Information on the federal program: Subject: Special Education Cluster – Internal Controls Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listing Number: 84.027, 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-123-PN01, 23611-0123-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Special Education Cluster and Procurement compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For the three small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The total amount disbursed for the sample items was $114,123 in FY23 and $13,404 in FY24 for contracted rehabilitation therapy and speech pathology services. The School Corporation did properly perform a suspension and debarment checks on the sample vendors. Identification as a repeat finding: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that the School Corporation’s procurement policy is adhered to and quotes are obtained from an adequate number of qualified sources as required for small purchase method procurements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements 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: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance, Qualified Opinion 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). . . ." 29 CFR 5.5 states in part: (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics… (3)(ii)(A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). 2 CFR 200 Appendix II states in part: In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week.. . .” 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 Special Tests and Provisions – Wage Rate Requirements 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 design and implement an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: For the three projects sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the companies that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. Additionally, the School Corporation did not have contracts with the companies that included the clause for the federal wage rate requirements. The total amount disbursed and reported on the SEFA during the audit period is $648,235 and the labor portion was not determinable by the School Corporation. Identification as a repeat finding: This is a repeat finding from the immediately prior audit. The prior finding number was 2022-002. Recommendation: We recommend the School Corporation implement a formal process to ensure the required weekly payroll reports certifications are collected and reviewed to ensure compliance with the wage rate requirements. Additionally, We recommend the School Corporation implement a formal process to ensure the contracts including labor costs over $2,000 funded by federal awards have Davis Bacon wage rate requirement clause in written contract. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Federal Agencies: US Department of Defense (DoD); US Department of Energy (DOE); US Health and Human Services (HHS) Program Names: Research & Development Cluster: Basic, Applied and Advanced Research in Science and Engineering; Fossil Energy Research and Development; COVID19 – Discovery and Applied Research for Technological Innovations to Improve Human Health; Research and Technology Development; Office of Science and Financial Assistance Program; Air Force Defense Research Sciences Program; Cardiovascular Diseases Research; Health Center Program Cluster: Community Health Centers; and AIDS Education and Training Centers ALN #s: 12.630; 81.089; 93.286; 12.910; 81.049; 12.800; 93.837; 93.224; and 93.145 Award Numbers: ARMY W911NF-17-2-0196; DOE DE-FE0031581; DOE DE-FE0032049; NIH 1 R21 EB031310A; DARPA HR011-23-2-0004; DOE DE-SC0018420; AF FA9550-23-1-0609; SNAP 5R01HL152692-04; HRSA 5 U1OHA29293-09-03; and HRSA 5 U1OHA32109-07 Federal Award Year 2023 – 2024 Questioned Costs: None 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not make certain subrecipient payments timely and the controls in place did not identify the late payments. Condition: Out of thirty-two subrecipient payments tested which were made by the University of Illinois at Urbana-Champaign under the Research & Development Cluster, twelve payments (38%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 35-201 days after receipt of the billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. Out of eight subrecipient payments tested which were made by the University of Illinois Chicago under the Research & Development Cluster, one payment (13%) was not submitted within 30 days after receipt of the billing from the subrecipient. The payment was 32 days after the receipt of billing from the subrecipient. The sample was not intended to be, and was not, a statistically valid sample. Out of eighteen subrecipient payments tested which were made by the University of Illinois Chicago under the Health Center Program Cluster: Community Health Centers and AIDS Education and Training Centers, five payments (28%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 42-120 days after the receipt of billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments (Continued) Criteria: Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Cause: University of Illinois Urbana-Champaign officials stated the multi-layered review and approval process along with staffing deficiencies and workload challenges caused the situations for the exceptions noted. University of Illinois Chicago officials stated the one payment was paid 32 days from receipt of the invoice due to high volumes of invoice processing at fiscal year end and the payment due date coinciding with a holiday. The five other subrecipient payments were due to high staff workloads and occurred prior to the fiscal year 2023 corrective action implementation. Effect: Without proper program cash management processes and procedures, late subrecipient payments could result in the loss of future funding. (Finding Code No. 2024-002; 2023-006; 2022-008) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes, policies and procedures to minimize the time elapsing between the transfer of federal funds to the subrecipient. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Defense (DoD); US Department of Energy (DOE); US Health and Human Services (HHS) Program Names: Research & Development Cluster: Basic, Applied and Advanced Research in Science and Engineering; Fossil Energy Research and Development; COVID19 – Discovery and Applied Research for Technological Innovations to Improve Human Health; Research and Technology Development; Office of Science and Financial Assistance Program; Air Force Defense Research Sciences Program; Cardiovascular Diseases Research; Health Center Program Cluster: Community Health Centers; and AIDS Education and Training Centers ALN #s: 12.630; 81.089; 93.286; 12.910; 81.049; 12.800; 93.837; 93.224; and 93.145 Award Numbers: ARMY W911NF-17-2-0196; DOE DE-FE0031581; DOE DE-FE0032049; NIH 1 R21 EB031310A; DARPA HR011-23-2-0004; DOE DE-SC0018420; AF FA9550-23-1-0609; SNAP 5R01HL152692-04; HRSA 5 U1OHA29293-09-03; and HRSA 5 U1OHA32109-07 Federal Award Year 2023 – 2024 Questioned Costs: None 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not make certain subrecipient payments timely and the controls in place did not identify the late payments. Condition: Out of thirty-two subrecipient payments tested which were made by the University of Illinois at Urbana-Champaign under the Research & Development Cluster, twelve payments (38%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 35-201 days after receipt of the billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. Out of eight subrecipient payments tested which were made by the University of Illinois Chicago under the Research & Development Cluster, one payment (13%) was not submitted within 30 days after receipt of the billing from the subrecipient. The payment was 32 days after the receipt of billing from the subrecipient. The sample was not intended to be, and was not, a statistically valid sample. Out of eighteen subrecipient payments tested which were made by the University of Illinois Chicago under the Health Center Program Cluster: Community Health Centers and AIDS Education and Training Centers, five payments (28%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 42-120 days after the receipt of billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments (Continued) Criteria: Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Cause: University of Illinois Urbana-Champaign officials stated the multi-layered review and approval process along with staffing deficiencies and workload challenges caused the situations for the exceptions noted. University of Illinois Chicago officials stated the one payment was paid 32 days from receipt of the invoice due to high volumes of invoice processing at fiscal year end and the payment due date coinciding with a holiday. The five other subrecipient payments were due to high staff workloads and occurred prior to the fiscal year 2023 corrective action implementation. Effect: Without proper program cash management processes and procedures, late subrecipient payments could result in the loss of future funding. (Finding Code No. 2024-002; 2023-006; 2022-008) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes, policies and procedures to minimize the time elapsing between the transfer of federal funds to the subrecipient. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Defense (DoD); US Department of Energy (DOE); US Health and Human Services (HHS) Program Names: Research & Development Cluster: Basic, Applied and Advanced Research in Science and Engineering; Fossil Energy Research and Development; COVID19 – Discovery and Applied Research for Technological Innovations to Improve Human Health; Research and Technology Development; Office of Science and Financial Assistance Program; Air Force Defense Research Sciences Program; Cardiovascular Diseases Research; Health Center Program Cluster: Community Health Centers; and AIDS Education and Training Centers ALN #s: 12.630; 81.089; 93.286; 12.910; 81.049; 12.800; 93.837; 93.224; and 93.145 Award Numbers: ARMY W911NF-17-2-0196; DOE DE-FE0031581; DOE DE-FE0032049; NIH 1 R21 EB031310A; DARPA HR011-23-2-0004; DOE DE-SC0018420; AF FA9550-23-1-0609; SNAP 5R01HL152692-04; HRSA 5 U1OHA29293-09-03; and HRSA 5 U1OHA32109-07 Federal Award Year 2023 – 2024 Questioned Costs: None 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not make certain subrecipient payments timely and the controls in place did not identify the late payments. Condition: Out of thirty-two subrecipient payments tested which were made by the University of Illinois at Urbana-Champaign under the Research & Development Cluster, twelve payments (38%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 35-201 days after receipt of the billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. Out of eight subrecipient payments tested which were made by the University of Illinois Chicago under the Research & Development Cluster, one payment (13%) was not submitted within 30 days after receipt of the billing from the subrecipient. The payment was 32 days after the receipt of billing from the subrecipient. The sample was not intended to be, and was not, a statistically valid sample. Out of eighteen subrecipient payments tested which were made by the University of Illinois Chicago under the Health Center Program Cluster: Community Health Centers and AIDS Education and Training Centers, five payments (28%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 42-120 days after the receipt of billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments (Continued) Criteria: Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Cause: University of Illinois Urbana-Champaign officials stated the multi-layered review and approval process along with staffing deficiencies and workload challenges caused the situations for the exceptions noted. University of Illinois Chicago officials stated the one payment was paid 32 days from receipt of the invoice due to high volumes of invoice processing at fiscal year end and the payment due date coinciding with a holiday. The five other subrecipient payments were due to high staff workloads and occurred prior to the fiscal year 2023 corrective action implementation. Effect: Without proper program cash management processes and procedures, late subrecipient payments could result in the loss of future funding. (Finding Code No. 2024-002; 2023-006; 2022-008) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes, policies and procedures to minimize the time elapsing between the transfer of federal funds to the subrecipient. