CONDITION The Department of Public Instruction (DPI) did not report Child Nutrition Cluster subawards to the Federal Funding Accountability and Transparency Act (FFATA) correctly. After testing FFATA reporting for the Child Nutrition Cluster, it was discovered that there were FFATA errors in the following areas: 1. The Department of Public Instruction did not report the subaward information timely for the Child Nutrition Cluster (CNC) (Assistance Listing number 10.553, 10.555, 10.559) for the 2023 grant year awards (October 2022-September 2023). After an analysis of grants awarded in 2023, we randomly sampled and pulled 11 awards to test. We found that all 11 were not submitted timely. The samples we pulled should have been reported by 4/30/23, 6/30/23, 7/31/23, 9/30/23, 11/30/23, and 1/31/24, but were not reported until 4/3/24 or 4/5/24. DPI explained that this occurred because all CNP reports from March to October of 2023 had to be resubmitted due to the wrong FEIN # being used on the reports. DPI resubmitted these reports on 4/3/24 and 4/5/24. The resubmitting of reports over a year later and without evidence that the reports were initially submitted timely is the reason for the audit finding. Those grant awards totaled $328,815.19. 2. The Department of Public Instruction did not report the subaward information timely for the Child Nutrition Cluster (Assistance Listing number 10.553, 10.555, 10.556, 10.559) for the 2024 grant year awards (October 2023-September 2024). After an analysis of grant awards awarded in 2024, we randomly sampled and pulled 4 awards to test. We found one of the four was not reported timely to FFATA. The report should have been submitted by 1/31/24 but it wasn't reported until 3/4/24. 3. The Department of Public Instruction did not report the subaward information for the Child Nutrition Cluster (Assistance Listing number 10.553, 10.555, 10.556, 10.559) for program months November and December of 2023 of the October 2023-September 2024 grant year. After an analysis of grant awards for that grant year and as reported to the auditor by DPI, it was discovered that 133 subawards should have been reported to FFATA, totaling $1,437,209.93. 4. The Department of Public Instruction did not properly report the subaward action/obligation date in the FSRS system for the Child Nutrition Cluster (Assistance Listing number 10.553, 10.555, 10.556, 10.559, 10.582). DPI staff run the FFATA report from the ND Foods system at the end of every month which is then uploaded into the FSRS system. In the FSRS system, it is listing the subaward action /obligation date as the day the report was pulled which is not the same day that payments are actually made. DPI reported the wrong subaward action/obligation date for all Child Nutrition Cluster samples that were pulled. There is no dollar error for these awards, only the obligation date. CRITERIA Federal regulation 2 CFR 170, Appendix A requires a Federal Financial Assistance Transparency Act (FFATA) report for each subaward that equals or exceeds $30,000 no later than the end of the month following the month in which the obligation was made. 2 CFR 200.303(a) states that non-Federal entities 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. CAUSE DPI does not have adequate policies and procedures to ensure accurate and timely reporting for FFATA EFFECT Not meeting the FFATA requirements increases the likelihood that the public will not have access to transparent and accurate information regarding expenditures of federal awards. Additionally, federal regulations address actions that federal agencies may impose if a state entity does not comply with the U.S. Constitution, federal statutes, regulations, or the terms and conditions of a federal award. According to 2 CFR 200.208(c), “Specific conditions,” these actions may include • requiring reimbursement instead of advance payments; • not allowing the agency to proceed to the next phase until it submits evidence of acceptable performance; • requiring additional, more detailed financial reports or additional project monitoring; • requiring the agency to obtain technical or management assistance; or • establishing other prior approvals. If the federal agency determines the state agency cannot remedy its noncompliance through the above actions, 2 CFR 200.339, “Remedies for noncompliance,” outlines additional actions the federal agency may take. Depending on the circumstances, these actions may include: • temporarily withholding payments until the noncompliance has been corrected, • Denying the use of funds, • partly or fully suspending or terminating the federal award, • suspending or debarring the agency, • withholding further awards for the project or program, or • pursuing other available legal remedies. CONTEXT During our audit period, there were 407 subrecipients receiving Federal grant awards for the Child Nutrition Cluster program totaling $68,351,704. Out of the 407 subrecipients, 309 were over the $30,000 threshold and should have been reported to FFATA. In 2023, there were 164 subrecipients and, in 2024, 145 subrecipients that met the threshold, for a total of $66,879,778. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-022 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction implement policies and procedures to ensure timely and accurate submission of FFATA reports in accordance with federal regulations. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the issues identified. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities 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. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Special Education Cluster, Title 1, Supporting Effective Instruction, Child and Adult Care Food Program, and Education Stabilization Fund. CRITERIA 2 CFR 200.332 requires pass-through entities to communicate specific required information to subrecipients. Required information includes: - Subrecipients name (Must match the name associated with its unique entity identifier) - Subrecipients unique entity identifier - Federal award identification number (FAIN) - Federal award date - Subaward period of performance start and end date - Amount of Federal funds obligated in the subaward - Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Total amount of the Federal award committed to the subrecipient by the pass-through entity - Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listings title and number; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance listings number at the time of disbursement - Identification of whether the Federal award is for research and development - Indirect cost rate for the Federal award (including if the de minimis rate is used) - All requirements of the subaward, including requirements imposed by federal statutes, regulations, and the terms and condition of the Federal award 2 CFR 200.303 requires non-Federal entities, in part, to 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. CAUSE Not all grant agreement requirements were entered into the grant award template. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT The number of grant agreements during the audit period is listed below. A. Special Education Cluster - 134 awards - 14 tested with 10 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity B. Title I program - 276 awards - 25 tested with 16 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity C. Supporting Effective Instruction - 278 awards - 25 tested with 21 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - Federal award date - Federal award Identification Number (FAIN) - Total amount of the Federal award committed to the subrecipient by the pass-through entity D. Child and Adult Care Food Program - 134 awards - 14 tested with 2 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - 1 subrecipient did not have a grant contract E. Education Stabilization Fund - 641 awards - 40 tested with 10 errors noted The following criteria were missing or incorrect: - Subrecipient name (1 sample did not have the correct subrecipient name on the grant award) - Subrecipients unique entity identifier (2 did not match the Subrecipient name on grant award) - Federal award date (8 awards did not have this) - Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity (6 awards did not include Name of Federal Awarding Agency (Dept of Education) on grant award) Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-024 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Instruction update its grant award templates to ensure that subrecipients are made award of all required grant award information DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Special Education Cluster, Title 1, Supporting Effective Instruction, Child and Adult Care Food Program, and Education Stabilization Fund. CRITERIA 2 CFR 200.332 requires pass-through entities to communicate specific required information to subrecipients. Required information includes: - Subrecipients name (Must match the name associated with its unique entity identifier) - Subrecipients unique entity identifier - Federal award identification number (FAIN) - Federal award date - Subaward period of performance start and end date - Amount of Federal funds obligated in the subaward - Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Total amount of the Federal award committed to the subrecipient by the pass-through entity - Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listings title and number; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance listings number at the time of disbursement - Identification of whether the Federal award is for research and development - Indirect cost rate for the Federal award (including if the de minimis rate is used) - All requirements of the subaward, including requirements imposed by federal statutes, regulations, and the terms and condition of the Federal award 2 CFR 200.303 requires non-Federal entities, in part, to 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. CAUSE Not all grant agreement requirements were entered into the grant award template. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT The number of grant agreements during the audit period is listed below. A. Special Education Cluster - 134 awards - 14 tested with 10 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity B. Title I program - 276 awards - 25 tested with 16 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity C. Supporting Effective Instruction - 278 awards - 25 tested with 21 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - Federal award date - Federal award Identification Number (FAIN) - Total amount of the Federal award committed to the subrecipient by the pass-through entity D. Child and Adult Care Food Program - 134 awards - 14 tested with 2 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - 1 subrecipient did not have a grant contract E. Education Stabilization Fund - 641 awards - 40 tested with 10 errors noted The following criteria were missing or incorrect: - Subrecipient name (1 sample did not have the correct subrecipient name on the grant award) - Subrecipients unique entity identifier (2 did not match the Subrecipient name on grant award) - Federal award date (8 awards did not have this) - Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity (6 awards did not include Name of Federal Awarding Agency (Dept of Education) on grant award) Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-024 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Instruction update its grant award templates to ensure that subrecipients are made award of all required grant award information DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Special Education Cluster, Title 1, Supporting Effective Instruction, Child and Adult Care Food Program, and Education Stabilization Fund. CRITERIA 2 CFR 200.332 requires pass-through entities to communicate specific required information to subrecipients. Required information includes: - Subrecipients name (Must match the name associated with its unique entity identifier) - Subrecipients unique entity identifier - Federal award identification number (FAIN) - Federal award date - Subaward period of performance start and end date - Amount of Federal funds obligated in the subaward - Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Total amount of the Federal award committed to the subrecipient by the pass-through entity - Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listings title and number; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance listings number at the time of disbursement - Identification of whether the Federal award is for research and development - Indirect cost rate for the Federal award (including if the de minimis rate is used) - All requirements of the subaward, including requirements imposed by federal statutes, regulations, and the terms and condition of the Federal award 2 CFR 200.303 requires non-Federal entities, in part, to 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. CAUSE Not all grant agreement requirements were entered into the grant award template. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT The number of grant agreements during the audit period is listed below. A. Special Education Cluster - 134 awards - 14 tested with 10 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity B. Title I program - 276 awards - 25 tested with 16 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity C. Supporting Effective Instruction - 278 awards - 25 tested with 21 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - Federal award date - Federal award Identification Number (FAIN) - Total amount of the Federal award committed to the subrecipient by the pass-through entity D. Child and Adult Care Food Program - 134 awards - 14 tested with 2 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - 1 subrecipient did not have a grant contract E. Education Stabilization Fund - 641 awards - 40 tested with 10 errors noted The following criteria were missing or incorrect: - Subrecipient name (1 sample did not have the correct subrecipient name on the grant award) - Subrecipients unique entity identifier (2 did not match the Subrecipient name on grant award) - Federal award date (8 awards did not have this) - Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity (6 awards did not include Name of Federal Awarding Agency (Dept of Education) on grant award) Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-024 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Instruction update its grant award templates to ensure that subrecipients are made award of all required grant award information DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Special Education Cluster, Title 1, Supporting Effective Instruction, Child and Adult Care Food Program, and Education Stabilization Fund. CRITERIA 2 CFR 200.332 requires pass-through entities to communicate specific required information to subrecipients. Required information includes: - Subrecipients name (Must match the name associated with its unique entity identifier) - Subrecipients unique entity identifier - Federal award identification number (FAIN) - Federal award date - Subaward period of performance start and end date - Amount of Federal funds obligated in the subaward - Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Total amount of the Federal award committed to the subrecipient by the pass-through entity - Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listings title and number; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance listings number at the time of disbursement - Identification of whether the Federal award is for research and development - Indirect cost rate for the Federal award (including if the de minimis rate is used) - All requirements of the subaward, including requirements imposed by federal statutes, regulations, and the terms and condition of the Federal award 2 CFR 200.303 requires non-Federal entities, in part, to 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. CAUSE Not all grant agreement requirements were entered into the grant award template. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT The number of grant agreements during the audit period is listed below. A. Special Education Cluster - 134 awards - 14 tested with 10 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity B. Title I program - 276 awards - 25 tested with 16 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity C. Supporting Effective Instruction - 278 awards - 25 tested with 21 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - Federal award date - Federal award Identification Number (FAIN) - Total amount of the Federal award committed to the subrecipient by the pass-through entity D. Child and Adult Care Food Program - 134 awards - 14 tested with 2 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - 1 subrecipient did not have a grant contract E. Education Stabilization Fund - 641 awards - 40 tested with 10 errors noted The following criteria were missing or incorrect: - Subrecipient name (1 sample did not have the correct subrecipient name on the grant award) - Subrecipients unique entity identifier (2 did not match the Subrecipient name on grant award) - Federal award date (8 awards did not have this) - Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity (6 awards did not include Name of Federal Awarding Agency (Dept of Education) on grant award) Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-024 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Instruction update its grant award templates to ensure that subrecipients are made award of all required grant award information DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Special Education Cluster, Title 1, Supporting Effective Instruction, Child and Adult Care Food Program, and Education Stabilization Fund. CRITERIA 2 CFR 200.332 requires pass-through entities to communicate specific required information to subrecipients. Required information includes: - Subrecipients name (Must match the name associated with its unique entity identifier) - Subrecipients unique entity identifier - Federal award identification number (FAIN) - Federal award date - Subaward period of performance start and end date - Amount of Federal funds obligated in the subaward - Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Total amount of the Federal award committed to the subrecipient by the pass-through entity - Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listings title and number; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance listings number at the time of disbursement - Identification of whether the Federal award is for research and development - Indirect cost rate for the Federal award (including if the de minimis rate is used) - All requirements of the subaward, including requirements imposed by federal statutes, regulations, and the terms and condition of the Federal award 2 CFR 200.303 requires non-Federal entities, in part, to 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. CAUSE Not all grant agreement requirements were entered into the grant award template. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT The number of grant agreements during the audit period is listed below. A. Special Education Cluster - 134 awards - 14 tested with 10 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity B. Title I program - 276 awards - 25 tested with 16 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity C. Supporting Effective Instruction - 278 awards - 25 tested with 21 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - Federal award date - Federal award Identification Number (FAIN) - Total amount of the Federal award committed to the subrecipient by the pass-through entity D. Child and Adult Care Food Program - 134 awards - 14 tested with 2 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - 1 subrecipient did not have a grant contract E. Education Stabilization Fund - 641 awards - 40 tested with 10 errors noted The following criteria were missing or incorrect: - Subrecipient name (1 sample did not have the correct subrecipient name on the grant award) - Subrecipients unique entity identifier (2 did not match the Subrecipient name on grant award) - Federal award date (8 awards did not have this) - Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity (6 awards did not include Name of Federal Awarding Agency (Dept of Education) on grant award) Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-024 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Instruction update its grant award templates to ensure that subrecipients are made award of all required grant award information DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Special Education Cluster, Title 1, Supporting Effective Instruction, Child and Adult Care Food Program, and Education Stabilization Fund. CRITERIA 2 CFR 200.332 requires pass-through entities to communicate specific required information to subrecipients. Required information includes: - Subrecipients name (Must match the name associated with its unique entity identifier) - Subrecipients unique entity identifier - Federal award identification number (FAIN) - Federal award date - Subaward period of performance start and end date - Amount of Federal funds obligated in the subaward - Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Total amount of the Federal award committed to the subrecipient by the pass-through entity - Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listings title and number; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance listings number at the time of disbursement - Identification of whether the Federal award is for research and development - Indirect cost rate for the Federal award (including if the de minimis rate is used) - All requirements of the subaward, including requirements imposed by federal statutes, regulations, and the terms and condition of the Federal award 2 CFR 200.303 requires non-Federal entities, in part, to 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. CAUSE Not all grant agreement requirements were entered into the grant award template. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT The number of grant agreements during the audit period is listed below. A. Special Education Cluster - 134 awards - 14 tested with 10 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity B. Title I program - 276 awards - 25 tested with 16 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity C. Supporting Effective Instruction - 278 awards - 25 tested with 21 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - Federal award date - Federal award Identification Number (FAIN) - Total amount of the Federal award committed to the subrecipient by the pass-through entity D. Child and Adult Care Food Program - 134 awards - 14 tested with 2 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - 1 subrecipient did not have a grant contract E. Education Stabilization Fund - 641 awards - 40 tested with 10 errors noted The following criteria were missing or incorrect: - Subrecipient name (1 sample did not have the correct subrecipient name on the grant award) - Subrecipients unique entity identifier (2 did not match the Subrecipient name on grant award) - Federal award date (8 awards did not have this) - Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity (6 awards did not include Name of Federal Awarding Agency (Dept of Education) on grant award) Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-024 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Instruction update its grant award templates to ensure that subrecipients are made award of all required grant award information DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Special Education Cluster, Title 1, Supporting Effective Instruction, Child and Adult Care Food Program, and Education Stabilization Fund. CRITERIA 2 CFR 200.332 requires pass-through entities to communicate specific required information to subrecipients. Required information includes: - Subrecipients name (Must match the name associated with its unique entity identifier) - Subrecipients unique entity identifier - Federal award identification number (FAIN) - Federal award date - Subaward period of performance start and end date - Amount of Federal funds obligated in the subaward - Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Total amount of the Federal award committed to the subrecipient by the pass-through entity - Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listings title and number; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance listings number at the time of disbursement - Identification of whether the Federal award is for research and development - Indirect cost rate for the Federal award (including if the de minimis rate is used) - All requirements of the subaward, including requirements imposed by federal statutes, regulations, and the terms and condition of the Federal award 2 CFR 200.303 requires non-Federal entities, in part, to 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. CAUSE Not all grant agreement requirements were entered into the grant award template. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT The number of grant agreements during the audit period is listed below. A. Special Education Cluster - 134 awards - 14 tested with 10 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity B. Title I program - 276 awards - 25 tested with 16 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity C. Supporting Effective Instruction - 278 awards - 25 tested with 21 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - Federal award date - Federal award Identification Number (FAIN) - Total amount of the Federal award committed to the subrecipient by the pass-through entity D. Child and Adult Care Food Program - 134 awards - 14 tested with 2 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - 1 subrecipient did not have a grant contract E. Education Stabilization Fund - 641 awards - 40 tested with 10 errors noted The following criteria were missing or incorrect: - Subrecipient name (1 sample did not have the correct subrecipient name on the grant award) - Subrecipients unique entity identifier (2 did not match the Subrecipient name on grant award) - Federal award date (8 awards did not have this) - Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity (6 awards did not include Name of Federal Awarding Agency (Dept of Education) on grant award) Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-024 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Instruction update its grant award templates to ensure that subrecipients are made award of all required grant award information DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction incorrectly included neglected or delinquent facilities as part of their Title IIA allocation to Local Educational Agencies (LEA). We selected a sample of 17 in 2022-2023 and 17 in 2023-2024. Of the 17 samples in 2022-2023, we identified a 100% error rate. The total known allocation error identified was $60,026. This amount was the total allocated to negligent and delinquent districts. By allocating this amount to the noneligible districts, the eligible school districts were under allocated by the same amount. This was issue was fixed by the department for the 2023-2024 year and no error were found during the testing of 2023-2024. CRITERIA The Elementary and Secondary Education Act of 1965 (ESEA Section 2012(a)(1)) states, the State, acting through the State Educational Agency (DPI), shall award subgrants to eligible local educational agencies (LEA). 