Finding Reference Number: 2024-014 COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W) Federal Award Numbers: S425D210017, S425U210017 Federal Award Year: 2021 U.S. Department of Education Compliance Requirement: Reporting Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-008 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria ESSER, GEER, and EANS grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. LEAs/subrecipients submit data to the SEA/Governor for the SEA’s/Governor’s report. Report Title: ESF – ESSER Recipient Data Collection Form (OMB No 1810-0749) is required to filled annually in the spring based on the State fiscal year. Key line items include: 1. Line 3.b1 LEA expenditures by ESSER Subgrant fund, expenditure category, and object code 2. Line 3.b10 Number of specific positions supported with ESSER Funds 3. Line 3.c Allocation of ESSER funds to schools and criteria used to allocate funds to schools 4. Line 5.a Full Time Equivalent positions Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Funds (ESF) to subrecipients (Local Educational Agencies). During our testwork over special reporting at the Department for ESF Grants, we selected each annual report for ESSER, GEER, and EANS Recipient Data Collection Forms and noted for the ESSER Recipient Data Collection Form, there was no supporting documentation provided to adequately reconcile the difference from the underlying support to the reported amounts for key line item 3.c on the ESSER Recipient Data Collection Form. Discrepancies include the following: A. For ESSER I, total amount of remaining grant funds and amount of remaining funds planned for specific purpose each reported as $0 while underlying support shows $423 for an unreconciled difference of $423. B. For ESSER II, total amount of grant expended by the SEA and all state subrecipients in the reporting period reported as $85,705,938 while underlying support shows $82,847,502 for an unreconciled difference of $2,858,436. C. For ESSER II, total amount of remaining grant funds and amount of remaining funds planned for a specific purpose each reported as $240,920,978 while underlying support shows $243,779,414 for an unreconciled difference of $2,858,436. D. For ESSER III, total amount of SEA Reserve that SEA expended directly in the current reporting period reported as $3,409,199 while underlying support shows $3,133,439 for an unreconciled difference of $275,760. E. For ESSER III, total amount of Summer Enrichment Set Aside reported as $0 while underlying support shows $247,835 for an unreconciled difference of $247,835. F. For ESSER III, total amount of Afterschool Programs Set Aside reported as $709,512 while underlying support shows $1,295,12 for an unreconciled difference of $709,512. G. For ESSER III, total amount of Emergency Needs and/or Admin Costs Set Aside reported as $395,035 while underlying support shows $274,198 for an unreconciled difference of $120,837. Cause The cause of the condition found that there are insufficient policies and procedures in place to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed and that amounts are reconciled to the report. Based on the documentation that was provided to support the data reported within each annual report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate. Effect The effect of the condition found is that the ESSER annual report was not complete and accurate when it was filed. Questioned Costs: None. Recommendation We recommend that policies and procedures be developed to ensure that all documentation to support the amounts reported on the ESSER Recipient Data Collection Form is properly maintained for each annual report. In addition, internal control procedures be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documented showing evidence that the required review process was performed prior to submitting the annual Recipient Data Collection Form. View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-014 COVID-19 Education Stabilization Fund (Assistance Listing #84.425D, #84.425R, #84.425U, #84.425V, and #84.425W) Federal Award Numbers: S425D210017, S425U210017 Federal Award Year: 2021 U.S. Department of Education Compliance Requirement: Reporting Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-008 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria ESSER, GEER, and EANS grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. LEAs/subrecipients submit data to the SEA/Governor for the SEA’s/Governor’s report. Report Title: ESF – ESSER Recipient Data Collection Form (OMB No 1810-0749) is required to filled annually in the spring based on the State fiscal year. Key line items include: 1. Line 3.b1 LEA expenditures by ESSER Subgrant fund, expenditure category, and object code 2. Line 3.b10 Number of specific positions supported with ESSER Funds 3. Line 3.c Allocation of ESSER funds to schools and criteria used to allocate funds to schools 4. Line 5.a Full Time Equivalent positions Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During the year ended June 30, 2024, we noted the New Hampshire Department of Education (the Department) passed through $145,806,837 in Education Stabilization Funds (ESF) to subrecipients (Local Educational Agencies). During our testwork over special reporting at the Department for ESF Grants, we selected each annual report for ESSER, GEER, and EANS Recipient Data Collection Forms and noted for the ESSER Recipient Data Collection Form, there was no supporting documentation provided to adequately reconcile the difference from the underlying support to the reported amounts for key line item 3.c on the ESSER Recipient Data Collection Form. Discrepancies include the following: A. For ESSER I, total amount of remaining grant funds and amount of remaining funds planned for specific purpose each reported as $0 while underlying support shows $423 for an unreconciled difference of $423. B. For ESSER II, total amount of grant expended by the SEA and all state subrecipients in the reporting period reported as $85,705,938 while underlying support shows $82,847,502 for an unreconciled difference of $2,858,436. C. For ESSER II, total amount of remaining grant funds and amount of remaining funds planned for a specific purpose each reported as $240,920,978 while underlying support shows $243,779,414 for an unreconciled difference of $2,858,436. D. For ESSER III, total amount of SEA Reserve that SEA expended directly in the current reporting period reported as $3,409,199 while underlying support shows $3,133,439 for an unreconciled difference of $275,760. E. For ESSER III, total amount of Summer Enrichment Set Aside reported as $0 while underlying support shows $247,835 for an unreconciled difference of $247,835. F. For ESSER III, total amount of Afterschool Programs Set Aside reported as $709,512 while underlying support shows $1,295,12 for an unreconciled difference of $709,512. G. For ESSER III, total amount of Emergency Needs and/or Admin Costs Set Aside reported as $395,035 while underlying support shows $274,198 for an unreconciled difference of $120,837. Cause The cause of the condition found that there are insufficient policies and procedures in place to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed and that amounts are reconciled to the report. Based on the documentation that was provided to support the data reported within each annual report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate. Effect The effect of the condition found is that the ESSER annual report was not complete and accurate when it was filed. Questioned Costs: None. Recommendation We recommend that policies and procedures be developed to ensure that all documentation to support the amounts reported on the ESSER Recipient Data Collection Form is properly maintained for each annual report. In addition, internal control procedures be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documented showing evidence that the required review process was performed prior to submitting the annual Recipient Data Collection Form. View of Responsible Officials: Management concurs with the finding above