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Defense (DoD); US Department of Energy (DOE); US Health and Human Services (HHS) Program Names: Research & Development Cluster: Basic, Applied and Advanced Research in Science and Engineering; Fossil Energy Research and Development; COVID19 – Discovery and Applied Research for Technological Innovations to Improve Human Health; Research and Technology Development; Office of Science and Financial Assistance Program; Air Force Defense Research Sciences Program; Cardiovascular Diseases Research; Health Center Program Cluster: Community Health Centers; and AIDS Education and Training Centers ALN #s: 12.630; 81.089; 93.286; 12.910; 81.049; 12.800; 93.837; 93.224; and 93.145 Award Numbers: ARMY W911NF-17-2-0196; DOE DE-FE0031581; DOE DE-FE0032049; NIH 1 R21 EB031310A; DARPA HR011-23-2-0004; DOE DE-SC0018420; AF FA9550-23-1-0609; SNAP 5R01HL152692-04; HRSA 5 U1OHA29293-09-03; and HRSA 5 U1OHA32109-07 Federal Award Year 2023 – 2024 Questioned Costs: None 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not make certain subrecipient payments timely and the controls in place did not identify the late payments. Condition: Out of thirty-two subrecipient payments tested which were made by the University of Illinois at Urbana-Champaign under the Research & Development Cluster, twelve payments (38%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 35-201 days after receipt of the billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. Out of eight subrecipient payments tested which were made by the University of Illinois Chicago under the Research & Development Cluster, one payment (13%) was not submitted within 30 days after receipt of the billing from the subrecipient. The payment was 32 days after the receipt of billing from the subrecipient. The sample was not intended to be, and was not, a statistically valid sample. Out of eighteen subrecipient payments tested which were made by the University of Illinois Chicago under the Health Center Program Cluster: Community Health Centers and AIDS Education and Training Centers, five payments (28%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 42-120 days after the receipt of billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments (Continued) Criteria: Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Cause: University of Illinois Urbana-Champaign officials stated the multi-layered review and approval process along with staffing deficiencies and workload challenges caused the situations for the exceptions noted. University of Illinois Chicago officials stated the one payment was paid 32 days from receipt of the invoice due to high volumes of invoice processing at fiscal year end and the payment due date coinciding with a holiday. The five other subrecipient payments were due to high staff workloads and occurred prior to the fiscal year 2023 corrective action implementation. Effect: Without proper program cash management processes and procedures, late subrecipient payments could result in the loss of future funding. (Finding Code No. 2024-002; 2023-006; 2022-008) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes, policies and procedures to minimize the time elapsing between the transfer of federal funds to the subrecipient. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agency: US Department of Education (ED) Program Name: Student Financial Assistance Cluster: Federal Direct Student Loans ALN #: 84.268 Award Numbers: N/A; Federal Award Year 2023 - 2024 Questioned Costs: None 2024-003. Finding: Errors in Reporting for NSLDS The University of Illinois Chicago did not properly report an enrollment change for a student who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not identify the error. Condition: Out of the twenty-five students tested at the University of Illinois Chicago, we noted one (4%) student in which the University did not report the correct enrollment effective date to the NSLDS at the Program-Level. The sample was not intended to be, and was not, a statistically valid sample. Criteria: The Code of Federal Regulations (34 CFR 685.309) requires enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. According to the NSLDS Enrollment Reporting Guide, a student’s Program-Level enrollment status should be reported with the same enrollment status as student’s Campus-Level enrollment status for all programs the student is enrolled in at a location, even if the student is not currently taking coursework which applies to a particular program. If the student has withdrawn or graduated from an academic program, a “terminal enrollment status” of ‘W’ or ‘G,’ as appropriate, should be reported for the program, even if the student is still taking coursework applicable to other programs in which the student is enrolled. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure enrollment reporting is completed properly. Cause: University officials stated despite a defect resolution implemented in June 2023, an issue remains unresolved with the NSLDS reporting process. Further targeted investigation into the NSLDS reporting process is ongoing. 2024-003. Finding: Errors in Reporting for NSLDS (Continued) Effect: If the NSLDS system is not updated with the student information, overawards could occur should the student transfer to another institution and the student may not properly enter the repayment period. (Finding Code No. 2024-003; 2023-007; 2022-006; 2021-010; 2020-006) Recommendation: We recommend the University of Illinois Chicago review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Defense (DoD); US Department of Energy (DOE); US Health and Human Services (HHS) Program Names: Research & Development Cluster: Basic, Applied and Advanced Research in Science and Engineering; Fossil Energy Research and Development; COVID19 – Discovery and Applied Research for Technological Innovations to Improve Human Health; Research and Technology Development; Office of Science and Financial Assistance Program; Air Force Defense Research Sciences Program; Cardiovascular Diseases Research; Health Center Program Cluster: Community Health Centers; and AIDS Education and Training Centers ALN #s: 12.630; 81.089; 93.286; 12.910; 81.049; 12.800; 93.837; 93.224; and 93.145 Award Numbers: ARMY W911NF-17-2-0196; DOE DE-FE0031581; DOE DE-FE0032049; NIH 1 R21 EB031310A; DARPA HR011-23-2-0004; DOE DE-SC0018420; AF FA9550-23-1-0609; SNAP 5R01HL152692-04; HRSA 5 U1OHA29293-09-03; and HRSA 5 U1OHA32109-07 Federal Award Year 2023 – 2024 Questioned Costs: None 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not make certain subrecipient payments timely and the controls in place did not identify the late payments. Condition: Out of thirty-two subrecipient payments tested which were made by the University of Illinois at Urbana-Champaign under the Research & Development Cluster, twelve payments (38%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 35-201 days after receipt of the billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. Out of eight subrecipient payments tested which were made by the University of Illinois Chicago under the Research & Development Cluster, one payment (13%) was not submitted within 30 days after receipt of the billing from the subrecipient. The payment was 32 days after the receipt of billing from the subrecipient. The sample was not intended to be, and was not, a statistically valid sample. Out of eighteen subrecipient payments tested which were made by the University of Illinois Chicago under the Health Center Program Cluster: Community Health Centers and AIDS Education and Training Centers, five payments (28%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 42-120 days after the receipt of billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments (Continued) Criteria: Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Cause: University of Illinois Urbana-Champaign officials stated the multi-layered review and approval process along with staffing deficiencies and workload challenges caused the situations for the exceptions noted. University of Illinois Chicago officials stated the one payment was paid 32 days from receipt of the invoice due to high volumes of invoice processing at fiscal year end and the payment due date coinciding with a holiday. The five other subrecipient payments were due to high staff workloads and occurred prior to the fiscal year 2023 corrective action implementation. Effect: Without proper program cash management processes and procedures, late subrecipient payments could result in the loss of future funding. (Finding Code No. 2024-002; 2023-006; 2022-008) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes, policies and procedures to minimize the time elapsing between the transfer of federal funds to the subrecipient. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Defense (DoD); US Department of Energy (DOE); US Health and Human Services (HHS) Program Names: Research & Development Cluster: Basic, Applied and Advanced Research in Science and Engineering; Fossil Energy Research and Development; COVID19 – Discovery and Applied Research for Technological Innovations to Improve Human Health; Research and Technology Development; Office of Science and Financial Assistance Program; Air Force Defense Research Sciences Program; Cardiovascular Diseases Research; Health Center Program Cluster: Community Health Centers; and AIDS Education and Training Centers ALN #s: 12.630; 81.089; 93.286; 12.910; 81.049; 12.800; 93.837; 93.224; and 93.145 Award Numbers: ARMY W911NF-17-2-0196; DOE DE-FE0031581; DOE DE-FE0032049; NIH 1 R21 EB031310A; DARPA HR011-23-2-0004; DOE DE-SC0018420; AF FA9550-23-1-0609; SNAP 5R01HL152692-04; HRSA 5 U1OHA29293-09-03; and HRSA 5 U1OHA32109-07 Federal Award Year 2023 – 2024 Questioned Costs: None 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not make certain subrecipient payments timely and the controls in place did not identify the late payments. Condition: Out of thirty-two subrecipient payments tested which were made by the University of Illinois at Urbana-Champaign under the Research & Development Cluster, twelve payments (38%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 35-201 days after receipt of the billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. Out of eight subrecipient payments tested which were made by the University of Illinois Chicago under the Research & Development Cluster, one payment (13%) was not submitted within 30 days after receipt of the billing from the subrecipient. The payment was 32 days after the receipt of billing from the subrecipient. The sample was not intended to be, and was not, a statistically valid sample. Out of eighteen subrecipient payments tested which were made by the University of Illinois Chicago under the Health Center Program Cluster: Community Health Centers and AIDS Education and Training Centers, five payments (28%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 42-120 days after the receipt of billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments (Continued) Criteria: Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Cause: University of Illinois Urbana-Champaign officials stated the multi-layered review and approval process along with staffing deficiencies and workload challenges caused the situations for the exceptions noted. University of Illinois Chicago officials stated the one payment was paid 32 days from receipt of the invoice due to high volumes of invoice processing at fiscal year end and the payment due date coinciding with a holiday. The five other subrecipient payments were due to high staff workloads and occurred prior to the fiscal year 2023 corrective action implementation. Effect: Without proper program cash management processes and procedures, late subrecipient payments could result in the loss of future funding. (Finding Code No. 2024-002; 2023-006; 2022-008) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes, policies and procedures to minimize the time elapsing between the transfer of federal funds to the subrecipient. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Agriculture (USDA), US Department of Energy (DOE), US Health & Human Services (HHS) Program Names: Research & Development Cluster: Agriculture and Food Research Initiative (AFRI); Office of Science Financial Assistance Program; Fossil Energy Research and Development; Alcohol Research Programs; Cardiovascular Diseases Research; Arthritis, Musculoskeletal and Skin Diseases Research; Vision Research ALN #s: 10.310; 81.049; 81.089; 93.273; 93.837; 93.846; and 93.867 Award Numbers: AG NIFA 2021-68012-35898; DOE DE-SC0018420; DOE DE-FE0032049; SNAP 5P50AA022538 10; SNAP 5R01HL152692-04; Snp 5R01AR081448-02; and NEI 5 P30 EY001792-45 Questioned Costs: None 2024-004. Finding: Internal Controls over Procurement The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not have sufficient rationale documented for the noncompetitive procurement method selected within their iBuy system at the time of approval of the purchase to allow a reviewer to determine the appropriateness of the procurement method in the Research and Development Cluster. Condition: The University of Illinois Urbana-Champaign and the University of Illinois Chicago’s internal controls over small purchases include review and approval of a purchase requisition form that documents the procurement method selected. Within the iBuy system, when a noncompetitive procurement method is selected, a radio button allows for selection of one of several circumstances where noncompetitive procurement is permitted by 2 CFR 200.320, including that the procurement can only be fulfilled by a single source. When this selection is made, additional information supporting this rationale should be available to the reviewer to determine that this noncompetitive procurement method is appropriate. We noted instances where there was not evidence that this information was available to the reviewer at the time of the approval. Out of twenty-nine small purchase procurement transactions tested at the University of Illinois Urbana-Champaign, for five transactions (17%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Out of eleven small purchase procurement transactions tested at the University of Illinois Chicago, for six transactions (55%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Based on additional information provided to us during our testing, there were no indications that the noncompetitive procurement methods selected were inappropriate. The sample was not intended to be, and was not, a statistically valid sample. 2024-004. Finding: Internal Controls over Procurement (Continued) Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained as required by 2 CFR 200.318. Cause: University officials stated a single e-procurement system is used to collect and capture procurement-related information. The electronic system required selection of the relevant procurement method in the form of a radio button, but did not require additional information in the central procurement file. Rather, this information was maintained by the requesting unit. Effect: If the procurement purchase requisition forms do not include sufficient supporting documentation of the rationale for the noncompetitive method of procurement selected, the University could approve payments of federal funds to vendors that do not meet federal regulations. (Finding Code 2024-004) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes within the iBuy system for noncompetitive procurement transactions to ensure sufficient documentation is included to support the rationale for the noncompetitive method of procurement selected. University Response: Accepted. While the University agrees that the supporting documentation was not captured in the electronic payment system, the rationale was available in other University records. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Defense (DoD); US Department of Energy (DOE); US Health and Human Services (HHS) Program Names: Research & Development Cluster: Basic, Applied and Advanced Research in Science and Engineering; Fossil Energy Research and Development; COVID19 – Discovery and Applied Research for Technological Innovations to Improve Human Health; Research and Technology Development; Office of Science and Financial Assistance Program; Air Force Defense Research Sciences Program; Cardiovascular Diseases Research; Health Center Program Cluster: Community Health Centers; and AIDS Education and Training Centers ALN #s: 12.630; 81.089; 93.286; 12.910; 81.049; 12.800; 93.837; 93.224; and 93.145 Award Numbers: ARMY W911NF-17-2-0196; DOE DE-FE0031581; DOE DE-FE0032049; NIH 1 R21 EB031310A; DARPA HR011-23-2-0004; DOE DE-SC0018420; AF FA9550-23-1-0609; SNAP 5R01HL152692-04; HRSA 5 U1OHA29293-09-03; and HRSA 5 U1OHA32109-07 Federal Award Year 2023 – 2024 Questioned Costs: None 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not make certain subrecipient payments timely and the controls in place did not identify the late payments. Condition: Out of thirty-two subrecipient payments tested which were made by the University of Illinois at Urbana-Champaign under the Research & Development Cluster, twelve payments (38%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 35-201 days after receipt of the billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. Out of eight subrecipient payments tested which were made by the University of Illinois Chicago under the Research & Development Cluster, one payment (13%) was not submitted within 30 days after receipt of the billing from the subrecipient. The payment was 32 days after the receipt of billing from the subrecipient. The sample was not intended to be, and was not, a statistically valid sample. Out of eighteen subrecipient payments tested which were made by the University of Illinois Chicago under the Health Center Program Cluster: Community Health Centers and AIDS Education and Training Centers, five payments (28%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 42-120 days after the receipt of billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments (Continued) Criteria: Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Cause: University of Illinois Urbana-Champaign officials stated the multi-layered review and approval process along with staffing deficiencies and workload challenges caused the situations for the exceptions noted. University of Illinois Chicago officials stated the one payment was paid 32 days from receipt of the invoice due to high volumes of invoice processing at fiscal year end and the payment due date coinciding with a holiday. The five other subrecipient payments were due to high staff workloads and occurred prior to the fiscal year 2023 corrective action implementation. Effect: Without proper program cash management processes and procedures, late subrecipient payments could result in the loss of future funding. (Finding Code No. 2024-002; 2023-006; 2022-008) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes, policies and procedures to minimize the time elapsing between the transfer of federal funds to the subrecipient. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Defense (DoD); US Department of Energy (DOE); US Health and Human Services (HHS) Program Names: Research & Development Cluster: Basic, Applied and Advanced Research in Science and Engineering; Fossil Energy Research and Development; COVID19 – Discovery and Applied Research for Technological Innovations to Improve Human Health; Research and Technology Development; Office of Science and Financial Assistance Program; Air Force Defense Research Sciences Program; Cardiovascular Diseases Research; Health Center Program Cluster: Community Health Centers; and AIDS Education and Training Centers ALN #s: 12.630; 81.089; 93.286; 12.910; 81.049; 12.800; 93.837; 93.224; and 93.145 Award Numbers: ARMY W911NF-17-2-0196; DOE DE-FE0031581; DOE DE-FE0032049; NIH 1 R21 EB031310A; DARPA HR011-23-2-0004; DOE DE-SC0018420; AF FA9550-23-1-0609; SNAP 5R01HL152692-04; HRSA 5 U1OHA29293-09-03; and HRSA 5 U1OHA32109-07 Federal Award Year 2023 – 2024 Questioned Costs: None 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not make certain subrecipient payments timely and the controls in place did not identify the late payments. Condition: Out of thirty-two subrecipient payments tested which were made by the University of Illinois at Urbana-Champaign under the Research & Development Cluster, twelve payments (38%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 35-201 days after receipt of the billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. Out of eight subrecipient payments tested which were made by the University of Illinois Chicago under the Research & Development Cluster, one payment (13%) was not submitted within 30 days after receipt of the billing from the subrecipient. The payment was 32 days after the receipt of billing from the subrecipient. The sample was not intended to be, and was not, a statistically valid sample. Out of eighteen subrecipient payments tested which were made by the University of Illinois Chicago under the Health Center Program Cluster: Community Health Centers and AIDS Education and Training Centers, five payments (28%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 42-120 days after the receipt of billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments (Continued) Criteria: Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Cause: University of Illinois Urbana-Champaign officials stated the multi-layered review and approval process along with staffing deficiencies and workload challenges caused the situations for the exceptions noted. University of Illinois Chicago officials stated the one payment was paid 32 days from receipt of the invoice due to high volumes of invoice processing at fiscal year end and the payment due date coinciding with a holiday. The five other subrecipient payments were due to high staff workloads and occurred prior to the fiscal year 2023 corrective action implementation. Effect: Without proper program cash management processes and procedures, late subrecipient payments could result in the loss of future funding. (Finding Code No. 2024-002; 2023-006; 2022-008) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes, policies and procedures to minimize the time elapsing between the transfer of federal funds to the subrecipient. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Agriculture (USDA), US Department of Energy (DOE), US Health & Human Services (HHS) Program Names: Research & Development Cluster: Agriculture and Food Research Initiative (AFRI); Office of Science Financial Assistance Program; Fossil Energy Research and Development; Alcohol Research Programs; Cardiovascular Diseases Research; Arthritis, Musculoskeletal and Skin Diseases Research; Vision Research ALN #s: 10.310; 81.049; 81.089; 93.273; 93.837; 93.846; and 93.867 Award Numbers: AG NIFA 2021-68012-35898; DOE DE-SC0018420; DOE DE-FE0032049; SNAP 5P50AA022538 10; SNAP 5R01HL152692-04; Snp 5R01AR081448-02; and NEI 5 P30 EY001792-45 Questioned Costs: None 2024-004. Finding: Internal Controls over Procurement The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not have sufficient rationale documented for the noncompetitive procurement method selected within their iBuy system at the time of approval of the purchase to allow a reviewer to determine the appropriateness of the procurement method in the Research and Development Cluster. Condition: The University of Illinois Urbana-Champaign and the University of Illinois Chicago’s internal controls over small purchases include review and approval of a purchase requisition form that documents the procurement method selected. Within the iBuy system, when a noncompetitive procurement method is selected, a radio button allows for selection of one of several circumstances where noncompetitive procurement is permitted by 2 CFR 200.320, including that the procurement can only be fulfilled by a single source. When this selection is made, additional information supporting this rationale should be available to the reviewer to determine that this noncompetitive procurement method is appropriate. We noted instances where there was not evidence that this information was available to the reviewer at the time of the approval. Out of twenty-nine small purchase procurement transactions tested at the University of Illinois Urbana-Champaign, for five transactions (17%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Out of eleven small purchase procurement transactions tested at the University of Illinois Chicago, for six transactions (55%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Based on additional information provided to us during our testing, there were no indications that the noncompetitive procurement methods selected were inappropriate. The sample was not intended to be, and was not, a statistically valid sample. 2024-004. Finding: Internal Controls over Procurement (Continued) Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained as required by 2 CFR 200.318. Cause: University officials stated a single e-procurement system is used to collect and capture procurement-related information. The electronic system required selection of the relevant procurement method in the form of a radio button, but did not require additional information in the central procurement file. Rather, this information was maintained by the requesting unit. Effect: If the procurement purchase requisition forms do not include sufficient supporting documentation of the rationale for the noncompetitive method of procurement selected, the University could approve payments of federal funds to vendors that do not meet federal regulations. (Finding Code 2024-004) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes within the iBuy system for noncompetitive procurement transactions to ensure sufficient documentation is included to support the rationale for the noncompetitive method of procurement selected. University Response: Accepted. While the University agrees that the supporting documentation was not captured in the electronic payment system, the rationale was available in other University records. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Agriculture (USDA), US Department of Energy (DOE), US Health & Human Services (HHS) Program Names: Research & Development Cluster: Agriculture and Food Research Initiative (AFRI); Office of Science Financial Assistance Program; Fossil Energy Research and Development; Alcohol Research Programs; Cardiovascular Diseases Research; Arthritis, Musculoskeletal and Skin Diseases Research; Vision Research ALN #s: 10.310; 81.049; 81.089; 93.273; 93.837; 93.846; and 93.867 Award Numbers: AG NIFA 2021-68012-35898; DOE DE-SC0018420; DOE DE-FE0032049; SNAP 5P50AA022538 10; SNAP 5R01HL152692-04; Snp 5R01AR081448-02; and NEI 5 P30 EY001792-45 Questioned Costs: None 2024-004. Finding: Internal Controls over Procurement The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not have sufficient rationale documented for the noncompetitive procurement method selected within their iBuy system at the time of approval of the purchase to allow a reviewer to determine the appropriateness of the procurement method in the Research and Development Cluster. Condition: The University of Illinois Urbana-Champaign and the University of Illinois Chicago’s internal controls over small purchases include review and approval of a purchase requisition form that documents the procurement method selected. Within the iBuy system, when a noncompetitive procurement method is selected, a radio button allows for selection of one of several circumstances where noncompetitive procurement is permitted by 2 CFR 200.320, including that the procurement can only be fulfilled by a single source. When this selection is made, additional information supporting this rationale should be available to the reviewer to determine that this noncompetitive procurement method is appropriate. We noted instances where there was not evidence that this information was available to the reviewer at the time of the approval. Out of twenty-nine small purchase procurement transactions tested at the University of Illinois Urbana-Champaign, for five transactions (17%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Out of eleven small purchase procurement transactions tested at the University of Illinois Chicago, for six transactions (55%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Based on additional information provided to us during our testing, there were no indications that the noncompetitive procurement methods selected were inappropriate. The sample was not intended to be, and was not, a statistically valid sample. 2024-004. Finding: Internal Controls over Procurement (Continued) Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained as required by 2 CFR 200.318. Cause: University officials stated a single e-procurement system is used to collect and capture procurement-related information. The electronic system required selection of the relevant procurement method in the form of a radio button, but did not require additional information in the central procurement file. Rather, this information was maintained by the requesting unit. Effect: If the procurement purchase requisition forms do not include sufficient supporting documentation of the rationale for the noncompetitive method of procurement selected, the University could approve payments of federal funds to vendors that do not meet federal regulations. (Finding Code 2024-004) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes within the iBuy system for noncompetitive procurement transactions to ensure sufficient documentation is included to support the rationale for the noncompetitive method of procurement selected. University Response: Accepted. While the University agrees that the supporting documentation was not captured in the electronic payment system, the rationale was available in other University records. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Agriculture (USDA), US Department of Energy (DOE), US Health & Human Services (HHS) Program Names: Research & Development Cluster: Agriculture and Food Research Initiative (AFRI); Office of Science Financial Assistance Program; Fossil Energy Research and Development; Alcohol Research Programs; Cardiovascular Diseases Research; Arthritis, Musculoskeletal and Skin Diseases Research; Vision Research ALN #s: 10.310; 81.049; 81.089; 93.273; 93.837; 93.846; and 93.867 Award Numbers: AG NIFA 2021-68012-35898; DOE DE-SC0018420; DOE DE-FE0032049; SNAP 5P50AA022538 10; SNAP 5R01HL152692-04; Snp 5R01AR081448-02; and NEI 5 P30 EY001792-45 Questioned Costs: None 2024-004. Finding: Internal Controls over Procurement The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not have sufficient rationale documented for the noncompetitive procurement method selected within their iBuy system at the time of approval of the purchase to allow a reviewer to determine the appropriateness of the procurement method in the Research and Development Cluster. Condition: The University of Illinois Urbana-Champaign and the University of Illinois Chicago’s internal controls over small purchases include review and approval of a purchase requisition form that documents the procurement method selected. Within the iBuy system, when a noncompetitive procurement method is selected, a radio button allows for selection of one of several circumstances where noncompetitive procurement is permitted by 2 CFR 200.320, including that the procurement can only be fulfilled by a single source. When this selection is made, additional information supporting this rationale should be available to the reviewer to determine that this noncompetitive procurement method is appropriate. We noted instances where there was not evidence that this information was available to the reviewer at the time of the approval. Out of twenty-nine small purchase procurement transactions tested at the University of Illinois Urbana-Champaign, for five transactions (17%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Out of eleven small purchase procurement transactions tested at the University of Illinois Chicago, for six transactions (55%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Based on additional information provided to us during our testing, there were no indications that the noncompetitive procurement methods selected were inappropriate. The sample was not intended to be, and was not, a statistically valid sample. 2024-004. Finding: Internal Controls over Procurement (Continued) Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained as required by 2 CFR 200.318. Cause: University officials stated a single e-procurement system is used to collect and capture procurement-related information. The electronic system required selection of the relevant procurement method in the form of a radio button, but did not require additional information in the central procurement file. Rather, this information was maintained by the requesting unit. Effect: If the procurement purchase requisition forms do not include sufficient supporting documentation of the rationale for the noncompetitive method of procurement selected, the University could approve payments of federal funds to vendors that do not meet federal regulations. (Finding Code 2024-004) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes within the iBuy system for noncompetitive procurement transactions to ensure sufficient documentation is included to support the rationale for the noncompetitive method of procurement selected. University Response: Accepted. While the University agrees that the supporting documentation was not captured in the electronic payment system, the rationale was available in other University records. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Defense (DoD); US Department of Energy (DOE); US Health and Human Services (HHS) Program Names: Research & Development Cluster: Basic, Applied and Advanced Research in Science and Engineering; Fossil Energy Research and Development; COVID19 – Discovery and Applied Research for Technological Innovations to Improve Human Health; Research and Technology Development; Office of Science and Financial Assistance Program; Air Force Defense Research Sciences Program; Cardiovascular Diseases Research; Health Center Program Cluster: Community Health Centers; and AIDS Education and Training Centers ALN #s: 12.630; 81.089; 93.286; 12.910; 81.049; 12.800; 93.837; 93.224; and 93.145 Award Numbers: ARMY W911NF-17-2-0196; DOE DE-FE0031581; DOE DE-FE0032049; NIH 1 R21 EB031310A; DARPA HR011-23-2-0004; DOE DE-SC0018420; AF FA9550-23-1-0609; SNAP 5R01HL152692-04; HRSA 5 U1OHA29293-09-03; and HRSA 5 U1OHA32109-07 Federal Award Year 2023 – 2024 Questioned Costs: None 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not make certain subrecipient payments timely and the controls in place did not identify the late payments. Condition: Out of thirty-two subrecipient payments tested which were made by the University of Illinois at Urbana-Champaign under the Research & Development Cluster, twelve payments (38%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 35-201 days after receipt of the billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. Out of eight subrecipient payments tested which were made by the University of Illinois Chicago under the Research & Development Cluster, one payment (13%) was not submitted within 30 days after receipt of the billing from the subrecipient. The payment was 32 days after the receipt of billing from the subrecipient. The sample was not intended to be, and was not, a statistically valid sample. Out of eighteen subrecipient payments tested which were made by the University of Illinois Chicago under the Health Center Program Cluster: Community Health Centers and AIDS Education and Training Centers, five payments (28%) were not submitted within 30 days after receipt of the billing from the subrecipient. The payments ranged from 42-120 days after the receipt of billing from the subrecipients. The sample was not intended to be, and was not, a statistically valid sample. 2024-002. Finding: Cash Management – Timeliness of Subrecipient Payments (Continued) Criteria: Under Uniform Guidance (2 CFR 200.305(b)(3)), when the reimbursement method is used, the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper. Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure subrecipient payments are made timely. Cause: University of Illinois Urbana-Champaign officials stated the multi-layered review and approval process along with staffing deficiencies and workload challenges caused the situations for the exceptions noted. University of Illinois Chicago officials stated the one payment was paid 32 days from receipt of the invoice due to high volumes of invoice processing at fiscal year end and the payment due date coinciding with a holiday. The five other subrecipient payments were due to high staff workloads and occurred prior to the fiscal year 2023 corrective action implementation. Effect: Without proper program cash management processes and procedures, late subrecipient payments could result in the loss of future funding. (Finding Code No. 2024-002; 2023-006; 2022-008) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes, policies and procedures to minimize the time elapsing between the transfer of federal funds to the subrecipient. University Response: Accepted. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Agriculture (USDA), US Department of Energy (DOE), US Health & Human Services (HHS) Program Names: Research & Development Cluster: Agriculture and Food Research Initiative (AFRI); Office of Science Financial Assistance Program; Fossil Energy Research and Development; Alcohol Research Programs; Cardiovascular Diseases Research; Arthritis, Musculoskeletal and Skin Diseases Research; Vision Research ALN #s: 10.310; 81.049; 81.089; 93.273; 93.837; 93.846; and 93.867 Award Numbers: AG NIFA 2021-68012-35898; DOE DE-SC0018420; DOE DE-FE0032049; SNAP 5P50AA022538 10; SNAP 5R01HL152692-04; Snp 5R01AR081448-02; and NEI 5 P30 EY001792-45 Questioned Costs: None 2024-004. Finding: Internal Controls over Procurement The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not have sufficient rationale documented for the noncompetitive procurement method selected within their iBuy system at the time of approval of the purchase to allow a reviewer to determine the appropriateness of the procurement method in the Research and Development Cluster. Condition: The University of Illinois Urbana-Champaign and the University of Illinois Chicago’s internal controls over small purchases include review and approval of a purchase requisition form that documents the procurement method selected. Within the iBuy system, when a noncompetitive procurement method is selected, a radio button allows for selection of one of several circumstances where noncompetitive procurement is permitted by 2 CFR 200.320, including that the procurement can only be fulfilled by a single source. When this selection is made, additional information supporting this rationale should be available to the reviewer to determine that this noncompetitive procurement method is appropriate. We noted instances where there was not evidence that this information was available to the reviewer at the time of the approval. Out of twenty-nine small purchase procurement transactions tested at the University of Illinois Urbana-Champaign, for five transactions (17%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Out of eleven small purchase procurement transactions tested at the University of Illinois Chicago, for six transactions (55%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Based on additional information provided to us during our testing, there were no indications that the noncompetitive procurement methods selected were inappropriate. The sample was not intended to be, and was not, a statistically valid sample. 