date of submission for the reports. b) There were 10 instances out of 13 reports tested where the County was unable to provide evidence the report was reviewed prior to submission. Questioned Costs: None. Effect: By not having the required documentation and underlying support, the County is not able to demonstrate compliance with the applicable requirements. Cause: The County did not have a formal policy to ensure documentation was retained to evidence review and submission of all reports. Recommendation: The County should consider creating a formalized policy to require all submitted reports and underlying data are retained in accordance with the Uniform Grant Guidance requirements. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: See Corrective Action Plan prepared by the County.
Information on the federal program: U.S. Department of Treasury, Assistance Listing No. 21.027 COVID-19 Coronavirus Fiscal Recovery Funds Criteria: 2 CFR 200.302 and 2 CFR 200.303 require entities to establish and maintain internal controls and financial management procedures to provide reasonable assurance the award is managed in compliance with statutes, regulations, and terms and conditions of the award and to ensure federal award expenditures are adequately supported by source documentation. Condition: We tested controls over disbursements to 11 hospitals during the year. For each hospital to receive funding they were to submit a staffing spreadsheet reporting their increased staffing costs due to COVID. Of the 11 tested, supporting documentation for 3 hospitals was not readily available. Additional information had to be obtained from the hospital to support the information reported by the hospital in the staffing spreadsheet. Cause: Salary information obtained in support of the staffing spreadsheet included Employees Quarterly Federal Tax Return (941) and payroll registers. Additional general ledger information had to be requested from the hospitals during the audit to reconcile to the amounts reported in the staffing spreadsheet. Effect: Internal Controls were not properly implemented to obtain source documentation to adequately support the amounts reported by the hospitals as additional staffing costs. Recommendation: We recommend the Organization strengthen its policies and procedures surrounding disbursements to hospitals to ensure the amounts reported were accurate and source documentation is retained to ensure compliance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the findings. See Management’s View and Corrective Action Plan included at the end of the report.
Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and conditions of the Federal award. Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, the non‐Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in Onesite. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year.rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial.
Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and conditions of the Federal award. Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, the non‐Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in Onesite. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year.rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial.
Federal Award Identification Number and Year: 121-HD080-NP-CMI - Federal Award Identification Number and Year: 121-HD080-NP-CMI - 2024 Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, the non‐Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year.
Federal Award Identification Number and Year: 121-HD080-NP-CMI - Federal Award Identification Number and Year: 121-HD080-NP-CMI - 2024 Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, the non‐Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD002-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year. Repeat Finding: N/A
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD002-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year. Repeat Finding: N/A
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD002-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Tenant rent computation was not calculated correctly. Questioned costs: None Context: As part of our testing, we noted an issue with a tenant's rent computation, which resulted in undercharged rent. The rent computation requires that all of the tenant's income and assets be included in the calculation of the tenant's rent. The error occurred due to excluding a tenant's asset and rental income. These exclusions collectively understated the rent that should have been charged to the tenant. Cause: Management oversight to address all of the tenant's assets and income on the rent computation form. Effect: Noncompliance results in possible over charges to the grant. Repeat Finding: N/A
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD002-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Tenant rent computation was not calculated correctly. Questioned costs: None Context: As part of our testing, we noted an issue with a tenant's rent computation, which resulted in undercharged rent. The rent computation requires that all of the tenant's income and assets be included in the calculation of the tenant's rent. The error occurred due to excluding a tenant's asset and rental income. These exclusions collectively understated the rent that should have been charged to the tenant. Cause: Management oversight to address all of the tenant's assets and income on the rent computation form. Effect: Noncompliance results in possible over charges to the grant. Repeat Finding: N/A
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD098-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year. Repeat Finding: N/A
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD098-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year. Repeat Finding: N/A
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons With Disabilities Assistance Listing Number: 14.181 Federal Award Identification Number and Year: 121-HD098-NP-CMI - 2024 Pass-Through Agency: N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: According to §200.303 Internal Controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Income thresholds in Onesite on form HUD-50059 were not updated to the current year very low-income limits published by HUD for the County of Monterey. Questioned costs: None noted. Context: The dicrepancy in the maximum income limit was identified during our testing of tenant rent eligibility. The variance between the correct income limit and the form HUD-50059 income limit used to determine tenants’ eligibility is immaterial. Cause: Management oversight and lack of clarity on the party responsible for updating the income limits in One Site. Effect: Noncompliance results in possible exclusion of eligible applicants as the income limits increased from prior year. Repeat Finding: N/A