Finding Reference Number: 2024-030 NH Department of Education Disability Insurance/SSI Cluster (Assistance Listing #96.001) Federal Award Numbers: 2304NHDI00, 2404NHD100 Federal Award Year: 2023, 2024 U.S. Social Security Administration Compliance Requirement: Reporting Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-019 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. The SSA-4513 – State Agency Report of Obligations for SSA Disability Programs – is due quarterly for each fiscal year still open in order to account for program disbursements and unliquidated obligations (POMS DI 39506.202). Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testwork over federal reporting related to the SSA-4513 quarterly report, we identified the following: A. For all 4 of 9 SSA-4513 reports selected for testwork, line item 7 was not checked to identify if the SSA-871 needed to be attached to the report. It is unclear if this needed to be attached or not. B. For all 9 SSA-4513 reports selected for testwork, the reports did not reconcile to the internal tracking sheets provided to validate the amounts reported. For all reports there were variances between the tracking sheets and the dollar amounts included within the federal report within sections 1, 2, 3 and 4. While variances are identified, we noted that the variances were not material overall to the individual line item. C. For all 9 SSA-4513 reports selected for testwork, we were unable to validate the completeness and accuracy of the amounts reported within Section 1 for Columns (A) for Disbursements, (B) for unliquidated obligations and (C) total obligations for line items 1, 2, 3 and 4. As such, we are not able to validate that the amounts reported are complete and accurate. As we were not able to obtain documentation to validate the obligation balances, we are unable to validate the accuracy of amounts reported within Sections 1, 2, and 3 of the report. D. For all 9 of the SSA-4513 reports selected for testwork, there was no support for the difference between the total obligations and cumulative obligational authorization. E. For 1 of 9 SSA-4513 reports selected for testwork, no supporting documentation was provided. F. For 8 of 9 SSA-4513 reports selected for testwork, documentation was not provided for Line Item 2.d, Other Identity obligation & amount Cause The cause of the condition found related to the SSA-4513 was due to insufficient policies and procedures to ensure that all necessary documentation is maintained to support the amounts reported for each federal report filed. Based on the documentation that was provided to support the data reported within each quarterly report, it is unclear if the internal control review procedures performed included a detail review over each line item of the report to ensure the amount reported is complete and accurate. Effect The effect of the condition found is the SSA-4134 reports were not complete and accurate when they were filed. Questioned Costs: None. Recommendation We recommend that the existing policies and procedures be developed to ensure that all documentation to support the amounts reported on the SSA-4513 is properly maintained for each quarterly report. In addition, internal control procedures should be evaluated to ensure that as part of the review process, each line item on the federal report is verified against the supporting documentation to ensure the report is complete and accurate. The review performed should also be properly documenting showing that the required review process was performed prior to submitting the SSA-4513. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-031 NH Department of Education Disability Insurance/SSI Cluster (Assistance Listing #96.001) Federal Award Numbers: 2304NHDI00, 2404NHD100 Federal Award Year: 2023, 2024 U.S. Social Security Administration Compliance Requirement: Special Tests and Provisions – Qualified Providers Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-020 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria Each state agency is responsible for comprehensive oversight management of its process and for ensuring accuracy, integrity, and economy of its processes (20 CFR sections 404.519g and 416.919g, and POMS DI 396569.300). As part of these duties, DDSs must have and follow procedures for performing medical license verifications to ensure that only qualified providers perform DDSs tasks. By “qualified,” SSA means that the medical source must: 1. Be currently licensed in the state and have the training and experience to perform the type of examination or tests DDS requests; and 2. Not be barred from participating in Medicare or Medicaid programs or other federal or federally assisted programs (20 CFR sections 404.5159g and 416.919g). Prior to using the services of any medical provider, the DDS must check the System of Award Management (SAM) website. Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition During our testwork over the special test and provision related to qualified providers, we identified the following 9 of 9 exceptions: A. For 2 of the 9 new providers selected for testwork, there was no documentation maintained that evidenced inspection of the SAM.gov website to verify the suspension and debarment status for new providers and no information was provided to support the provider had a valid medical license. B. For 3 of the 9 new providers selected for testwork, there was no documentation maintained to support the start date of the individual to verify the inspection of the SAM.gov website was performed prior to use of the provider’s service. C. For the remaining 4 of the 9 new providers selected for testwork, the supporting documentation maintained that evidenced inspection of the SAM.gov website to verify the suspension and debarment status for the provider occurred subsequent to the individual’s start date. Cause The cause of the condition found is primarily due to insufficient policies and procedures to verify a provider’s had a valid medical license or the provider’s suspension and debarment status had been reviewed within SAM.gov prior to use of services by the provider as required by the federal regulations. In response to the prior year finding corrective actions were being implemented after June 30, 2024 and not all personnel were following the policies and procedures. There does not appear to be sufficient internal controls in place to ensure that reviews of provider’s licenses and suspension and debarment status are performed, completed and properly documented and sufficient documentation is maintained and reviewed. Effect The effect of the condition found is that documentation to support the qualifications of providers has not been appropriately maintained and providers could have been used that did not meet the criteria to be a qualified provider. Questioned Costs: Not determinable. Recommendation We recommend that written policies and procedures be developed and followed by all personnel to outline what the required procedures are related to reviewing professional licenses and suspension and debarment status for new provider. The policies should describe how the reviews will be performed, how the review will be documented, and the timing of when reviews will be performed relative to the provider’s start date. Internal controls should be implemented to ensure that an appropriate review over the review is conducted to ensure that the review is performed, completed and accurate documentation maintained. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-032 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4624-DR-NH, FEMA-4329-DR Federal Award Year: July 29-30, 2021, July 1-2, 2017 U.S. Department of Homeland Security Compliance Requirement: Special Tests and Provisions - Project Accounting Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-021 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria For large projects, the recipient is required to make an accounting to the Federal Emergency Management Agency (FEMA) of eligible costs. Similarly, the subrecipient must make an accounting to the recipient. In submitting the accounting, the entity is required to certify that reported costs were incurred in performance of eligible work, that the approved work was completed, that the project is in compliance with the provisions of the FEMA-State Agreement, all grant conditions were met, and that payments for that project were made in accordance with the applicable payment provisions. For improved and alternate projects, if the total cost of the projects does not equal or exceed the approved eligible costs, then the auditor should expect to see an adjustment to reduce eligible costs (44 CFR section 206.205). Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters. During testwork over the Special Test - Project Accounting, the engagement team sampled 2 large ongoing projects and identified the following: A. For 1 of 2 ongoing projects, the award letter did not include any language outlining the project certification requirements in which the subrecipient must attest to. B. For 2 of 2 ongoing projects, the Department could not provide evidence of the project accounting reporting made to FEMA in compliance with required certification. Specifically, the Department has a process whereby the Project Completion and Certification reports are to be completed and submitted to the Department by subrecipients within 90 days of the project obligation date. The Department then submits a certification report on the first of each month on the reports submitted during the previous month. However, the engagement team requested evidence of the Project Completion and Certification report being received from the subrecipient or it being sent to FEMA and it could not be provided. Cause This control is not operating at a sufficient precision level to ensure the accounting certification reports were sent to FEMA and maintained as evidence of control operation. Effect The effect of the condition found is that the Department did not comply with 44 CFR section 206.205 and 45 CFR section 75 303(a). Questioned Costs: None. Recommendation We recommend that the Department enhance policies and procedures which include internal controls to ensure project accounting completion and certification reports are sent to FEMA and maintained on file as evidence of compliance with the Project Accounting certification requirements. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-032 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4624-DR-NH, FEMA-4329-DR Federal Award Year: July 29-30, 2021, July 1-2, 2017 U.S. Department of Homeland Security Compliance Requirement: Special Tests and Provisions - Project Accounting Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-021 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria For large projects, the recipient is required to make an accounting to the Federal Emergency Management Agency (FEMA) of eligible costs. Similarly, the subrecipient must make an accounting to the recipient. In submitting the accounting, the entity is required to certify that reported costs were incurred in performance of eligible work, that the approved work was completed, that the project is in compliance with the provisions of the FEMA-State Agreement, all grant conditions were met, and that payments for that project were made in accordance with the applicable payment provisions. For improved and alternate projects, if the total cost of the projects does not equal or exceed the approved eligible costs, then the auditor should expect to see an adjustment to reduce eligible costs (44 CFR section 206.205). Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters. During testwork over the Special Test - Project Accounting, the engagement team sampled 2 large ongoing projects and identified the following: A. For 1 of 2 ongoing projects, the award letter did not include any language outlining the project certification requirements in which the subrecipient must attest to. B. For 2 of 2 ongoing projects, the Department could not provide evidence of the project accounting reporting made to FEMA in compliance with required certification. Specifically, the Department has a process whereby the Project Completion and Certification reports are to be completed and submitted to the Department by subrecipients within 90 days of the project obligation date. The Department then submits a certification report on the first of each month on the reports submitted during the previous month. However, the engagement team requested evidence of the Project Completion and Certification report being received from the subrecipient or it being sent to FEMA and it could not be provided. Cause This control is not operating at a sufficient precision level to ensure the accounting certification reports were sent to FEMA and maintained as evidence of control operation. Effect The effect of the condition found is that the Department did not comply with 44 CFR section 206.205 and 45 CFR section 75 303(a). Questioned Costs: None. Recommendation We recommend that the Department enhance policies and procedures which include internal controls to ensure project accounting completion and certification reports are sent to FEMA and maintained on file as evidence of compliance with the Project Accounting certification requirements. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-033 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH, FEMA-4740-DR, FEMA-4771-DR Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-25, 2022, November 1, 2017, July 1-2, 2017, January 20, 2020, September 14, 2023, April 19, 2024 U.S. Department of Homeland Security Compliance Requirement: Reporting Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition New Hampshire Department of Safety (the Department) during the year ended June 30, 2024, $109,539,714 was passed through to subrecipients that met the requirements for first tier subawards under the Transparency Act and as such FFATA reports were required to be filed for each of those subawards. During our testwork over FFATA reporting, we identified the following: A. For the period ending June 30, 2024, we have identified that 10 of the 53 reports submitted were not submitted timely. B. For 1 of 8 reports selected for testwork, the report was missing an obligated awards noted within the expenditure detail provided by the Department that should have been reported. C. For 1 of 8 reports selected for testwork, the Department was unable to provide us with a copy of one of the submitted FFATA reports selected for testing. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 8 1 10 Unknown Unknown Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $1,616,072 $919,070 Unknown Unknown Unknown Cause The cause of the condition found was primarily due to insufficient internal controls and resources within the Department to ensure that FFATA reports were filed and that the reports filed were complete and accurate. Effect The effect of the condition found is that the inaccurate and not timely FFATA reports can be filed. Questioned Costs: None. Recommendation We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-033 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH, FEMA-4740-DR, FEMA-4771-DR Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-25, 2022, November 1, 2017, July 1-2, 2017, January 20, 2020, September 14, 2023, April 19, 2024 U.S. Department of Homeland Security Compliance Requirement: Reporting Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition New Hampshire Department of Safety (the Department) during the year ended June 30, 2024, $109,539,714 was passed through to subrecipients that met the requirements for first tier subawards under the Transparency Act and as such FFATA reports were required to be filed for each of those subawards. During our testwork over FFATA reporting, we identified the following: A. For the period ending June 30, 2024, we have identified that 10 of the 53 reports submitted were not submitted timely. B. For 1 of 8 reports selected for testwork, the report was missing an obligated awards noted within the expenditure detail provided by the Department that should have been reported. C. For 1 of 8 reports selected for testwork, the Department was unable to provide us with a copy of one of the submitted FFATA reports selected for testing. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 8 1 10 Unknown Unknown Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $1,616,072 $919,070 Unknown Unknown Unknown Cause The cause of the condition found was primarily due to insufficient internal controls and resources within the Department to ensure that FFATA reports were filed and that the reports filed were complete and accurate. Effect The effect of the condition found is that the inaccurate and not timely FFATA reports can be filed. Questioned Costs: None. Recommendation We recommend that the Department implement written policies, procedures and internal controls to ensure the accuracy of the data reported within FSRS and to ensure that reports are filed timely. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-034 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020 U.S. Department of Homeland Security Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-023 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters. During the year ended June 30, 2024, $41,851,050 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following: A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 17 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated: • Identification of whether the award is R&D was not communicated for 13 of 17 subrecipients selected for testwork; and • Indirect cost rate for the federal award was not communicated for 13 of 17 subrecipients selected for testwork B. For 4 of 17 subrecipients selected for testwork, while a risk assessment was performed, the Department did not perform it within calendar year of when the award was obligated as outlined within their policies and procedures. C. For 1 of 17 subrecipients selected for testwork, the risk assessment form was not dated or initialed to indicted when the risk assessment procedures were performed. As such, it was unclear if the risk assessment was completed timely. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no uniform guidance report review policies and procedures in place. For the 17 subrecipients selected for testwork, 5 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted: • For 4 of 5 subrecipients, the subrecipient’s uniform guidance report was not reviewed due to updated risk assessments not being performed in the current year. • For 1 of 5 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report. Cause The cause of the condition found was primarily due to the Department not following their sub monitoring internal controls in accordance with written formal policies and procedures. Questioned Costs: None. Recommendation We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h). View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-034 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020 U.S. Department of Homeland Security Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-023 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters. During the year ended June 30, 2024, $41,851,050 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following: A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 17 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated: • Identification of whether the award is R&D was not communicated for 13 of 17 subrecipients selected for testwork; and • Indirect cost rate for the federal award was not communicated for 13 of 17 subrecipients selected for testwork B. For 4 of 17 subrecipients selected for testwork, while a risk assessment was performed, the Department did not perform it within calendar year of when the award was obligated as outlined within their policies and procedures. C. For 1 of 17 subrecipients selected for testwork, the risk assessment form was not dated or initialed to indicted when the risk assessment procedures were performed. As such, it was unclear if the risk assessment was completed timely. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no uniform guidance report review policies and procedures in place. For the 17 subrecipients selected for testwork, 5 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted: • For 4 of 5 subrecipients, the subrecipient’s uniform guidance report was not reviewed due to updated risk assessments not being performed in the current year. • For 1 of 5 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report. Cause The cause of the condition found was primarily due to the Department not following their sub monitoring internal controls in accordance with written formal policies and procedures. Questioned Costs: None. Recommendation We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h). View of Responsible Officials: Management concurs with the finding above.
2024-001 Unit of Service Documentation – Internal Controls over Activities Allowed and Reporting (Significant Deficiency) Federal Program Information: Funding Agency: U.S. Department of Health and Human Services FALN: 93.597 Federal Award Identification Numbers: 42700-401-0001077629, 42700-401-0000112068 Pass Through Entity: Georgia Department of Human Services Award Year: 2022-2023, 2023-2024 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Condition: The documentation related to one unit of service was not maintained; and therefore, no documentation of controls over the allowable activity requirement. In addition, the form was not included in the reporting package. Effect: The inconsistent implementation of the controls could result in unallowable activities or incorrect reporting related to the federal program. Cause: The controls over the maintenance of the supporting documentation were implemented inconsistently. Known and Likely Questioned Costs: None Perspective: This finding does not represent a systematic problem. Repeat Finding: No Recommendation: We recommend the Agency ensure the current controls be implemented consistently and consider implementing additional controls to ensure all program activities are allowable, and the reporting is accurately completed.