2024-004. Finding: Internal Controls over Procurement (Continued) Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained as required by 2 CFR 200.318. Cause: University officials stated a single e-procurement system is used to collect and capture procurement-related information. The electronic system required selection of the relevant procurement method in the form of a radio button, but did not require additional information in the central procurement file. Rather, this information was maintained by the requesting unit. Effect: If the procurement purchase requisition forms do not include sufficient supporting documentation of the rationale for the noncompetitive method of procurement selected, the University could approve payments of federal funds to vendors that do not meet federal regulations. (Finding Code 2024-004) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes within the iBuy system for noncompetitive procurement transactions to ensure sufficient documentation is included to support the rationale for the noncompetitive method of procurement selected. University Response: Accepted. While the University agrees that the supporting documentation was not captured in the electronic payment system, the rationale was available in other University records. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Agriculture (USDA), US Department of Energy (DOE), US Health & Human Services (HHS) Program Names: Research & Development Cluster: Agriculture and Food Research Initiative (AFRI); Office of Science Financial Assistance Program; Fossil Energy Research and Development; Alcohol Research Programs; Cardiovascular Diseases Research; Arthritis, Musculoskeletal and Skin Diseases Research; Vision Research ALN #s: 10.310; 81.049; 81.089; 93.273; 93.837; 93.846; and 93.867 Award Numbers: AG NIFA 2021-68012-35898; DOE DE-SC0018420; DOE DE-FE0032049; SNAP 5P50AA022538 10; SNAP 5R01HL152692-04; Snp 5R01AR081448-02; and NEI 5 P30 EY001792-45 Questioned Costs: None 2024-004. Finding: Internal Controls over Procurement The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not have sufficient rationale documented for the noncompetitive procurement method selected within their iBuy system at the time of approval of the purchase to allow a reviewer to determine the appropriateness of the procurement method in the Research and Development Cluster. Condition: The University of Illinois Urbana-Champaign and the University of Illinois Chicago’s internal controls over small purchases include review and approval of a purchase requisition form that documents the procurement method selected. Within the iBuy system, when a noncompetitive procurement method is selected, a radio button allows for selection of one of several circumstances where noncompetitive procurement is permitted by 2 CFR 200.320, including that the procurement can only be fulfilled by a single source. When this selection is made, additional information supporting this rationale should be available to the reviewer to determine that this noncompetitive procurement method is appropriate. We noted instances where there was not evidence that this information was available to the reviewer at the time of the approval. Out of twenty-nine small purchase procurement transactions tested at the University of Illinois Urbana-Champaign, for five transactions (17%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Out of eleven small purchase procurement transactions tested at the University of Illinois Chicago, for six transactions (55%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Based on additional information provided to us during our testing, there were no indications that the noncompetitive procurement methods selected were inappropriate. The sample was not intended to be, and was not, a statistically valid sample. 2024-004. Finding: Internal Controls over Procurement (Continued) Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained as required by 2 CFR 200.318. Cause: University officials stated a single e-procurement system is used to collect and capture procurement-related information. The electronic system required selection of the relevant procurement method in the form of a radio button, but did not require additional information in the central procurement file. Rather, this information was maintained by the requesting unit. Effect: If the procurement purchase requisition forms do not include sufficient supporting documentation of the rationale for the noncompetitive method of procurement selected, the University could approve payments of federal funds to vendors that do not meet federal regulations. (Finding Code 2024-004) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes within the iBuy system for noncompetitive procurement transactions to ensure sufficient documentation is included to support the rationale for the noncompetitive method of procurement selected. University Response: Accepted. While the University agrees that the supporting documentation was not captured in the electronic payment system, the rationale was available in other University records. The University will take steps to address the recommendation in this finding.
Federal Agencies: US Department of Agriculture (USDA), US Department of Energy (DOE), US Health & Human Services (HHS) Program Names: Research & Development Cluster: Agriculture and Food Research Initiative (AFRI); Office of Science Financial Assistance Program; Fossil Energy Research and Development; Alcohol Research Programs; Cardiovascular Diseases Research; Arthritis, Musculoskeletal and Skin Diseases Research; Vision Research ALN #s: 10.310; 81.049; 81.089; 93.273; 93.837; 93.846; and 93.867 Award Numbers: AG NIFA 2021-68012-35898; DOE DE-SC0018420; DOE DE-FE0032049; SNAP 5P50AA022538 10; SNAP 5R01HL152692-04; Snp 5R01AR081448-02; and NEI 5 P30 EY001792-45 Questioned Costs: None 2024-004. Finding: Internal Controls over Procurement The University of Illinois Urbana-Champaign and the University of Illinois Chicago did not have sufficient rationale documented for the noncompetitive procurement method selected within their iBuy system at the time of approval of the purchase to allow a reviewer to determine the appropriateness of the procurement method in the Research and Development Cluster. Condition: The University of Illinois Urbana-Champaign and the University of Illinois Chicago’s internal controls over small purchases include review and approval of a purchase requisition form that documents the procurement method selected. Within the iBuy system, when a noncompetitive procurement method is selected, a radio button allows for selection of one of several circumstances where noncompetitive procurement is permitted by 2 CFR 200.320, including that the procurement can only be fulfilled by a single source. When this selection is made, additional information supporting this rationale should be available to the reviewer to determine that this noncompetitive procurement method is appropriate. We noted instances where there was not evidence that this information was available to the reviewer at the time of the approval. Out of twenty-nine small purchase procurement transactions tested at the University of Illinois Urbana-Champaign, for five transactions (17%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Out of eleven small purchase procurement transactions tested at the University of Illinois Chicago, for six transactions (55%), there was not sufficient evidence to support that documentation of the noncompetitive procurement method selected was provided at the time of review and approval. Based on additional information provided to us during our testing, there were no indications that the noncompetitive procurement methods selected were inappropriate. The sample was not intended to be, and was not, a statistically valid sample. 2024-004. Finding: Internal Controls over Procurement (Continued) Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained as required by 2 CFR 200.318. Cause: University officials stated a single e-procurement system is used to collect and capture procurement-related information. The electronic system required selection of the relevant procurement method in the form of a radio button, but did not require additional information in the central procurement file. Rather, this information was maintained by the requesting unit. Effect: If the procurement purchase requisition forms do not include sufficient supporting documentation of the rationale for the noncompetitive method of procurement selected, the University could approve payments of federal funds to vendors that do not meet federal regulations. (Finding Code 2024-004) Recommendation: We recommend the University of Illinois Urbana-Champaign and the University of Illinois Chicago review current processes within the iBuy system for noncompetitive procurement transactions to ensure sufficient documentation is included to support the rationale for the noncompetitive method of procurement selected. University Response: Accepted. While the University agrees that the supporting documentation was not captured in the electronic payment system, the rationale was available in other University records. The University will take steps to address the recommendation in this finding.
Department of Homeland Security Federal Financial Assistance Listing #97.036 COVID‐19 Disaster Grants – Public Assistance Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: Our testing identified eleven instances where contract labor costs were over claimed under the program due to a calculation error. Monument Health’s methodology for identifying contract labor attributable to COVID to be based upon identifying total contact labor and multiplying by the percentage of COVID patient days as a percentage of total patient days. The methodology also identified certain cost centers were to be excluded from the calculation, including behavioral health and med/surg nursing. Based upon review of management’s allocation percentage, it was noted the behavioral health and med/surg nursing COVID patient days were included within the total COVID patient days; therefore, a higher percentage of COVID patient days to total patient days was calculated. The calculation percentage was then utilized to calculate contract labor attributable to COVID for contract labor costs identified from July 2, 2022 through May 11, 2023. Cause: The review process did not identify the behavioral health and med/surg nursing COVID patient days being improperly included within the calculation of contract labor attributable to COVID. Effect: Monument Health’s control did not detect or correct the calculation error identified, which resulted in expenditures being claimed under the federal program that may be unallowable and a reasonable possibility that Monument Health would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: There are questioned costs in the amount of $58,985. Context: A non‐statistical sample of 60 out of 2,565 total transactions were selected for testing, which accounted for $178,483 of $10,295,993 of federal program expenditures. In addition, five individually significant items were selected for testing which accounted for $1,066,229 of federal program expenditures. Testing was also performed over the calculation of contract labor attributable to COVID patient days as a percentage of total patient days for the period from July 1, 2021 to July 1, 2022 and from July 2, 2022 to May 11, 2023. Repeat Finding from Prior Year: No Recommendation: We recommend Monument Health review and strengthen the controls surrounding the calculations of expenditures being claimed under the grant. Views of Responsible Officials: Management agrees with the finding.