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -003 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.027 – Special Education Cluster (IDEA, Part B) And 84.425/84.425D/84.425U/84.425W Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Not applicable. Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
2024 -002 Approval Of Payroll Expense Transactions - Significant Deficiency - Activities Allowed Or Unallowed And Allowable Costs/Cost Principles ALNs 84.010 – Title I And 84.425/84.425C/84.425D/84.425U Elementary And Secondary School Emergency Relief Fund (ESSER) Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The School has an internal control in place that payroll transactions are approved by the respective principal prior to their submission for payment Condition: During the course of the audit, the engagement team identified multiple expenditures where the support showing the principal’s approval of the federal grant expense was unable to be provided. Cause: The entity did not maintain sufficient support documentation to prove that expenditures were reviewed before payroll transactions were submitted for payment. Effect: Potential noncompliance could occur if expenditure amounts are not reviewed by the principal for accuracy and completeness. Questioned Costs: Not applicable. Context: These audit findings represent a systemic issue. Identification As A Repeat Finding: Yes Recommendation: The School should maintain proper documentation of approvals for all payroll transactions. View Of Responsible Officials: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
1. FINDING NUMBER: 2024 - 002 2. THIS FINDING IS: New 3. Federal Program Name and Year: Child Nutrition Cluster - 2024 4. Project No.: 24-4210-00, 24-4220-00 5. AL No.: 10.553, 10.555 6. Passed Through: Illinois State Board of Education 7. Federal Agency: U.S. Department of Agriculture 8. Criteria or specific requirement (including statutory, regulatory, or other citation): According to 2 CFR §200.303, non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 9. Condition: During our audit of the Child Nutrition Cluster, we identified that the District did not have adequate disbursement controls in place. Specifically, duplicate invoices on multiple occasions were entered into the District's software system due to typographical errors, resulting in payments being made twice to each vendor for the same service. 10. Questioned Costs: The duplicated invoices do not impact the reimbursement received by the District due to the Child Nutrition Cluster being an open-ended entitlement grant, meaning they provide reimbursements based on the number of eligible meals served rather than all food service expenditures incurred. As a result, no questioned costs were identified. 11. Context: During our audit of the Child Nutrition Cluster's allowable activities, two separate instances of duplicated invoices were identified from a stratified sample size of forty. The sample was deemed not statistically valid. 12. Effect: The District incurred unnecessary expenses by paying vendors twice for the same service, which could result in financial losses and potential non-compliance with Federal regulations. The finding does not impact the reimbursement the District receives. 13. Cause: The lack of proper review and approval processes for invoice entry and payment, combined with typographical errors, led to the duplication of invoices and subsequent duplicate payments. 14. Recommendation: We recommend that the District implement stronger internal controls over the disbursement process. This includes establishing a review and approval process for all invoices before payment, implementing software controls to detect duplicate invoices, and providing training to staff on proper invoice processing procedures to minimize typographical errors. 15. Management's response: Management agrees with the finding and has initiated steps to enhance disbursement controls. These steps include revising the invoice approval process, upgrading the software system to flag duplicate invoices, and conducting training sessions for staff on the new procedures to reduce typographical errors.
1. FINDING NUMBER: 2024 - 002 2. THIS FINDING IS: New 3. Federal Program Name and Year: Child Nutrition Cluster - 2024 4. Project No.: 24-4210-00, 24-4220-00 5. AL No.: 10.553, 10.555 6. Passed Through: Illinois State Board of Education 7. Federal Agency: U.S. Department of Agriculture 8. Criteria or specific requirement (including statutory, regulatory, or other citation): According to 2 CFR §200.303, non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 9. Condition: During our audit of the Child Nutrition Cluster, we identified that the District did not have adequate disbursement controls in place. Specifically, duplicate invoices on multiple occasions were entered into the District's software system due to typographical errors, resulting in payments being made twice to each vendor for the same service. 10. Questioned Costs: The duplicated invoices do not impact the reimbursement received by the District due to the Child Nutrition Cluster being an open-ended entitlement grant, meaning they provide reimbursements based on the number of eligible meals served rather than all food service expenditures incurred. As a result, no questioned costs were identified. 11. Context: During our audit of the Child Nutrition Cluster's allowable activities, two separate instances of duplicated invoices were identified from a stratified sample size of forty. The sample was deemed not statistically valid. 12. Effect: The District incurred unnecessary expenses by paying vendors twice for the same service, which could result in financial losses and potential non-compliance with Federal regulations. The finding does not impact the reimbursement the District receives. 13. Cause: The lack of proper review and approval processes for invoice entry and payment, combined with typographical errors, led to the duplication of invoices and subsequent duplicate payments. 14. Recommendation: We recommend that the District implement stronger internal controls over the disbursement process. This includes establishing a review and approval process for all invoices before payment, implementing software controls to detect duplicate invoices, and providing training to staff on proper invoice processing procedures to minimize typographical errors. 15. Management's response: Management agrees with the finding and has initiated steps to enhance disbursement controls. These steps include revising the invoice approval process, upgrading the software system to flag duplicate invoices, and conducting training sessions for staff on the new procedures to reduce typographical errors.