2024-001 Unit of Service Documentation – Internal Controls over Activities Allowed and Reporting (Significant Deficiency) Federal Program Information: Funding Agency: U.S. Department of Health and Human Services FALN: 93.597 Federal Award Identification Numbers: 42700-401-0001077629, 42700-401-0000112068 Pass Through Entity: Georgia Department of Human Services Award Year: 2022-2023, 2023-2024 Criteria: Under 2 CFR Section 200.303(a), non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Condition: The documentation related to one unit of service was not maintained; and therefore, no documentation of controls over the allowable activity requirement. In addition, the form was not included in the reporting package. Effect: The inconsistent implementation of the controls could result in unallowable activities or incorrect reporting related to the federal program. Cause: The controls over the maintenance of the supporting documentation were implemented inconsistently. Known and Likely Questioned Costs: None Perspective: This finding does not represent a systematic problem. Repeat Finding: No Recommendation: We recommend the Agency ensure the current controls be implemented consistently and consider implementing additional controls to ensure all program activities are allowable, and the reporting is accurately completed.
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
2024 – 001: Special Tests and Provisions: Gramm-Leach Bliley Act (GLBA) Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The Gramm-Leach Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The regulation states that the college must designate a qualified individual responsible for overseeing and implementing your information security program and enforcing your information security program (16 CFR 314.4(a). The entity shall have a Written Information Security Program (WISP) that outlines the design and implementation of the risk assessment procedures. (16 CFR 314.4(b). At a minimum, the institution’s written information security program must address the implementation of the minimum safeguards identified in 16 CFR 314.4(c)(1) through (8) including: Assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16 CFR 314.4(d). Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University has a Written information Security Program; however, the University did not meet the minimum requirements stated in the Gramm-Leach-Bliley Act. Questioned costs: None. Context: These GLBA requirements were applicable beginning on June 9, 2023, and there were multiple elements missing from their Written Information Security Program. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The University was not in Gramm-Leach-Bliley compliance standards. Repeat finding: Yes, 2023-002 Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Views of responsible officials: There is no disagreement with the audit finding.
2024 – 002: Eligibility: Loan Notifications Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: 34 CFR 668.165, states that an institution must notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to ED; and (3)the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. The notification requirement for loan funds applies only if the funds are disbursed by EFT payment or master check. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University did not properly notify students when loans were credited to the student's ledger account. Questioned costs: None. Context: During our Eligibility testing of 40 students, we identified that there was 1 student that received loan disbursements however, did not receive the required notification for the Fall 2023 term loan disbursement. Cause: Due to a clerical error, the Fall 2023 loan notifications was not sent to the student. Effect: Tailored award disbursement notifications inform the student or parent of the right to cancel all or a portion of that loan or loan disbursements and have the loan proceeds returned to the holder of that loan. The notifications also outline the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan. Repeat finding: Yes, 2023-003 Recommendation: We recommend the University evaluate its procedures around disbursements of loans and ensure that notifications of disbursements are sent and contain all the required elements outlined in the FSA handbook. Views of responsible officials: There is no disagreement with the audit finding.
2024-003: Reporting: Common Origination and Disbursement Federal Agency: U.S. Department of Education Federal Program Title: Student Financial Assistance ALN Number: 84.007, 84.033, 84.063, 84.268, 84.379 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023 through June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria or specific requirement: The Department of Education requires institutions to report the disbursement dates and amounts to the Common Origination and Disbursement (COD) system within 15 days of disbursing Pell (34 CFR 690.83(b)(2) and Direct Loan (34 CFR 685.309) funds to a student. Per 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. 2024-003: Reporting: Common Origination and Disbursement (Continued) Condition: During testing of Common Origination and Disbursement reporting, we noted 1 instance of noncompliance. Questioned costs: None. Context: During our testing of 40 COD disbursements we identified, 1 disbursement was not reported within the required 15 days. Cause: The University has not implemented precise review controls to ensure compliance with accurate and timely reporting or disbursement dates and amounts. Effect: Student interest accrues based on disbursement date reported to COD, thus interest calculation could be misstated due to the discrepancy in disbursement dates reported. Repeat finding: Yes, 2023-005 Recommendation: We recommend that the Student Financial Aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date and that disbursements date reported in COD matches the disbursement date to the student. Views of responsible officials: There is no disagreement with the audit finding.
Reference Number 2024-002 Federal Program: 21.027 – Coronavirus State and Local Fiscal Recovery Funds Federal Agency U.S. Department of Treasury Pass-Through Entity State of California Evaluation of Finding Significant Deficiency Compliance Area L – Reporting Condition During the allowable cost testing for the 21.027 Coronavirus State and Local Fiscal Recovery Funds program, it was found that an expenditure of $945,041 was recorded in the wrong period. The invoice indicated that the services were rendered as of June 30, 2023, but the expenditure was recorded as July 1, 2023 instead. This misstatement impacts the accuracy of financial reporting and grant compliance. Criteria According to 2 CFR 200.302(b)(3) and 2 CFR 200.303, entities receiving federal funds must maintain effective internal controls over financial reporting to ensure accurate and timely recognition of expenditures in the appropriate period. Cause of Condition The City's internal controls over financial reporting and expenditure recognition were not effectively designed or implemented, leading to recurring errors in the timing of recorded expenditures. Effect or Potential Effect of Condition Improper recording of expenditures can lead to misstatements in financial reports, noncompliance with federal grant requirements, and potential audit findings. Continued recurrence of this issue may impact the entity’s ability to demonstrate sound financial management practices. Recommendation We recommend that management continue to strengthen internal controls over expenditure recognition by implementing enhanced review procedures and periodic reconciliations to ensure expenditures are recorded in the appropriate period. Client Response The City agrees with the recommendation and has implemented new procedures and review processes to ensure expenditures for federal programs are recognized in the appropriate fiscal year's Schedule of Expenditures of Federal Awards (SEFA).