Assistance Listing, Federal Agency, and Program Name - 19.510, Department of State, U.S. Refugee Admissions Program, Federal Award Identification Number and Year - SPRMCO23CA0007; SPRMCO23CA0371; SPRMCO23CA0368; SPRMCO23CA0189 Pass through Entity - HIAS, Inc. Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.303 requires that recipients of federal awards establish, document and maintain effective internal control that provides reasonable assurance that the recipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. 2 CFR 200 Appendix XI Part 3. Cash Management requires that recipients establish written procedures to meet the requirements of 2 CFR 200.305 and the terms of the grant award, expenditures must be incurred before reimbursement of federal funds is requested. 2 CFR 200 subpart E Cost Principles requires recipients to follow allowability requirements as defined in the grant award and within general cost principles. 2 CFR 200 requires that costs be expended in accordance with the period of performance defined within the award agreement. Condition - In performing our audit procedures, there was no evidence of a system of internal control over the cash management requirements, including a written policy, related to reimbursement of funds on a per refugee basis. In addition, we noted that reimbursement was requested prior to incurring expenses on a per refugee basis. There were also refugee costs coded incorrectly within the general ledger. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - When gaining an understanding of internal control over compliance for cash management, we noted a lack of internal controls in place to ensure that expenses on a per refugee basis were incurred prior to requesting reimbursement. In testing the compliance requirements for cash management, we were unable to test compliance on a per refugee basis. Each month, funds become available based on the number of refugees who arrived and been allocated to the program. We noted that in one month, $5,300 was available to be spent on new arrivals; however, only $2,285 was spent on the new arrivals and $3,015 was improperly spent on refugees who had arrived previously and for which reimbursement had already been received. In total, over the entire term of the grant, and based on the total number of refugees served, the appropriate amount of funds were requested for reimbursement. In addition, we noted one instance where refugee costs were applied to an incorrect award based on the period of performance and the allowable 90-day resettlement period. These costs were within the total amount allowed for each of the awards, but were not assigned correctly within the general ledger. Cause and Effect - There was not a sufficient cash management policy in place and there were no internal controls in place to ensure reimbursement requests were made only after expenses had been incurred on a per refugee basis. Recommendation - The organization should establish a written cash management policy which encompasses per refugee spending and ensure there is an effective review process in place to ensure that reimbursement is not requested prior to funds being incurred on a per refugee basis. This process should ensure that general ledger expenses are reconciled to per refugee spending and that the correct award funds are utilized for the specified refugee. In addition, the general ledger expenses should be coded in such a manner to facilitate this review on a per-refugee basis. These improvements will ensure that only allowable costs are recorded in the federal grant general ledger codes and are requested for reimbursement. Views of Responsible Officials and Corrective Action Plan - Agree with finding. Financial policies will be updated to include cash management requirements to ensure expenditures are incurred, including any required per client expenditures, prior to reimbursement requests. During the year under audit, there was not a reconciliation between individual refugee spending and the general ledger expenses. Subsequent to year end a new process was put in place to compare the individual refugee ledgers to the reimbursement request to ensure no expenditures were requested in advance and that refugee spending is coded to the appropriate general ledger account based on the specific award funding.
Assistance Listing, Federal Agency, and Program Name - 19.510, Department of State, U.S. Refugee Admissions Program, Federal Award Identification Number and Year - SPRMCO23CA0007; SPRMCO23CA0371; SPRMCO23CA0368; SPRMCO23CA0189 Pass through Entity - HIAS, Inc. Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.303 requires that recipients of federal awards establish, document and maintain effective internal control that provides reasonable assurance that the recipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. 2 CFR 200 Appendix XI Part 3. Cash Management requires that recipients establish written procedures to meet the requirements of 2 CFR 200.305 and the terms of the grant award, expenditures must be incurred before reimbursement of federal funds is requested. 2 CFR 200 subpart E Cost Principles requires recipients to follow allowability requirements as defined in the grant award and within general cost principles. 2 CFR 200 requires that costs be expended in accordance with the period of performance defined within the award agreement. Condition - In performing our audit procedures, there was no evidence of a system of internal control over the cash management requirements, including a written policy, related to reimbursement of funds on a per refugee basis. In addition, we noted that reimbursement was requested prior to incurring expenses on a per refugee basis. There were also refugee costs coded incorrectly within the general ledger. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - When gaining an understanding of internal control over compliance for cash management, we noted a lack of internal controls in place to ensure that expenses on a per refugee basis were incurred prior to requesting reimbursement. In testing the compliance requirements for cash management, we were unable to test compliance on a per refugee basis. Each month, funds become available based on the number of refugees who arrived and been allocated to the program. We noted that in one month, $5,300 was available to be spent on new arrivals; however, only $2,285 was spent on the new arrivals and $3,015 was improperly spent on refugees who had arrived previously and for which reimbursement had already been received. In total, over the entire term of the grant, and based on the total number of refugees served, the appropriate amount of funds were requested for reimbursement. In addition, we noted one instance where refugee costs were applied to an incorrect award based on the period of performance and the allowable 90-day resettlement period. These costs were within the total amount allowed for each of the awards, but were not assigned correctly within the general ledger. Cause and Effect - There was not a sufficient cash management policy in place and there were no internal controls in place to ensure reimbursement requests were made only after expenses had been incurred on a per refugee basis. Recommendation - The organization should establish a written cash management policy which encompasses per refugee spending and ensure there is an effective review process in place to ensure that reimbursement is not requested prior to funds being incurred on a per refugee basis. This process should ensure that general ledger expenses are reconciled to per refugee spending and that the correct award funds are utilized for the specified refugee. In addition, the general ledger expenses should be coded in such a manner to facilitate this review on a per-refugee basis. These improvements will ensure that only allowable costs are recorded in the federal grant general ledger codes and are requested for reimbursement. Views of Responsible Officials and Corrective Action Plan - Agree with finding. Financial policies will be updated to include cash management requirements to ensure expenditures are incurred, including any required per client expenditures, prior to reimbursement requests. During the year under audit, there was not a reconciliation between individual refugee spending and the general ledger expenses. Subsequent to year end a new process was put in place to compare the individual refugee ledgers to the reimbursement request to ensure no expenditures were requested in advance and that refugee spending is coded to the appropriate general ledger account based on the specific award funding.
Assistance Listing, Federal Agency, and Program Name - 19.510, Department of State, U.S. Refugee Admissions Program, Federal Award Identification Number and Year - SPRMCO23CA0007; SPRMCO23CA0371; SPRMCO23CA0368; SPRMCO23CA0189 Pass through Entity - HIAS, Inc. Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.303 requires that recipients of federal awards establish, document and maintain effective internal control that provides reasonable assurance that the recipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. 2 CFR 200 Appendix XI Part 3. Cash Management requires that recipients establish written procedures to meet the requirements of 2 CFR 200.305 and the terms of the grant award, expenditures must be incurred before reimbursement of federal funds is requested. 2 CFR 200 subpart E Cost Principles requires recipients to follow allowability requirements as defined in the grant award and within general cost principles. 2 CFR 200 requires that costs be expended in accordance with the period of performance defined within the award agreement. Condition - In performing our audit procedures, there was no evidence of a system of internal control over the cash management requirements, including a written policy, related to reimbursement of funds on a per refugee basis. In addition, we noted that reimbursement was requested prior to incurring expenses on a per refugee basis. There were also refugee costs coded incorrectly within the general ledger. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - When gaining an understanding of internal control over compliance for cash management, we noted a lack of internal controls in place to ensure that expenses on a per refugee basis were incurred prior to requesting reimbursement. In testing the compliance requirements for cash management, we were unable to test compliance on a per refugee basis. Each month, funds become available based on the number of refugees who arrived and been allocated to the program. We noted that in one month, $5,300 was available to be spent on new arrivals; however, only $2,285 was spent on the new arrivals and $3,015 was improperly spent on refugees who had arrived previously and for which reimbursement had already been received. In total, over the entire term of the grant, and based on the total number of refugees served, the appropriate amount of funds were requested for reimbursement. In addition, we noted one instance where refugee costs were applied to an incorrect award based on the period of performance and the allowable 90-day resettlement period. These costs were within the total amount allowed for each of the awards, but were not assigned correctly within the general ledger. Cause and Effect - There was not a sufficient cash management policy in place and there were no internal controls in place to ensure reimbursement requests were made only after expenses had been incurred on a per refugee basis. Recommendation - The organization should establish a written cash management policy which encompasses per refugee spending and ensure there is an effective review process in place to ensure that reimbursement is not requested prior to funds being incurred on a per refugee basis. This process should ensure that general ledger expenses are reconciled to per refugee spending and that the correct award funds are utilized for the specified refugee. In addition, the general ledger expenses should be coded in such a manner to facilitate this review on a per-refugee basis. These improvements will ensure that only allowable costs are recorded in the federal grant general ledger codes and are requested for reimbursement. Views of Responsible Officials and Corrective Action Plan - Agree with finding. Financial policies will be updated to include cash management requirements to ensure expenditures are incurred, including any required per client expenditures, prior to reimbursement requests. During the year under audit, there was not a reconciliation between individual refugee spending and the general ledger expenses. Subsequent to year end a new process was put in place to compare the individual refugee ledgers to the reimbursement request to ensure no expenditures were requested in advance and that refugee spending is coded to the appropriate general ledger account based on the specific award funding.