2 CFR 200.303(a) states that non-Federal entities 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, regulation, and the terms and conditions of the federal award. The Elementary and Secondary Education Act of 1965 (ESEA Section 8101(30) states "the term local educational agency means a public board of education or other public authority legally constituted within a state for either administrative control or direction of, or to perform a service function for, public elementary schools or secondary schools in a city, county, township, school district, or other political subdivision of a state, or for a combination of school districts or counties that is recognized in a state administrative agency for its public elementary school or secondary schools." The Elementary and Secondary Education Act of 1965 (ESEA Section 1432) defines Institutions for Neglected or Delinquent Children and Youth as "a public or private residential facility, other than a foster home, that is operated for the care of children who have been committed to the institution or voluntarily placed in the institution under applicable State law, due to abandonment, neglect, or death of their parents or guardian; or a public or private residential facility for the care of children who have deemed adjudicated to be delinquent or in need of supervision." As Neglected and Delinquent Facilities are operated only for the care of old children who have been committed or placed in their institution due to abandonment, neglect, death of their parents or guardians, or in need of supervision, these facilities are not recognized as Local Educational Agency. CAUSE The Department of Public Instruction was unaware that neglected and delinquent facilities could not be included in their Title IIA allocation calculation and on subrecipient's grant awards. EFFECT The Department of Public Instruction did not comply with the allocation requirements to LEAs for Title IIA grants. The LEAs eligible to receive funding were allocated less than they should have. CONTEXT The Department of Public Instruction allocated $9,834,095 in Federal funds to 169 school districts during the 2022-2023 school year and $9,939,938 in Federal funds to 169 school districts during the 2023-2024 school year. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-032 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction ensure the Title IIA allocations are calculated based on the Federal requirements. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Special Education Cluster, Title 1, Supporting Effective Instruction, Child and Adult Care Food Program, and Education Stabilization Fund. CRITERIA 2 CFR 200.332 requires pass-through entities to communicate specific required information to subrecipients. Required information includes: - Subrecipients name (Must match the name associated with its unique entity identifier) - Subrecipients unique entity identifier - Federal award identification number (FAIN) - Federal award date - Subaward period of performance start and end date - Amount of Federal funds obligated in the subaward - Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Total amount of the Federal award committed to the subrecipient by the pass-through entity - Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listings title and number; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance listings number at the time of disbursement - Identification of whether the Federal award is for research and development - Indirect cost rate for the Federal award (including if the de minimis rate is used) - All requirements of the subaward, including requirements imposed by federal statutes, regulations, and the terms and condition of the Federal award 2 CFR 200.303 requires non-Federal entities, in part, to 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. CAUSE Not all grant agreement requirements were entered into the grant award template. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT The number of grant agreements during the audit period is listed below. A. Special Education Cluster - 134 awards - 14 tested with 10 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity B. Title I program - 276 awards - 25 tested with 16 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity C. Supporting Effective Instruction - 278 awards - 25 tested with 21 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - Federal award date - Federal award Identification Number (FAIN) - Total amount of the Federal award committed to the subrecipient by the pass-through entity D. Child and Adult Care Food Program - 134 awards - 14 tested with 2 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - 1 subrecipient did not have a grant contract E. Education Stabilization Fund - 641 awards - 40 tested with 10 errors noted The following criteria were missing or incorrect: - Subrecipient name (1 sample did not have the correct subrecipient name on the grant award) - Subrecipients unique entity identifier (2 did not match the Subrecipient name on grant award) - Federal award date (8 awards did not have this) - Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity (6 awards did not include Name of Federal Awarding Agency (Dept of Education) on grant award) Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-024 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Instruction update its grant award templates to ensure that subrecipients are made award of all required grant award information DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Special Education Cluster, Title 1, Supporting Effective Instruction, Child and Adult Care Food Program, and Education Stabilization Fund. CRITERIA 2 CFR 200.332 requires pass-through entities to communicate specific required information to subrecipients. Required information includes: - Subrecipients name (Must match the name associated with its unique entity identifier) - Subrecipients unique entity identifier - Federal award identification number (FAIN) - Federal award date - Subaward period of performance start and end date - Amount of Federal funds obligated in the subaward - Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Total amount of the Federal award committed to the subrecipient by the pass-through entity - Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listings title and number; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance listings number at the time of disbursement - Identification of whether the Federal award is for research and development - Indirect cost rate for the Federal award (including if the de minimis rate is used) - All requirements of the subaward, including requirements imposed by federal statutes, regulations, and the terms and condition of the Federal award 2 CFR 200.303 requires non-Federal entities, in part, to 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. CAUSE Not all grant agreement requirements were entered into the grant award template. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT The number of grant agreements during the audit period is listed below. A. Special Education Cluster - 134 awards - 14 tested with 10 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity B. Title I program - 276 awards - 25 tested with 16 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity C. Supporting Effective Instruction - 278 awards - 25 tested with 21 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - Federal award date - Federal award Identification Number (FAIN) - Total amount of the Federal award committed to the subrecipient by the pass-through entity D. Child and Adult Care Food Program - 134 awards - 14 tested with 2 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - 1 subrecipient did not have a grant contract E. Education Stabilization Fund - 641 awards - 40 tested with 10 errors noted The following criteria were missing or incorrect: - Subrecipient name (1 sample did not have the correct subrecipient name on the grant award) - Subrecipients unique entity identifier (2 did not match the Subrecipient name on grant award) - Federal award date (8 awards did not have this) - Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity (6 awards did not include Name of Federal Awarding Agency (Dept of Education) on grant award) Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-024 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Instruction update its grant award templates to ensure that subrecipients are made award of all required grant award information DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Special Education Cluster, Title 1, Supporting Effective Instruction, Child and Adult Care Food Program, and Education Stabilization Fund. CRITERIA 2 CFR 200.332 requires pass-through entities to communicate specific required information to subrecipients. Required information includes: - Subrecipients name (Must match the name associated with its unique entity identifier) - Subrecipients unique entity identifier - Federal award identification number (FAIN) - Federal award date - Subaward period of performance start and end date - Amount of Federal funds obligated in the subaward - Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Total amount of the Federal award committed to the subrecipient by the pass-through entity - Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listings title and number; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance listings number at the time of disbursement - Identification of whether the Federal award is for research and development - Indirect cost rate for the Federal award (including if the de minimis rate is used) - All requirements of the subaward, including requirements imposed by federal statutes, regulations, and the terms and condition of the Federal award 2 CFR 200.303 requires non-Federal entities, in part, to 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. CAUSE Not all grant agreement requirements were entered into the grant award template. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT The number of grant agreements during the audit period is listed below. A. Special Education Cluster - 134 awards - 14 tested with 10 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity B. Title I program - 276 awards - 25 tested with 16 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity C. Supporting Effective Instruction - 278 awards - 25 tested with 21 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - Federal award date - Federal award Identification Number (FAIN) - Total amount of the Federal award committed to the subrecipient by the pass-through entity D. Child and Adult Care Food Program - 134 awards - 14 tested with 2 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - 1 subrecipient did not have a grant contract E. Education Stabilization Fund - 641 awards - 40 tested with 10 errors noted The following criteria were missing or incorrect: - Subrecipient name (1 sample did not have the correct subrecipient name on the grant award) - Subrecipients unique entity identifier (2 did not match the Subrecipient name on grant award) - Federal award date (8 awards did not have this) - Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity (6 awards did not include Name of Federal Awarding Agency (Dept of Education) on grant award) Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-024 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Instruction update its grant award templates to ensure that subrecipients are made award of all required grant award information DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Special Education Cluster, Title 1, Supporting Effective Instruction, Child and Adult Care Food Program, and Education Stabilization Fund. CRITERIA 2 CFR 200.332 requires pass-through entities to communicate specific required information to subrecipients. Required information includes: - Subrecipients name (Must match the name associated with its unique entity identifier) - Subrecipients unique entity identifier - Federal award identification number (FAIN) - Federal award date - Subaward period of performance start and end date - Amount of Federal funds obligated in the subaward - Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Total amount of the Federal award committed to the subrecipient by the pass-through entity - Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listings title and number; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance listings number at the time of disbursement - Identification of whether the Federal award is for research and development - Indirect cost rate for the Federal award (including if the de minimis rate is used) - All requirements of the subaward, including requirements imposed by federal statutes, regulations, and the terms and condition of the Federal award 2 CFR 200.303 requires non-Federal entities, in part, to 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. CAUSE Not all grant agreement requirements were entered into the grant award template. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT The number of grant agreements during the audit period is listed below. A. Special Education Cluster - 134 awards - 14 tested with 10 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity B. Title I program - 276 awards - 25 tested with 16 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity C. Supporting Effective Instruction - 278 awards - 25 tested with 21 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - Federal award date - Federal award Identification Number (FAIN) - Total amount of the Federal award committed to the subrecipient by the pass-through entity D. Child and Adult Care Food Program - 134 awards - 14 tested with 2 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - 1 subrecipient did not have a grant contract E. Education Stabilization Fund - 641 awards - 40 tested with 10 errors noted The following criteria were missing or incorrect: - Subrecipient name (1 sample did not have the correct subrecipient name on the grant award) - Subrecipients unique entity identifier (2 did not match the Subrecipient name on grant award) - Federal award date (8 awards did not have this) - Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity (6 awards did not include Name of Federal Awarding Agency (Dept of Education) on grant award) Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-024 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Instruction update its grant award templates to ensure that subrecipients are made award of all required grant award information DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Special Education Cluster, Title 1, Supporting Effective Instruction, Child and Adult Care Food Program, and Education Stabilization Fund. CRITERIA 2 CFR 200.332 requires pass-through entities to communicate specific required information to subrecipients. Required information includes: - Subrecipients name (Must match the name associated with its unique entity identifier) - Subrecipients unique entity identifier - Federal award identification number (FAIN) - Federal award date - Subaward period of performance start and end date - Amount of Federal funds obligated in the subaward - Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Total amount of the Federal award committed to the subrecipient by the pass-through entity - Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listings title and number; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance listings number at the time of disbursement - Identification of whether the Federal award is for research and development - Indirect cost rate for the Federal award (including if the de minimis rate is used) - All requirements of the subaward, including requirements imposed by federal statutes, regulations, and the terms and condition of the Federal award 2 CFR 200.303 requires non-Federal entities, in part, to 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. CAUSE Not all grant agreement requirements were entered into the grant award template. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT The number of grant agreements during the audit period is listed below. A. Special Education Cluster - 134 awards - 14 tested with 10 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity B. Title I program - 276 awards - 25 tested with 16 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity C. Supporting Effective Instruction - 278 awards - 25 tested with 21 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - Federal award date - Federal award Identification Number (FAIN) - Total amount of the Federal award committed to the subrecipient by the pass-through entity D. Child and Adult Care Food Program - 134 awards - 14 tested with 2 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - 1 subrecipient did not have a grant contract E. Education Stabilization Fund - 641 awards - 40 tested with 10 errors noted The following criteria were missing or incorrect: - Subrecipient name (1 sample did not have the correct subrecipient name on the grant award) - Subrecipients unique entity identifier (2 did not match the Subrecipient name on grant award) - Federal award date (8 awards did not have this) - Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity (6 awards did not include Name of Federal Awarding Agency (Dept of Education) on grant award) Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-024 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Instruction update its grant award templates to ensure that subrecipients are made award of all required grant award information DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not ensure all subrecipients submitted a Single Audit Report or a form identifying a Single Audit is not required. In addition, The Department of Public Instruction did not issue management decisions on audit findings within 6 months or ensure that timely and appropriate corrective action was taken in all applicable instances. CRITERIA 2 CFR 200.331(f) states that a pass-through entity must verify that every subrecipient is audited as required by 2 CFS 200 Subpart F. 2 CFR 200.311(d)(2) states that a pass-through entity must ensure subrecipients take timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity through audits, on-site reviews, and other means. 2 CFR 200.521(d) states that a pass-through entity must issue a management decision within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). 