2024-003 Document Policies and Procedures over Federal Awards (Significant Deficiency) Cluster/Program: All Federal Programs Type of Finding: Compliance – Other Matters Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following: • Determination of allowable costs • Conflict of interest • Employee travel • Cash Management • Equipment and inventory • Procurement and Suspension and Debarment • Time and effort reporting; and • Subrecipient monitoring and management. Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance. Cause: Weaknesses in the formal documentation of internal controls. Effect: There are no formal policies related to federal grant activity noted above. Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement. Identification as Repeat Finding: This is not a repeat finding. Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-003 Document Policies and Procedures over Federal Awards (Significant Deficiency) Cluster/Program: All Federal Programs Type of Finding: Compliance – Other Matters Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following: • Determination of allowable costs • Conflict of interest • Employee travel • Cash Management • Equipment and inventory • Procurement and Suspension and Debarment • Time and effort reporting; and • Subrecipient monitoring and management. Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance. Cause: Weaknesses in the formal documentation of internal controls. Effect: There are no formal policies related to federal grant activity noted above. Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement. Identification as Repeat Finding: This is not a repeat finding. Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-003 Document Policies and Procedures over Federal Awards (Significant Deficiency) Cluster/Program: All Federal Programs Type of Finding: Compliance – Other Matters Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following: • Determination of allowable costs • Conflict of interest • Employee travel • Cash Management • Equipment and inventory • Procurement and Suspension and Debarment • Time and effort reporting; and • Subrecipient monitoring and management. Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance. Cause: Weaknesses in the formal documentation of internal controls. Effect: There are no formal policies related to federal grant activity noted above. Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement. Identification as Repeat Finding: This is not a repeat finding. Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-003 Document Policies and Procedures over Federal Awards (Significant Deficiency) Cluster/Program: All Federal Programs Type of Finding: Compliance – Other Matters Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following: • Determination of allowable costs • Conflict of interest • Employee travel • Cash Management • Equipment and inventory • Procurement and Suspension and Debarment • Time and effort reporting; and • Subrecipient monitoring and management. Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance. Cause: Weaknesses in the formal documentation of internal controls. Effect: There are no formal policies related to federal grant activity noted above. Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement. Identification as Repeat Finding: This is not a repeat finding. Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-003 Document Policies and Procedures over Federal Awards (Significant Deficiency) Cluster/Program: All Federal Programs Type of Finding: Compliance – Other Matters Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following: • Determination of allowable costs • Conflict of interest • Employee travel • Cash Management • Equipment and inventory • Procurement and Suspension and Debarment • Time and effort reporting; and • Subrecipient monitoring and management. Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance. Cause: Weaknesses in the formal documentation of internal controls. Effect: There are no formal policies related to federal grant activity noted above. Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement. Identification as Repeat Finding: This is not a repeat finding. Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-003 Document Policies and Procedures over Federal Awards (Significant Deficiency) Cluster/Program: All Federal Programs Type of Finding: Compliance – Other Matters Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following: • Determination of allowable costs • Conflict of interest • Employee travel • Cash Management • Equipment and inventory • Procurement and Suspension and Debarment • Time and effort reporting; and • Subrecipient monitoring and management. Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance. Cause: Weaknesses in the formal documentation of internal controls. Effect: There are no formal policies related to federal grant activity noted above. Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement. Identification as Repeat Finding: This is not a repeat finding. Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-003 Document Policies and Procedures over Federal Awards (Significant Deficiency) Cluster/Program: All Federal Programs Type of Finding: Compliance – Other Matters Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following: • Determination of allowable costs • Conflict of interest • Employee travel • Cash Management • Equipment and inventory • Procurement and Suspension and Debarment • Time and effort reporting; and • Subrecipient monitoring and management. Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance. Cause: Weaknesses in the formal documentation of internal controls. Effect: There are no formal policies related to federal grant activity noted above. Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement. Identification as Repeat Finding: This is not a repeat finding. Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
Information on the federal program: Subject: Special Education Cluster (IDEA) – Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.318(a) (Uniform Guidance) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.318(a) (Revised Uniform Guidance) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non- Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases – (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro purchase threshold, but below the simplified acquisition threshold. Micro purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Cause: Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective system of internal controls, as well as adequately document the procurement process for small purchases, prevented the determination of the School Corporation's compliance with the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not obtain price or rate quotes for one out of four vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. Documentation of vendor contract, bids or the School Corporation's process and rationale for the chosen vendor was not available for audit. Further, the School Corporation could not provide evidence that a suspension and debarment check had been performed on the vendor prior to entering into contract. Identification as a repeat finding, if applicable: Yes. See finding 2022-006 in the prior audit report. Recommendation: We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and the system of internal controls outlines how the School Corporation will comply with their procurement policy, requirements of the grant agreement and the Procurement and Suspension and Debarment compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Special Education Cluster (IDEA) – Procurement Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listing Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): H027A220084, H027A230084 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Significant Deficiency Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.318(a) (Uniform Guidance) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.318(a) (Revised Uniform Guidance) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.318(i) states: "The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price." 2 CFR 200.320(b) (Uniform Guidance) states: "Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources." 