Assistance Listing, Federal Agency, and Program Name - 19.510, Department of State, U.S. Refugee Admissions Program, Federal Award Identification Number and Year - SPRMCO23CA0007; SPRMCO23CA0371; SPRMCO23CA0368; SPRMCO23CA0189 Pass through Entity - HIAS, Inc. Finding Type - Significant deficiency Repeat Finding - No Criteria - 2 CFR 200.303 requires that recipients of federal awards establish, document and maintain effective internal control that provides reasonable assurance that the recipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. 2 CFR 200 Appendix XI Part 3. Cash Management requires that recipients establish written procedures to meet the requirements of 2 CFR 200.305 and the terms of the grant award, expenditures must be incurred before reimbursement of federal funds is requested. 2 CFR 200 subpart E Cost Principles requires recipients to follow allowability requirements as defined in the grant award and within general cost principles. 2 CFR 200 requires that costs be expended in accordance with the period of performance defined within the award agreement. Condition - In performing our audit procedures, there was no evidence of a system of internal control over the cash management requirements, including a written policy, related to reimbursement of funds on a per refugee basis. In addition, we noted that reimbursement was requested prior to incurring expenses on a per refugee basis. There were also refugee costs coded incorrectly within the general ledger. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - When gaining an understanding of internal control over compliance for cash management, we noted a lack of internal controls in place to ensure that expenses on a per refugee basis were incurred prior to requesting reimbursement. In testing the compliance requirements for cash management, we were unable to test compliance on a per refugee basis. Each month, funds become available based on the number of refugees who arrived and been allocated to the program. We noted that in one month, $5,300 was available to be spent on new arrivals; however, only $2,285 was spent on the new arrivals and $3,015 was improperly spent on refugees who had arrived previously and for which reimbursement had already been received. In total, over the entire term of the grant, and based on the total number of refugees served, the appropriate amount of funds were requested for reimbursement. In addition, we noted one instance where refugee costs were applied to an incorrect award based on the period of performance and the allowable 90-day resettlement period. These costs were within the total amount allowed for each of the awards, but were not assigned correctly within the general ledger. Cause and Effect - There was not a sufficient cash management policy in place and there were no internal controls in place to ensure reimbursement requests were made only after expenses had been incurred on a per refugee basis. Recommendation - The organization should establish a written cash management policy which encompasses per refugee spending and ensure there is an effective review process in place to ensure that reimbursement is not requested prior to funds being incurred on a per refugee basis. This process should ensure that general ledger expenses are reconciled to per refugee spending and that the correct award funds are utilized for the specified refugee. In addition, the general ledger expenses should be coded in such a manner to facilitate this review on a per-refugee basis. These improvements will ensure that only allowable costs are recorded in the federal grant general ledger codes and are requested for reimbursement. Views of Responsible Officials and Corrective Action Plan - Agree with finding. Financial policies will be updated to include cash management requirements to ensure expenditures are incurred, including any required per client expenditures, prior to reimbursement requests. During the year under audit, there was not a reconciliation between individual refugee spending and the general ledger expenses. Subsequent to year end a new process was put in place to compare the individual refugee ledgers to the reimbursement request to ensure no expenditures were requested in advance and that refugee spending is coded to the appropriate general ledger account based on the specific award funding.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: Six-line items in the ARP ESSER grant, totaling $115,645.51. Five-line items in the ESSER II grant, totaling $31,135.42 Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44. One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: Six-line items in the ARP ESSER grant, totaling $115,645.51. Five-line items in the ESSER II grant, totaling $31,135.42 Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44. One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: Six-line items in the ARP ESSER grant, totaling $115,645.51. Five-line items in the ESSER II grant, totaling $31,135.42 Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44. One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: Six-line items in the ARP ESSER grant, totaling $115,645.51. Five-line items in the ESSER II grant, totaling $31,135.42 Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44. One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: Six-line items in the ARP ESSER grant, totaling $115,645.51. Five-line items in the ESSER II grant, totaling $31,135.42 Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44. One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: Six-line items in the ARP ESSER grant, totaling $115,645.51. Five-line items in the ESSER II grant, totaling $31,135.42 Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44. One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: Six-line items in the ARP ESSER grant, totaling $115,645.51. Five-line items in the ESSER II grant, totaling $31,135.42 Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44. One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination: Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred. One instance where there was no invoice or credit memo to support the transaction. Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Repeat Finding: No Criteria: 2 CFR 200.303 requires that a non-federal entity establish, document and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, 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). 7 CFR 210.14(g) also requires school food authorities to follow fair and consistent methodologies to identify and allocate allowable indirect costs to the nonprofit school food service account, in accordance with 2 CFR part 200 as implemented by 2 CFR part 400. Condition: Our procedures indicate that the District’s internal control system is inadequate for ensuring that indirect costs charged to various federal grant programs are adequately documented and accurately calculated. Specifically: Child Nutrition Cluster: The District could not provide documentation of its calculation to support the $25,000 per quarter requested as reimbursement for indirect costs. Elementary and Secondary School Emergency Relief (ESSER II): The District used an indirect cost rate from a prior year to calculate indirect costs charged to the ESSER II program which resulted in an overcharge of $68,829. Our procedures indicate that the District’s internal control system is insufficient to ensure that the indirect cost charged to the program is accurately calculated and based on calculations that meet the requirements outlined in Sections 2 CFR 200.303, 2 CFR 200.414 and Appendix VII to Part 200. Context/ Perspective: This finding arises from our audit procedures on internal control, where attempted to obtain documentation of the District's calculation and subsequent approval of reimbursement for indirect costs as well as other procedures performed by us recalculating indirect costs charged to certain federal grant programs. Cause: The District lacks the necessary internal controls to ensure that requests for reimbursement of indirect costs are accurately calculated, properly documented and approved by the appropriate director. Effect: The lack of adequate internal controls over the calculation of indirect cost reimbursement may increase the risk of misappropriation or loss of public funds. It could also result in inappropriate charges to the federal award, potentially leading to disallowed costs being applied to the program. Questioned Costs: $68,829 (Elementary and Secondary School Emergency Relief II) Recommendation: The District should implement stronger internal controls to ensure that indirect cost reimbursements are accurately calculated, properly documented, and approved by the appropriate federal grant program director. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Repeat Finding: No Criteria: 2 CFR 200.303 requires that a non-federal entity establish, document and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, 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). 7 CFR 210.14(g) also requires school food authorities to follow fair and consistent methodologies to identify and allocate allowable indirect costs to the nonprofit school food service account, in accordance with 2 CFR part 200 as implemented by 2 CFR part 400. Condition: Our procedures indicate that the District’s internal control system is inadequate for ensuring that indirect costs charged to various federal grant programs are adequately documented and accurately calculated. Specifically: Child Nutrition Cluster: The District could not provide documentation of its calculation to support the $25,000 per quarter requested as reimbursement for indirect costs. Elementary and Secondary School Emergency Relief (ESSER II): The District used an indirect cost rate from a prior year to calculate indirect costs charged to the ESSER II program which resulted in an overcharge of $68,829. Our procedures indicate that the District’s internal control system is insufficient to ensure that the indirect cost charged to the program is accurately calculated and based on calculations that meet the requirements outlined in Sections 2 CFR 200.303, 2 CFR 200.414 and Appendix VII to Part 200. Context/ Perspective: This finding arises from our audit procedures on internal control, where attempted to obtain documentation of the District's calculation and subsequent approval of reimbursement for indirect costs as well as other procedures performed by us recalculating indirect costs charged to certain federal grant programs. Cause: The District lacks the necessary internal controls to ensure that requests for reimbursement of indirect costs are accurately calculated, properly documented and approved by the appropriate director. Effect: The lack of adequate internal controls over the calculation of indirect cost reimbursement may increase the risk of misappropriation or loss of public funds. It could also result in inappropriate charges to the federal award, potentially leading to disallowed costs being applied to the program. Questioned Costs: $68,829 (Elementary and Secondary School Emergency Relief II) Recommendation: The District should implement stronger internal controls to ensure that indirect cost reimbursements are accurately calculated, properly documented, and approved by the appropriate federal grant program director. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Repeat Finding: No Criteria: 2 CFR 200.303 requires that a non-federal entity establish, document and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, 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). 7 CFR 210.14(g) also requires school food authorities to follow fair and consistent methodologies to identify and allocate allowable indirect costs to the nonprofit school food service account, in accordance with 2 CFR part 200 as implemented by 2 CFR part 400. Condition: Our procedures indicate that the District’s internal control system is inadequate for ensuring that indirect costs charged to various federal grant programs are adequately documented and accurately calculated. Specifically: Child Nutrition Cluster: The District could not provide documentation of its calculation to support the $25,000 per quarter requested as reimbursement for indirect costs. Elementary and Secondary School Emergency Relief (ESSER II): The District used an indirect cost rate from a prior year to calculate indirect costs charged to the ESSER II program which resulted in an overcharge of $68,829. Our procedures indicate that the District’s internal control system is insufficient to ensure that the indirect cost charged to the program is accurately calculated and based on calculations that meet the requirements outlined in Sections 2 CFR 200.303, 2 CFR 200.414 and Appendix VII to Part 200. Context/ Perspective: This finding arises from our audit procedures on internal control, where attempted to obtain documentation of the District's calculation and subsequent approval of reimbursement for indirect costs as well as other procedures performed by us recalculating indirect costs charged to certain federal grant programs. Cause: The District lacks the necessary internal controls to ensure that requests for reimbursement of indirect costs are accurately calculated, properly documented and approved by the appropriate director. Effect: The lack of adequate internal controls over the calculation of indirect cost reimbursement may increase the risk of misappropriation or loss of public funds. It could also result in inappropriate charges to the federal award, potentially leading to disallowed costs being applied to the program. Questioned Costs: $68,829 (Elementary and Secondary School Emergency Relief II) Recommendation: The District should implement stronger internal controls to ensure that indirect cost reimbursements are accurately calculated, properly documented, and approved by the appropriate federal grant program director. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.