FINDING 2024-004 Information on the federal program: Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards 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 terms and conditions of the Federal award. Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Special Education Cluster and Activities Allowed or Unallowed. Cause: The School District's management had not developed a system of internal controls that would have ensured compliance with the Activities Allowed or Unallowed compliance requirement. Effect: The failure to establish an effective internal control system placed the School District 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 we no questioned costs identified. Context: During the testing of a sample of 40 payroll disbursements charged to the Special Education Cluster during the audit period, the following exceptions were noted: For eight transactions selected, management was unable to provide an approved contract to support the selected employees' bi-weekly pay rate. For two transactions selected, management was unable to provide approved timecards for the selected hourly employee and time period. For seven transactions selected, management was unable to provide time and effort logs to support the allocation of one employee’s salary between the federal grant and the Education fund. The lack of controls was systematic throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School District's management establish a system of internal controls related to payroll disbursement charged to federal awards to ensure that the costs allocated are properly supported by contracts, timecards, and that the methodology for salary employees allocated to grant are supported by time and effort documentation. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-004 Information on the federal program: Subject: Special Education Cluster (IDEA) – Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards 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 terms and conditions of the Federal award. Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Special Education Cluster and Activities Allowed or Unallowed. Cause: The School District's management had not developed a system of internal controls that would have ensured compliance with the Activities Allowed or Unallowed compliance requirement. Effect: The failure to establish an effective internal control system placed the School District 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 we no questioned costs identified. Context: During the testing of a sample of 40 payroll disbursements charged to the Special Education Cluster during the audit period, the following exceptions were noted: For eight transactions selected, management was unable to provide an approved contract to support the selected employees' bi-weekly pay rate. For two transactions selected, management was unable to provide approved timecards for the selected hourly employee and time period. For seven transactions selected, management was unable to provide time and effort logs to support the allocation of one employee’s salary between the federal grant and the Education fund. The lack of controls was systematic throughout the audit period. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School District's management establish a system of internal controls related to payroll disbursement charged to federal awards to ensure that the costs allocated are properly supported by contracts, timecards, and that the methodology for salary employees allocated to grant are supported by time and effort documentation. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-002 Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Activities Allowed or Unallowed Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards 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 terms and conditions of the Federal award. Condition: An effective internal control system was not in place at the School District to ensure compliance with requirements related to the Education Stabilization Fund and Activities Allowed or Unallowed. Cause: The School District's management had not developed a system of internal controls that would have ensured compliance with the Activities Allowed or Unallowed compliance requirement. Effect: The failure to establish an effective internal control system placed the School District 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: $730.43 Context: During the testing of payroll disbursements charged to the Education Stabilization Fund grant awards during the audit period, the following exceptions were noted: For 16 payroll disbursements, in a sample of 40, management was unable to provide an approved employee contract or hourly rate ordinance to support the selected employees' bi-weekly pay rate. For one transaction selection, an employee received a $730.43 one-time payment for a Teacher Appreciation Grant (TAG) funded by the 84.425U award. The Teacher Appreciation Grant has its own fund and is a state/local grant received to reward high-performing, eligible certified staff. The selected employee is a non-certified employee and did not qualify for a TAG award. There was no documentation provided to support work performed under this award to support allowability of the cost incurred. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School District maintain supporting documentation for vendor and payroll disbursements to support costs charged to the federal grant awards. For payroll disbursements charged to Federal awards, management should maintain time records to support payroll costs allocated to Education Stabilization Grant funds to verify they are allowable and supported by documentation for work performed under the award. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2024-003 Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting 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). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School District in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School District's management had not developed a system of internal controls to ensure compliance with the compliance requirements listed above. Effect: The failure to establish an effective internal control system placed the School District 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: The School Corporation had not designed nor implemented a system of internal control to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The reports were prepared and submitted in JotForm, the online application used by the Indiana Department of Education to collect information, without an oversight or secondary review process in place to prevent, or detect and correct, errors. During tie out of the Year 3 report, a variance between the underlying records and reported expenditures of $187,649 was noted due to the lack of effective controls surrounding annual data reporting. 84.425U expenditures submitted within the Year 3 report were overstated by $187,649. Identification as a repeat finding: Yes, see Finding 2022-001. Recommendation: We recommend someone other than the preparer of the report perform a documented, secondary review of the report information prior to submission to validate the accuracy and completeness of the data submitted. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.