2 CFR 200.303(a) states that non-federal entities 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 statutes, regulations, and the terms and condition of the federal award. CAUSE The Department of Public Instruction maintains a spreadsheet to track all subrecipient audit report monitoring, however, they did not ensure that everyone on the spreadsheet provided a Single Audit report, or review the filed report within 6 months, or provided a certification of total federal expenditures. EFFECT Subrecipients spending more than $750,000 from all federal sources may not be obtaining audits as required or may not be implementing a corrective action plan in a timely manner if findings are noted in audits that were completed. The Department of Public instruction is not meeting the requirements of 2 CFR 200 Subpart F. CONTEXT The total number of subrecipients was 536 and the total amount received from the Department of Public Instruction was $667,731,290. Where sampling was performed, the audit used a non-statistical sampling method. Of all the subrecipients that had errors, the total amount they received from the Department of Public Instruction was $53,403,270. Sixty subrecipients that received funds from the Department of Public Instruction were included in our sampling. One subrecipient was not included on the Departments tracking spreadsheet, two subrecipients did not received the required audit as required by 2 CFR Subpart F. 10 Subrecipients had reports filed, but the Department did not review the report within the required 6 month window. IDENTIFICATION AS A REPEAT FINDING Finding 2022-033 was reported in the immediate prior year. Findings 2020-021 and 2018-041 were reported in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction: • Ensure all subrecipients obtain audits in accordance with 2 CFR 200 Subpart F if they meet the requirements; • Issue management decisions within a timely manner; • Ensure subrecipients took timely corrective action on deficiencies identified in the audits. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Special Education Cluster, Title 1, Supporting Effective Instruction, Child and Adult Care Food Program, and Education Stabilization Fund. CRITERIA 2 CFR 200.332 requires pass-through entities to communicate specific required information to subrecipients. Required information includes: - Subrecipients name (Must match the name associated with its unique entity identifier) - Subrecipients unique entity identifier - Federal award identification number (FAIN) - Federal award date - Subaward period of performance start and end date - Amount of Federal funds obligated in the subaward - Total amount of Federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Total amount of the Federal award committed to the subrecipient by the pass-through entity - Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listings title and number; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance listings number at the time of disbursement - Identification of whether the Federal award is for research and development - Indirect cost rate for the Federal award (including if the de minimis rate is used) - All requirements of the subaward, including requirements imposed by federal statutes, regulations, and the terms and condition of the Federal award 2 CFR 200.303 requires non-Federal entities, in part, to 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. CAUSE Not all grant agreement requirements were entered into the grant award template. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT The number of grant agreements during the audit period is listed below. A. Special Education Cluster - 134 awards - 14 tested with 10 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity B. Title I program - 276 awards - 25 tested with 16 errors noted The following criteria were missing or incorrect: - Total amount of the Federal award committed to the subrecipient by the pass-through entity C. Supporting Effective Instruction - 278 awards - 25 tested with 21 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - Federal award date - Federal award Identification Number (FAIN) - Total amount of the Federal award committed to the subrecipient by the pass-through entity D. Child and Adult Care Food Program - 134 awards - 14 tested with 2 errors noted The following criteria were missing or incorrect: - Subrecipients unique entity identifier - 1 subrecipient did not have a grant contract E. Education Stabilization Fund - 641 awards - 40 tested with 10 errors noted The following criteria were missing or incorrect: - Subrecipient name (1 sample did not have the correct subrecipient name on the grant award) - Subrecipients unique entity identifier (2 did not match the Subrecipient name on grant award) - Federal award date (8 awards did not have this) - Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity (6 awards did not include Name of Federal Awarding Agency (Dept of Education) on grant award) Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-024 was reported in the immediate prior year. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Instruction update its grant award templates to ensure that subrecipients are made award of all required grant award information DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the finding. See “Management’s Response and Corrective Action” section of this report.
CONDITION The audit tested quarterly Project and Expenditure reports of the State and Local Fiscal Recovery Funds (SLFRF) program for the periods ending March 2023, December 2023, and June 2024. Project and Expenditure reports are prepared and submitted by the ND Office of Management and Budget. Errors in key line items in all three quarterly Project and Expenditures Reports tested were identified. Key line items with errors included current period expenditures, cumulative expenditures, and current period obligations. Current period expenditures reported on the March 2023 and December 2023 reports did not agree to the tracking spreadsheet used to prepare the report. The net unreconciled difference in current period expenditures for these quarters was $732,036. The reason for the difference included that OMB's own SLFRF expenditures were not reported in the proper period. Cumulative expenditures reported by OMB for all three covered periods did not agree to the tracking spreadsheet used to prepare the report. The state's actual cumulative expenditures were not determined since changes or revisions can be reflected in the next Project and Expenditures report. However, cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130 while cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688. The basis of accounting used to prepare the SEFA varies amongst the agencies and universities; however, the state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Current period obligations reported by OMB for the covered period ending June 30, 2024, totaled $93,696,726, which should have been $0. This error did not impact the cumulative obligation amount since OMB previously reported the state's SLFRF allotment was 100% obligated in the cumulative obligation amount for the covered period ending December 31, 2023. CRITERIA According to Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, states are required to submit quarterly Project and Expenditure Reports. The 2023 and 2024 Compliance Supplements indicate the following line items are key line items: current period obligation, cumulative obligation, current period expenditure, and cumulative expenditure are key line items. In addition, report corrections cannot be made after the reporting deadline unless prompted by Treasury staff. Any changes or revisions will need to be reflected in the next Project and Expenditure report. 2 CFR 200.502 states that the determination of when a federal award is expended must be based on when the activity related to the award occurs. In general, the activity pertains to events that require the nonfederal entity to comply with federal statutes, regulations, and the terms and conditions of federal awards. 2 CFR 200.303(a) states that non-Federal entities 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. CAUSE OMB manages State and Local Fiscal Recovery Funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures are incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds were included in the federal report for the period in which reimbursement to the agency occurred. In some cases, this resulted in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report. In addition, OMB's reporting process did not identify its own SLFRF expenditures in a timely manner. Lastly, OMB did not consistently utilize its tracking spreadsheet for reporting certain key line items. EFFECT State and Local Fiscal Recovery Funds (SLFRF) data reported to the U.S. Department of Treasury in quarterly Project and Expenditures Reports was inaccurate. CONTEXT In March 2021, the Federal Department of Treasury obligated funds to all 50 states under the State Local and Fiscal Recovery Fund to help states mitigate negative economic impacts caused by the COVID-19 pandemic. In November 2021, the special session of the 67th legislature obligated use of the majority of the funds to various agencies across the state. As the state was able to show that the revenue lost in years 2020 and 2021 exceeded the amount of the obligation from the Department of Treasury, the state was able to claim use of these funds under revenue replacement which allowed the state to utilize them for 'government operations' in addition to other specific uses and also allowing the state to report use of these funds under a single 'revenue replacement' project. The agencies began using the funds for purposes after they were obligated by the state legislature and began recording expenditures against the grant throughout our audit period. When these funds were initially disbursed to the state in March 2021, the funds were received by OMB and OMB then transferred reimbursement to agencies on request. The remainder of the funds were obligated by the state legislature during the 68th Legislative Assembly, which included any turnback funds obligated in previous legislation. North Dakota's project description on the reports was consistent and based on legislative appropriation. As reported, "Due to its extraordinary revenue loss during the pandemic, North Dakota’s entire SLFRF allocation is dedicated to project expenditure category group 6 – Revenue Replacement. Consequently, all expenditures will fall under project expenditure category 6.1 – Provision of Government Services. Government services, as defined by the North Dakota legislature, includes economic development and workforce development initiatives, infrastructure and deferred maintenance initiatives, state service delivery and information technology improvements, and healthcare and emergency response initiatives." Cumulative expenditures reported by OMB for the covered period ending June 30, 2024, totaled $686,652,130. Cumulative expenditures reported by agencies and universities on SEFAs for the same period totaled $670,946,688; however, the basis of accounting used to prepare the SEFA varies amongst the agencies and universities. The state's cumulative expenditures are expected to reconcile to the state's SLFRF allocation in its final Project and Expenditure Report. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2022-035 was reported in the immediate prior year. RECOMMENDATION We recommend the Office of Management and Budget ensure quarterly Project and Expenditure Reports accurately report the State's SLFRF obligations and expenditures to the Department of Treasury. OFFICE OF MANAGEMENT AND BUDGET RESPONSE The Office of Management agrees with this finding, but will continue federal reporting based on the timing of reimbursement of expenditures to other state agencies for the duration of the SLFRF reporting period. OMB will ensure all expenditures of SFLRF funding are accurately included in the reports based on the period of reimbursement. Because OMB is responsible for the state reporting under this program, it is necessary to maintain some level of control over these funds. Consequently, OMB manages the funds centrally and developed a process to reimburse agencies for their eligible expenditures once expenditures were incurred and agencies requested reimbursement. As a result, reimbursement from the state’s allocation of SLFRF moneys always occurs after the agency expenditure. Funds are included in the Federal report for the period in which reimbursement from the SLFRF occurs. In some cases, this results in the agency expenditure occurring in a period prior to the period covered under the quarterly SLFRF report in which the reimbursement is reported. To better track OMB expenditures of SLFRF moneys, which is a separate process from the reimbursement of other agencies, OMB will run specific expense reports for OMB agency expenditures to ensure all SLFRF expenses are reported in the proper period. See “Management’s Response and Corrective Action” section of this report. AUDITOR’S CONCLUDING COMMENTS While the Office of Management and Budget agrees with the finding, continuing Federal reporting based on the timing of reimbursed expenditures will likely cause further inaccurate SLFRF reporting. In addition, amounts transferred to agencies are not confirmed to not exceed incurred expenditures to ensure a reimbursement process is in place.
CONDITION Quarterly Project and Expenditure Reports tested did not accurately report key line items for each project. CRITERIA Coronavirus Capital Projects Fund Compliance and Reporting Guidance For States, Territories, and Freely Associated States (published December 2022) indicates that expenditures may be reported on a cash or accrual basis as long as the methodology is disclosed and is consistently applied. Project and Expenditure Reports must incorporate the definition of expenditures pursuant to 2 CFR 200.1. Recipients must maintain accounting records for compiling and reporting accurate financial data in accordance with appropriate accounting standards and principles. The guidance also defines "Obligations" as orders placed for property and services, contracts and subawards made, and similar transactions that require payment. In addition, for Multipurpose Community Facility Projects, recipients are required to report, for each project, current period obligations, cumulative obligations, current period expenditures, and cumulative expenditures; as well as total square footage funded by CPF dollars (planned/actual). Lastly, the guidance allows edits or changes to be reflected in the next available report. Federal regulation, 2 CFR 200.303, requires non-Federal entities, in part, to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Per GAO Standards for Internal Control in Federal Government, Information and Communication, Principle 13 - Use of Quality Information, Attribute 13.04, management should obtain relevant data from reliable internal and external sources in a timely manner based on the identified information requirements. CAUSE Career and Technical Education did not consistently utilize accounting records for compiling Project and Expenditure Report data in accordance with appropriate accounting standards and principles. The tracking spreadsheet used to prepare the reports lacked a consistent basis of accounting for tracking payments since certain dates reflected in the spreadsheet did not agree to the state's accounting system (PeopleSoft) posted dates. Lastly, Career and Technical Education was unaware of the definition of an "obligation" until it was brought up during the Single Audit. EFFECT Inaccurate Project and Expenditure Reports limit the Treasury's ability to effectively track and monitor the use of the Coronavirus Capital Projects Fund for approved projects. In addition, inaccurate Project and Expenditures Reports also impacts the accuracy of program reporting for public transparency purposes. CONTEXT The Career and Technical Education entered into grant agreements with subrecipients on March 17, 2022, that obligated the initial CPF appropriation of $68,276,228 for multipurpose community facility projects. These grant agreements were subsequently amended in March 2024 to allocate $6,319,473 of CPF initially appropriated for broadband projects. We tested the Project and Expenditure Reports which covered the periods January 1, 2024, to March 31, 2024, and April 1, 2024, to June 30, 2024. For the covered period January 1, 2024, to March 31, 2024, current period obligations were overstated by $9,272,777, cumulative obligations were understated by $36,987,052, current period expenditures were incorrectly reported for 5 out of 19 projects (in total, current period expenditures were understated by $124,881 using the cash basis) and cumulative expenditures were incorrectly reported for 7 out of 19 projects (in total, cumulative expenditures were overstated by $143,376 using the cash basis). For the covered period April 1, 2024, to June 30, 2024, current period obligations were overstated by $10,308,528, cumulative obligation amounts were corrected based on discussions with the auditor, current period expenditures were incorrectly reported for 8 out of 19 projects (in total, current period expenditures were overstated by $1,639,438 using the cash basis), and cumulative expenditures were incorrectly reported for 9 out of 19 projects (in total, cumulative expenditures were overstated by $2,223,450 using the cash basis or understated by $737,558 using the accrual basis). Lastly, it appeared total square footage reported (planned and actual) included square footage funded by all funding sources and not the square footage funded solely by CPF. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Career and Technical Education establish a consistent methodology for compiling and reporting financial data that is in accordance with appropriate accounting standards and principles. We also recommend the Career and Technical Education comply with Project and Expenditure Report guidance for reporting obligations, expenditures, and total square footage funded by Capital Project Fund dollars, including making any necessary edits and changes in the next available report. CAREER AND TECHNICAL EDUCATION RESPONSE The Department agrees with this recommendation See “Management’s Response and Corrective Action” section of this report.