Finding 2024-001: Special Tests and Provisions: Enrollment Reporting Program Name: Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, Assistance Listing No. 84.007 Federal Work-Study Program, Assistance Listing No. 84.033 Federal Pell Grant Program, Assistance Listing No. 84.063 Federal Direct Student Loans. Assistance Listing No. 84.268 Awarding Agency: U.S. Department of Education Finding Type: Significant Deficiency on Internal Controls over Compliance Questioned Costs: None Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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). In addition, the Department of Education relies on institution’s enrollments reports to determine a student’s enrollment status based on reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence. According to 34 CFR 690.83(b)(2) and 685.309, the University is required to submit changes in student attendance to the National Student Loan Data System (NSLDS) at a minimum of every 60 days. Context/Condition: Of the 43 students selected for enrollment reporting testing, eight student withdrawals within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Cause: The University did not have effective controls in place to ensure timely reporting of all status changes. Effect: Without timely notification of withdrawals or graduation, the NSLDS is unable to accurately determine when a student enters repayment status. Recommendation: We recommend that the University review and update internal controls to ensure student enrollment status in the NSLDS is updated in a timely manner to ensure compliance with Federal requirements. Views of Responsible Officials: Management agrees with the finding. See accompanying Corrective Action Plan.
Finding 2024-001: Special Tests and Provisions: Enrollment Reporting Program Name: Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, Assistance Listing No. 84.007 Federal Work-Study Program, Assistance Listing No. 84.033 Federal Pell Grant Program, Assistance Listing No. 84.063 Federal Direct Student Loans. Assistance Listing No. 84.268 Awarding Agency: U.S. Department of Education Finding Type: Significant Deficiency on Internal Controls over Compliance Questioned Costs: None Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, 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). In addition, the Department of Education relies on institution’s enrollments reports to determine a student’s enrollment status based on reductions or increases in attendance levels, withdrawals, graduations or approved leaves-of-absence. According to 34 CFR 690.83(b)(2) and 685.309, the University is required to submit changes in student attendance to the National Student Loan Data System (NSLDS) at a minimum of every 60 days. Context/Condition: Of the 43 students selected for enrollment reporting testing, eight student withdrawals within the sample were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Cause: The University did not have effective controls in place to ensure timely reporting of all status changes. Effect: Without timely notification of withdrawals or graduation, the NSLDS is unable to accurately determine when a student enters repayment status. Recommendation: We recommend that the University review and update internal controls to ensure student enrollment status in the NSLDS is updated in a timely manner to ensure compliance with Federal requirements. Views of Responsible Officials: Management agrees with the finding. See accompanying Corrective Action Plan.
Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: 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). 29 CFR 5.5 states in part: (1) Minimum wages. (i) All laborers and mechanics employed or working upon the site of the work (or under the United States Housing Act of 1937 or under the Housing Act of 1949 in the construction or development of the project), will be paid unconditionally and not less often than once a week, and without subsequent deduction or rebate on any account (except such payroll deductions as are permitted by regulations issued by the Secretary of Labor under the Copeland Act (29 CFR part 3)), the full amount of wages and bona fide fringe benefits (or cash equivalents thereof) due at time of payment computed at rates not less than those contained in the wage determination of the Secretary of Labor which is attached hereto and made a part hereof, regardless of any contractual relationship which may be alleged to exist between the contractor and such laborers and mechanics… (3)(ii)(A) The contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the (write in name of appropriate federal agency) if the agency is a party to the contract, but if the agency is not such a party, the contractor will submit the payrolls to the applicant, sponsor, or owner, as the case may be, for transmission to the (write in name of agency). 2 CFR 200 Appendix II states in part: In addition to other provisions required by the Federal agency or non-Federal entity; all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following, as applicable. . . . (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay w ages not less than once a week.. . .” 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 Special Tests and Provisions – Wage Rate Requirements 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 design and implement an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: For 1 of 2 sample items tested, we noted the School Corporation expended approximately $212,000 on science room improvements, which was funded with ESSER II (84.425D) grant awards. The School Corporation did not properly include Davis-Bacon wage rate requirements in the vendor contract. Additionally, the School Corporation did not obtain the weekly payroll reports certifications from the construction vendor to monitor compliance with Davis-Bacon wage rate requirements. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The lack of controls and noncompliance was isolated to fiscal year 2023. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation ensure vendor contracts with labor installation in excess of $2,000 which are funded by federal grants including Davis Bacon Wage Rate Requirement clauses and implement a formal process to ensure the required weekly payroll reports certifications are collected and reviewed to ensure compliance with federal regulations. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Federal agency: U.S. Department of Education Federal program title: Student Financial Aid Cluster ALN Number: 84.063, 84.268 Federal Award Identification Number: P063P221568, P063P231568, P063Q221568, P063Q231568, P268K231568, P268K241568 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: 1. The Code of Federal Regulations, consisting of 34 CFR 685.309 and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. 2. The Code of Federal Regulations, consisting of 34 CFR 685.309 and 34 CFR 690.83(b)(2), requires certain student enrollment information be reported to the Department of Education. Information provided to the Department of Education should agree to the institutions records. Condition: The change in status was not reported timely and the program begin date per the institutions records did not agree to information in the NSLDS. Questioned costs: None Context: This condition occurred in our statistically valid sample as follows: 1. The status was not reported timely for 4 out of 36 students 2. The Program Begin Date was incorrectly reported for 7 out of 35 students Cause: The Registrar's Office has been through several transitions over the past five years and training has been inadequate during this period. Specifically, there was not sufficient training on enrollment submissions, error resolutions, and timely updates. Effect: 1. The published program length reported to NSLDS is used to determine the students maximum and remaining eligibility periods under the 150% limit. By not reporting the correct length, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. 2. The NSLDS system is not updated timely with the student information which may cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes, 2023-001 Recommendation: We recommend the College review its reporting procedures to ensure that students statuses are accurately and timely reported to NSLDS as required by regulations. 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 ALN Number: 84.063, 84.268 Federal Award Identification Number: P063P221568, P063P231568, P063Q221568, P063Q231568, P268K231568, P268K241568 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: 1. The Code of Federal Regulations, consisting of 34 CFR 685.309 and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. 2. The Code of Federal Regulations, consisting of 34 CFR 685.309 and 34 CFR 690.83(b)(2), requires certain student enrollment information be reported to the Department of Education. Information provided to the Department of Education should agree to the institutions records. Condition: The change in status was not reported timely and the program begin date per the institutions records did not agree to information in the NSLDS. Questioned costs: None Context: This condition occurred in our statistically valid sample as follows: 1. The status was not reported timely for 4 out of 36 students 2. The Program Begin Date was incorrectly reported for 7 out of 35 students Cause: The Registrar's Office has been through several transitions over the past five years and training has been inadequate during this period. Specifically, there was not sufficient training on enrollment submissions, error resolutions, and timely updates. Effect: 1. The published program length reported to NSLDS is used to determine the students maximum and remaining eligibility periods under the 150% limit. By not reporting the correct length, the calculation of the 150% would be incorrect and the grace period begin date would be incorrect. 2. The NSLDS system is not updated timely with the student information which may cause over awarding should the student transfer to another institution and the students may not properly enter the repayment period. Repeat Finding: Yes, 2023-001 Recommendation: We recommend the College review its reporting procedures to ensure that students statuses are accurately and timely reported to NSLDS as required by regulations. 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 ALN Number: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Number: P007A221791, P007A231791, P007A241791, P033A221791, P063P221568, P033A231791, P063P231568, P063Q221568, P063Q231568, P268K231568, P268K241568 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 - The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The elements that an institution must address in its written information security program are at 16 CFR 314.4. Condition: Certain elements of the Colleges information security program were not meeting GLBA requirements. Questioned costs: None Context: The Colleges written information security program did not cover the requirement to provide for the design and implementation of safeguards to control the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the institutions written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8). Cause: The gaps in the Colleges information security program, during the specified audit period, stemmed from prior deficiencies in documentation and procedural enforcement, which were exacerbated by staff turnover and resource constraints. Effect: Information security management may not be optimized and responses delayed without the written plan. Repeat Finding: Yes, 2023-002 Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. 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 ALN Number: 84.063, 84.268, 84.007, 84.033 Federal Award Identification Number: P007A221791, P007A231791, P007A241791, P033A221791, P063P221568, P033A231791, P063P231568, P063Q221568, P063Q231568, P268K231568, P268K241568 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 - The Gramm-Leach-Bliley Act (Public Law 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as financial institutions and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The elements that an institution must address in its written information security program are at 16 CFR 314.4. Condition: Certain elements of the Colleges information security program were not meeting GLBA requirements. Questioned costs: None Context: The Colleges written information security program did not cover the requirement to provide for the design and implementation of safeguards to control the risks the institution identifies through its risk assessment (16 CFR 314.4(c)). At a minimum, the institutions written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8). Cause: The gaps in the Colleges information security program, during the specified audit period, stemmed from prior deficiencies in documentation and procedural enforcement, which were exacerbated by staff turnover and resource constraints. Effect: Information security management may not be optimized and responses delayed without the written plan. Repeat Finding: Yes, 2023-002 Recommendation: We recommend the College ensure its written information security program addresses the required minimum elements as outlined in 16 CFR 314.4. Views of responsible officials: There is no disagreement with the audit finding.