2 CFR 200.320 (Revised Uniform Guidance) states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non- Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases – (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro purchase threshold, but below the simplified acquisition threshold. Micro purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Cause: Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective system of internal controls, as well as adequately document the procurement process for small purchases, prevented the determination of the School Corporation's compliance with the procurement requirements of the Procurement and Suspension and Debarment compliance requirement. Questioned Costs: There were no questioned costs identified. Context: The School Corporation did not obtain price or rate quotes for one out of four vendors tested that were less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. Documentation of vendor contract, bids or the School Corporation's process and rationale for the chosen vendor was not available for audit. Further, the School Corporation could not provide evidence that a suspension and debarment check had been performed on the vendor prior to entering into contract. Identification as a repeat finding, if applicable: Yes. See finding 2022-006 in the prior audit report. Recommendation: We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and the system of internal controls outlines how the School Corporation will comply with their procurement policy, requirements of the grant agreement and the Procurement and Suspension and Debarment compliance requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Cause: Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect: The failure to establish an effective system of internal controls, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: We noted that for 11 payroll claims in a sample of 60, the School Corporation was not able to provide semi-annual certifications or support that the personnel were approved to be paid with Title I funds. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the eligibility compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During the testing of eligibility, we noted three out of 25 eligibility samples that were reported as free or reduced socioeconomic status to the Indiana Department of Education in the October 2022 data exchange count, but supporting documentation supported these students as a paid status. These three students should not have been reported as free or reduced socioeconomic status. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls to review the applications submitted for free or reduced socioeconomic status to ensure the students are classified correctly within the system. We also recommend that management have a secondary review of the information submitted as part of the data exchange count to ensure the information is accurate and agrees to the underlying detail. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card/High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card/High School Graduation Rate Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain documentation from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or is deceased.” Condition: An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The School Corporation must report graduation rate data for all public high schools within the corporation using the four-year adjusted cohort rate. To remove a student from the cohort, the School Corporation must confirm the reason for removal in writing. Additionally, required documentation for each removal type must be retained by the School Corporation. Cause: Management had not designed or implemented a system of internal controls that would have ensured compliance with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Effect: The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not established internal controls to ensure required documentation to support the reason for a student's removal from the high school graduation cohort for mobility reasons was prepared, reviewed, and retained. For three of the eight students tested, the School Corporation was unable to provide documentation to support the removal of the student from the graduation cohort. Identification as a repeat finding, if applicable: Yes. See finding 2022-008 in the prior audit report. Recommendation: We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Cause: Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect: The failure to establish an effective system of internal controls, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: We noted that for 11 payroll claims in a sample of 60, the School Corporation was not able to provide semi-annual certifications or support that the personnel were approved to be paid with Title I funds. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the eligibility compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During the testing of eligibility, we noted three out of 25 eligibility samples that were reported as free or reduced socioeconomic status to the Indiana Department of Education in the October 2022 data exchange count, but supporting documentation supported these students as a paid status. These three students should not have been reported as free or reduced socioeconomic status. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls to review the applications submitted for free or reduced socioeconomic status to ensure the students are classified correctly within the system. We also recommend that management have a secondary review of the information submitted as part of the data exchange count to ensure the information is accurate and agrees to the underlying detail. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card/High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card/High School Graduation Rate Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain documentation from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or is deceased.” Condition: An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The School Corporation must report graduation rate data for all public high schools within the corporation using the four-year adjusted cohort rate. To remove a student from the cohort, the School Corporation must confirm the reason for removal in writing. Additionally, required documentation for each removal type must be retained by the School Corporation. Cause: Management had not designed or implemented a system of internal controls that would have ensured compliance with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Effect: The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not established internal controls to ensure required documentation to support the reason for a student's removal from the high school graduation cohort for mobility reasons was prepared, reviewed, and retained. For three of the eight students tested, the School Corporation was unable to provide documentation to support the removal of the student from the graduation cohort. Identification as a repeat finding, if applicable: Yes. See finding 2022-008 in the prior audit report. Recommendation: We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Cause: Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect: The failure to establish an effective system of internal controls, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: We noted that for 11 payroll claims in a sample of 60, the School Corporation was not able to provide semi-annual certifications or support that the personnel were approved to be paid with Title I funds. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies – Eligibility Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Condition: An effective system of internal controls was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirement. Cause: Management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the eligibility compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: During the testing of eligibility, we noted three out of 25 eligibility samples that were reported as free or reduced socioeconomic status to the Indiana Department of Education in the October 2022 data exchange count, but supporting documentation supported these students as a paid status. These three students should not have been reported as free or reduced socioeconomic status. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls to review the applications submitted for free or reduced socioeconomic status to ensure the students are classified correctly within the system. We also recommend that management have a secondary review of the information submitted as part of the data exchange count to ensure the information is accurate and agrees to the underlying detail. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card/High School Graduation Rate Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010A Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card/High School Graduation Rate Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain documentation from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or is deceased.” Condition: An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. The School Corporation must report graduation rate data for all public high schools within the corporation using the four-year adjusted cohort rate. To remove a student from the cohort, the School Corporation must confirm the reason for removal in writing. Additionally, required documentation for each removal type must be retained by the School Corporation. Cause: Management had not designed or implemented a system of internal controls that would have ensured compliance with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Effect: The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were no questioned costs identified. Context: The School Corporation had not established internal controls to ensure required documentation to support the reason for a student's removal from the high school graduation cohort for mobility reasons was prepared, reviewed, and retained. For three of the eight students tested, the School Corporation was unable to provide documentation to support the removal of the student from the graduation cohort. Identification as a repeat finding, if applicable: Yes. See finding 2022-008 in the prior audit report. Recommendation: We recommended that the School Corporation's management establish a system of internal controls to ensure compliance and comply with the Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School Corporation's management implemented a review control over the annual data reports, however, it was not sufficient enough to detect and prevent errors in annual data reports submitted to the Indiana Department of Education. Effect: Annual data reports submitted during the audit period to the Indiana Department of Education contained material errors compared to underlying transaction detail for the period reported. Questioned Costs: There were no questioned costs identified. Context: The School Corporation was required to submit Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I amount reported on the Year 3 report ($266,367) did not agree to the underlying expenditure record ($96,019) for the period of July 1, 2021 through June 30, 2022. Additionally, the ESSER II and ESSER III amount reported on the Year 2 report ($1,433,207, and $643,771, respectively) did not agree to the underlying expenditure records ($1,400,698, and $630,465 respectively) for the period of July 1, 2021 through June 30, 2022. We also noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($4,291 and $1,522,378, respectively) did not agree to the underlying expenditure records ($4,590 and $1,774,722, respectively) for the period of July 1, 2022 through June 30, 2023. Additionally, the School Corporation was not able to provide any support for the 288 full-time equivalent (FTE) positions on September 30, 2022, reported on the Year 2 CrossAct report or the 338 full-time equivalent (FTE) positions on September 30, 2023, reported on the Year 3 CrossAct report. Crowe also noted that the School Corporation reported 0 full-time equivalent (FTE) positions paid by ESSER on September 2023, but there were ESSER positions reported in the ESSER applications. Identification as a repeat finding: No. Recommendation: We recommend management review internal controls over the review of annual data reports to ensure the data to be submitted agrees to underlying transaction detail or other supporting documentation prior to the submission of the annual data report. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School Corporation's management implemented a review control over the annual data reports, however, it was not sufficient enough to detect and prevent errors in annual data reports submitted to the Indiana Department of Education. Effect: Annual data reports submitted during the audit period to the Indiana Department of Education contained material errors compared to underlying transaction detail for the period reported. Questioned Costs: There were no questioned costs identified. Context: The School Corporation was required to submit Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I amount reported on the Year 3 report ($266,367) did not agree to the underlying expenditure record ($96,019) for the period of July 1, 2021 through June 30, 2022. Additionally, the ESSER II and ESSER III amount reported on the Year 2 report ($1,433,207, and $643,771, respectively) did not agree to the underlying expenditure records ($1,400,698, and $630,465 respectively) for the period of July 1, 2021 through June 30, 2022. We also noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($4,291 and $1,522,378, respectively) did not agree to the underlying expenditure records ($4,590 and $1,774,722, respectively) for the period of July 1, 2022 through June 30, 2023. Additionally, the School Corporation was not able to provide any support for the 288 full-time equivalent (FTE) positions on September 30, 2022, reported on the Year 2 CrossAct report or the 338 full-time equivalent (FTE) positions on September 30, 2023, reported on the Year 3 CrossAct report. Crowe also noted that the School Corporation reported 0 full-time equivalent (FTE) positions paid by ESSER on September 2023, but there were ESSER positions reported in the ESSER applications. Identification as a repeat finding: No. Recommendation: We recommend management review internal controls over the review of annual data reports to ensure the data to be submitted agrees to underlying transaction detail or other supporting documentation prior to the submission of the annual data report. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirements. Cause: The School Corporation’s management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect: The failure to establish an effective system of internal controls enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs: There were $1,944 of known questioned costs identified. Context: During testing of the Allowable Costs/Cost Principles compliance requirements, there were two vendor vouchers in a sample of 60, where the School Corporation was unable to locate any supporting documentation. These two selections totaled $1,530 charged to the grant. It was further noted that during our testing of payroll costs charged to the COVID-19 – Education Stabilization Fund, for 2 selections in a sample of 40, the School Corporation was unable to provide any support to validate the amount of payroll charged to the grant. These two selections totaled $414 charged to the COVID-19 – Education Stabilization Fund. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation’s management establish a system of internal controls to ensure that documentation will be maintained and that expenditures charged to the grant comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 Financial reporting . . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Cause: The School Corporation's management implemented a review control over the annual data reports, however, it was not sufficient enough to detect and prevent errors in annual data reports submitted to the Indiana Department of Education. Effect: Annual data reports submitted during the audit period to the Indiana Department of Education contained material errors compared to underlying transaction detail for the period reported. Questioned Costs: There were no questioned costs identified. Context: The School Corporation was required to submit Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I amount reported on the Year 3 report ($266,367) did not agree to the underlying expenditure record ($96,019) for the period of July 1, 2021 through June 30, 2022. Additionally, the ESSER II and ESSER III amount reported on the Year 2 report ($1,433,207, and $643,771, respectively) did not agree to the underlying expenditure records ($1,400,698, and $630,465 respectively) for the period of July 1, 2021 through June 30, 2022. We also noted that the ESSER II and ESSER III amounts reported on the Year 3 report ($4,291 and $1,522,378, respectively) did not agree to the underlying expenditure records ($4,590 and $1,774,722, respectively) for the period of July 1, 2022 through June 30, 2023. Additionally, the School Corporation was not able to provide any support for the 288 full-time equivalent (FTE) positions on September 30, 2022, reported on the Year 2 CrossAct report or the 338 full-time equivalent (FTE) positions on September 30, 2023, reported on the Year 3 CrossAct report. Crowe also noted that the School Corporation reported 0 full-time equivalent (FTE) positions paid by ESSER on September 2023, but there were ESSER positions reported in the ESSER applications. Identification as a repeat finding: No. Recommendation: We recommend management review internal controls over the review of annual data reports to ensure the data to be submitted agrees to underlying transaction detail or other supporting documentation prior to the submission of the annual data report. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.