CONDITION Career and Technical Education is not verifying every subrecipient is audited and reviewing audit findings as required by 2 CFR 200, Subpart F. Subsequently, by not verifying every subrecipient is audited, Career and Technical Education is not ensuring their responsibilities for issuing management decisions are performed, if any findings are identified in the audits. CRITERIA All pass-through entities must: • Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and terms and conditions of the subaward, and that the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, in part, following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward; issuing a management decision for applicable audit findings pertaining only to the federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521; and ensuring audit findings specifically related to the subaward are resolved (2 CFR 200.332(d)). • Verify that every subrecipient is audited as required by 2 CFR 200, Subpart F, when it is expected that the subrecipient's Federal award expended during the respective fiscal year equaled or exceeded the $750,000 threshold set forth in 2 CFR 200.501 (2 CFR 200.332(f). Federal regulation, 2 CFR 200.303, requires non-Federal entities, in part, to 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. CAUSE Career and Technical Education has not established processes to identify which subrecipients are subject to required audits or to obtain and review Uniform Guidance Single Audit reports. In addition, Career and Technical Education has not developed a tracking system to ensure timely submission of required audit reports and to ensure timely and appropriate corrective action is taken on all deficiencies. EFFECT Subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward, including audit findings pertaining to the Federal award, may go undetected and unresolved. CONTEXT Career and Technical Education awarded subawards, individually up to $10 million, to 13 subrecipients totaling $74.6 million for 19 different multi-purpose community facility projects. Career and Technical Education has had prior experience with these subrecipients. Projects were included in the state’s program plan that was reviewed and approved by U.S. Treasury. Career and Technical Education imposed specific subaward conditions upon each subrecipient requiring payments as reimbursements rather than advance payments. Career and Technical Education performs ongoing monitoring procedures through review and approval of subrecipient requests for reimbursements, which includes reviewing invoices and contractor progress billings for unallowable expenses, prior to disbursing Capital Project Funds. Lastly, Career and Technical Education conducts annual on-site visits of started projects until completed to visually inspect projects are being completed as planned. Where sampling was performed, the audit used a non-statistical sampling method. This finding, in combination with the finding regarding required communication of award information to the subrecipients (Finding 2024-04), results in a modified opinion for the subrecipient monitoring compliance requirement. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend Career and Technical Education establish processes to identify which subrecipients are subject to required audits and to obtain and review Uniform Guidance Single Audit reports, including developing a tracking system to ensure timely submission of required audit reports and timely and appropriate corrective action is taken on all deficiencies. We also recommend Career and Technical Education verify every subrecipient is audited as required by 2 CFR 200, Subpart F; follow-up and ensure that subrecipients take timely and appropriate action on all deficiencies of the Federal award; and issue management decisions and ensure audit findings have been resolved. CAREER AND TECHNICAL EDUCATION RESPONSE The Department agrees with this recommendation See “Management’s Response and Corrective Action” section of this report.
CONDITION The Career and Technical Education did not ensure all required information was provided to subrecipients provided Coronavirus Capital Project Funds CPF). In addition, the pass-through entity's internal controls were insufficient to ensure that subrecipients received communication regarding the necessary items. Required information not communicated included: • Subrecipient's name did not always match the name associated with its unique entity identifier obtained from SAM.gov; • Subrecipient's unique entity identifier; • Federal Award Identification Number; • Federal Award date; • Subaward Period of Performance Start and End Date; • Amounts of the Federal Funds obligated, committed, and in total to the subrecipient by the pass-through entity were not clearly identifiable between Coronavirus Capital Projects Fund and Coronavirus State and Local Fiscal Recovery Funds; • Assistance Listing Number; and, • Reference of requirement for auditor access to the subrecipient's records and financial statements. CRITERIA Federal regulation, 2 CFR 200.332(a), requires pass-through entities to communicate specific required information to subrecipients. Federal regulation, 2 CFR 200.303, requires non-Federal entities, in part, to 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. CAUSE Career and Technical Education worked with the Attorney General's Office to develop a standard template for agreements with subrecipients. However, Career and Technical Education did not ensure all required communications applicable to Federal awards were included in the standard template. EFFECT These required communications are required to help subrecipients meet all their reporting requirements, and to meet all award terms. Subrecipients subject to Single Audits also need this information for their audits. CONTEXT Career and Technical Education awarded Capital Project Fund subawards, individually up to $10 million, to 13 subrecipients totaling $74.6 million for 19 different multi-purpose community facility projects. Four subaward agreements were tested and all did not include the required information identified in the condition of this finding. In addition, three subrecipients received $6,666,667 for the projects from the State and Local Fiscal Recovery Fund. Career and Technical Education only entered into one grant agreement, which commingled Capital Project Funds and State and Local Fiscal Recovery Funds, with three of the 13 subrecipients. One of the three subrecipients that received both Capital Project Funds and State and Local Fiscal Recovery Funds had its fiscal year 2023 Single Audit on the Federal Audit Clearinghouse. This subrecipient incorrectly reported all $10 million as Capital Project Funds (ALN 21.029) on its Schedule of Expenditures of Federal Awards when only $3,333,333 should have been reported under ALN 21.029. Where sampling was performed, the audit used a non-statistical sampling method. This finding, in combination with the finding regarding required audits (Finding 2024-03), results in a modified opinion for the subrecipient monitoring compliance requirement. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend Career and Technical Education: • Communicate all required information of 2 CFR 200.332(b) to subrecipients; • Develop procedures to ensure grant agreement templates are updated and that all Coronavirus Capital Projects Fund award information is communicated to subrecipients; and, • Reissue grant agreements to outline the required information. CAREER AND TECHNICAL EDUCATION RESPONSE The Department agrees with this recommendation See “Management’s Response and Corrective Action” section of this report.
CONDITION The Department of Health and Human Services (DHHS) charged WIC special formula distribution center food outlay costs to the wrong Federal fiscal year. CRITERIA Federal regulation, 2 CFR 200.403(h), states, in part, in order to be allowable under Federal awards, costs must be incurred during the approved budget period. Federal regulation, 2 CFR 200.303, requires non-Federal entities, in part, to 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. CAUSE The Department of Health and Human Services does not have a procedure to ensure special formula distribution center food outlays are applied to the correct Federal fiscal year. EFFECT The WIC special formula distribution center food outlay costs charged to the wrong Federal fiscal year resulted in unallowable costs to the Federal fiscal year in which they were charged since the costs were outside of the period of performance for grant. This also impacted the accuracy of Federal fiscal year expenses reported to USDA Food and Nutrition Services. CONTEXT State agencies can only charge allowable costs for obligations incurred during the grant's period of performance. The WIC grant is available for one year, October 1 through September 30, and only obligations incurred during that period can be charged to the grant. The Department of Health and Human Services incurred costs in August 2022 for FFY 2022 for special formula distribution center food outlays that were paid in February 2023 and charged to FFY 2023. A random sample test identified a known error amount is $15,451 with likely projected questioned costs of $71,642. Twenty-six special formula distribution center payments were made during the audit period totaling $604,441. Aside from the projection and based on support provided by DHHS, eight special formula distribution center payments, in addition to the known error from sample testing, totaling $198,289, are likely charged to the incorrect Federal fiscal year. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the Department of Health and Human Services establish procedures to ensure WIC special formula distribution center food outlay costs are charged to the proper Federal fiscal year. We also recommend the Department of Health and Human Services work with U.S. Food and Nutrition Services to complete a post closeout adjustment to accurately reflect expenses within the correct Federal fiscal years. DEPARTMENT OF HEALTH AND HUMAN SERVICES RESPONSE The Department of Health and Human Services agrees with the recommendation. See “Management’s Response and Corrective Action” section of this report.