Prior Year Finding: No Federal Agency: U.S Treasury Entity: City of Portsmouth (the City) Federal Program: Coronavirus State and Local Recovery Funds (CSLRF) Assistance Listing: 21.027 Federal Award Identification Number and Year: None Pass-Through Entity: N/A Award Number and Period: None, March 3, 2021 - December 31, 2024 Compliance Requirement: Allowable Activities Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance - Recipients may use CSLFRF payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 USC 802 and 42 USC 803 respectively). Control - Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City developed policies to determine the allowable uses of gift cards under the program+ including supporting documentation to be obtained prior to distribution of the gift cards. The City was not in compliance with its internal policy for obtaining required supporting documentation. Context: CLA noted that 2 out of 60 samples did not have support for the current year school contract and 2 out of 60 samples did not have support for proof of school or VA State ID. Questioned costs: $2,100 Cause: The City initially responded by offering immediate financial assistance to its residents. Consequently, this led to the bypassing of internal controls related to supporting documentation. Effect: The City may be unable to support the allowability of activity supported by the gift cards. Recommendation: We recommend that the City develop and distribute clear guidelines on the documentation requirements for the assistance program and provide training for staff on the importance of obtaining and maintaining proper documentation and adhering to internal controls. Views of responsible officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S Treasury Entity: City of Portsmouth (the City) Federal Program: Coronavirus State and Local Recovery Funds (CSLRF) Assistance Listing: 21.027 Federal Award Identification Number and Year: None Pass-Through Entity: N/A Award Number and Period: None, March 3, 2021 - December 31, 2024 Compliance Requirement: Allowable Activities Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance - Recipients may use CSLFRF payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 USC 802 and 42 USC 803 respectively). Control - Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The City developed policies to determine the allowable uses of gift cards under the program+ including supporting documentation to be obtained prior to distribution of the gift cards. The City was not in compliance with its internal policy for obtaining required supporting documentation. Context: CLA noted that 2 out of 60 samples did not have support for the current year school contract and 2 out of 60 samples did not have support for proof of school or VA State ID. Questioned costs: $2,100 Cause: The City initially responded by offering immediate financial assistance to its residents. Consequently, this led to the bypassing of internal controls related to supporting documentation. Effect: The City may be unable to support the allowability of activity supported by the gift cards. Recommendation: We recommend that the City develop and distribute clear guidelines on the documentation requirements for the assistance program and provide training for staff on the importance of obtaining and maintaining proper documentation and adhering to internal controls. Views of responsible officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: None, 2023 Pass-Through Entity: N/A Award Number and Period: B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligation incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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: The City of Portsmouth charged costs to the program that were incurred outside of the grant. award's period of performance. Context: One of Five expenditure transactions selected for testing, totaling $ 1,000, were incurred before the award start date of July 1, 2023. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program's review process did not detect the errors nor take timely corrective action. Effect: The City of Portsmouth was not compliant with the grant's period of performance which could result in the grantor's disallowance of the costs. Questioned costs: $1,000. Recommendation: We recommend that the City of Portsmouth review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Views of Responsible Officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: None, 2023 Pass-Through Entity: N/A Award Number and Period: B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligation incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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: The City of Portsmouth charged costs to the program that were incurred outside of the grant. award's period of performance. Context: One of Five expenditure transactions selected for testing, totaling $ 1,000, were incurred before the award start date of July 1, 2023. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program's review process did not detect the errors nor take timely corrective action. Effect: The City of Portsmouth was not compliant with the grant's period of performance which could result in the grantor's disallowance of the costs. Questioned costs: $1,000. Recommendation: We recommend that the City of Portsmouth review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Views of Responsible Officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: None, 2023 Pass-Through Entity: N/A Award Number and Period: B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligation incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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: The City of Portsmouth charged costs to the program that were incurred outside of the grant. award's period of performance. Context: One of Five expenditure transactions selected for testing, totaling $ 1,000, were incurred before the award start date of July 1, 2023. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program's review process did not detect the errors nor take timely corrective action. Effect: The City of Portsmouth was not compliant with the grant's period of performance which could result in the grantor's disallowance of the costs. Questioned costs: $1,000. Recommendation: We recommend that the City of Portsmouth review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Views of Responsible Officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: None, 2023 Pass-Through Entity: N/A Award Number and Period: B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligation incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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: The City of Portsmouth charged costs to the program that were incurred outside of the grant. award's period of performance. Context: One of Five expenditure transactions selected for testing, totaling $ 1,000, were incurred before the award start date of July 1, 2023. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program's review process did not detect the errors nor take timely corrective action. Effect: The City of Portsmouth was not compliant with the grant's period of performance which could result in the grantor's disallowance of the costs. Questioned costs: $1,000. Recommendation: We recommend that the City of Portsmouth review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Views of Responsible Officials: Management agrees with the finding.
Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development (HUD) Entity: City of Portsmouth (the City) Federal Program: Community Development Block Grants/Entitlement Grants Assistance Listing: 14.218 Federal Award Identification Number and Year: None, 2023 Pass-Through Entity: N/A Award Number and Period: B-23-MC-51-0018 (7/1/23-9/1/30) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligation incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply 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: The City of Portsmouth charged costs to the program that were incurred outside of the grant. award's period of performance. Context: One of Five expenditure transactions selected for testing, totaling $ 1,000, were incurred before the award start date of July 1, 2023. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program's review process did not detect the errors nor take timely corrective action. Effect: The City of Portsmouth was not compliant with the grant's period of performance which could result in the grantor's disallowance of the costs. Questioned costs: $1,000. Recommendation: We recommend that the City of Portsmouth review its procedures to ensure that expenditures charged to the program are incurred within the grant's period of performance. Views of Responsible Officials: Management agrees with the finding.
FINDING 2024-001 Subject: Economic Adjustment Assistance - Special Tests and Provisions - Wage Rate Requirements Federal Agency: US Department of Commerce Federal Program: Economic Adjustment Assistance Assistance Listings Number: 11.307 Federal Award Number and Year (or Other Identifying Number): 06-79-06301 URI: 116544 Pass-Through Entity: Direct Compliance Requirements: Special Tests and Provisions - Wage Rate Requirements Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College in order to ensure compliance with the following compliance requirement: Special Tests and Provisions - Wage Rate Requirement. The College could not provide documentation or evidence to verify a review that the weekly certified payrolls were submitted by the contractor. The lack of effective internal controls was an isolated issue to one contractor during the audit period. 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). . . ." Cause The College's management was unable to provide documentation to verify a review that certified payrolls were submitted by the contractor due to policies and procedures not being adequate to retain the documentation for the special tests and provisions - wage rate requirement. Effect Without the proper implementation of an effectively designed system of internal controls, the College cannot ensure the wage rate requirement is met. Noncompliance with the Special Tests and Provisions - Wage Rate Requirements compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 18 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal controls procedures for federal programs is retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002 Subject: TRIO Cluster - Eligibility Federal Agency: US Department of Education Federal Programs: Student Support Services, Talent Search, Upward Bound Assistance Listings Numbers: 84.042A, 84.044, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Eligibility Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the eligibility requirements. The following internal control deficiencies over determination of eligibility were noted: For TRIO Student Support Services, 2 of the 42 students tested from the Richmond Campus did not have evidence of internal controls over admission to the program. For TRIO Talent Search, 1 of the 40 students tested from the Northwest (Lake) Campus did not have evidence of internal controls over admission to the program. For TRIO Upward Bound, 4 of the 26 students tested from the Indianapolis Campus did not have evidence of internal controls over admission to the program. The lack of internal controls was isolated to three of the seven campuses that host a TRIO program. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 19 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." Cause The College's management was unable to provide documentation that a review of students being properly admitted into the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for TRIO Eligibility. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the Eligibility compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002 Subject: TRIO Cluster - Eligibility Federal Agency: US Department of Education Federal Programs: Student Support Services, Talent Search, Upward Bound Assistance Listings Numbers: 84.042A, 84.044, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Eligibility Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the eligibility requirements. The following internal control deficiencies over determination of eligibility were noted: For TRIO Student Support Services, 2 of the 42 students tested from the Richmond Campus did not have evidence of internal controls over admission to the program. For TRIO Talent Search, 1 of the 40 students tested from the Northwest (Lake) Campus did not have evidence of internal controls over admission to the program. For TRIO Upward Bound, 4 of the 26 students tested from the Indianapolis Campus did not have evidence of internal controls over admission to the program. The lack of internal controls was isolated to three of the seven campuses that host a TRIO program. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 19 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." Cause The College's management was unable to provide documentation that a review of students being properly admitted into the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for TRIO Eligibility. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the Eligibility compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002 Subject: TRIO Cluster - Eligibility Federal Agency: US Department of Education Federal Programs: Student Support Services, Talent Search, Upward Bound Assistance Listings Numbers: 84.042A, 84.044, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Eligibility Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the eligibility requirements. The following internal control deficiencies over determination of eligibility were noted: For TRIO Student Support Services, 2 of the 42 students tested from the Richmond Campus did not have evidence of internal controls over admission to the program. For TRIO Talent Search, 1 of the 40 students tested from the Northwest (Lake) Campus did not have evidence of internal controls over admission to the program. For TRIO Upward Bound, 4 of the 26 students tested from the Indianapolis Campus did not have evidence of internal controls over admission to the program. The lack of internal controls was isolated to three of the seven campuses that host a TRIO program. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: INDIANA STATE BOARD OF ACCOUNTS 19 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). . . ." Cause The College's management was unable to provide documentation that a review of students being properly admitted into the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for TRIO Eligibility. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the Eligibility compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: TRIO Cluster - Reporting Federal Agency: US Department of Education Federal Programs: Student Support Services, Upward Bound Assistance Listings Numbers: 84.042A, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 20 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the College to ensure compliance with requirements related to the Reporting compliance requirement. The following errors in the reporting of key line items (per Part 4 of the Compliance Supplement) on the fiscal year 2023 Annual Performance Report (APR) were noted: For Student Support Services at the Indianapolis campus, key line items were tested for 16 students. For 2 students, field 27 "College Grade Level (at the end of academic year)" was inaccurately reported. For Student Support Services at the Richmond campus, key line items were tested for 17 students. o For 1 student, field 18 "Date of First Project Service" was inaccurately reported. o For 2 students, field 19 "College Grade Level (entry into project)" was inaccurately reported. o For 3 students, field 23 "Enrollment Status (at the end of academic year)" was inaccurately reported. o For 2 students, field 24 "Academic Standing" was inaccurately reported. o For 1 student, field 27 "College Grade Level (at end of academic year)" was inaccurately reported. For Upward Bound at the Indianapolis campus, key line items were tested for 6 students. For 4 students, field 28 "Participation Level for reporting year" was inaccurately reported. For Upward Bound at the Muncie campus, key line items were tested for 6 students. o For 2 students, field 16 "Eligibility" was inaccurately reported. o For 1 student, field 17 "At Risk: Reading Language Arts or Math Proficiency Not Achieved (at time of initial selection)" was inaccurately reported. The lack of effective internal controls and noncompliance was a systemic issue at 4 of the 7 campuses that were reported on the TRIO Program during the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 21 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.329(c)(1) states in part: "The recipient or subrecipient must submit performance reports as required by the Federal award. . . ." 34 CFR 646.32(c) states in part: "Recordkeeping. A grantee must maintain participant records that show– (1) The basis for the grantee's determination that each participant is eligible to participate in the project under sec. 646.3; (2) The grantee's basis for determining the academic need for each participant; (3) The services that are provided to each participant; (4) The performance and progress of each participant by cohort for the duration of the participant's attendance at the grantee's institution . . ." Cause The College's management had not developed an effective system of internal controls that would have ensured compliance with the Reporting compliance requirement. The College had not developed policies and procedures to verify that TRIO Cluster reporting agreed with supporting records. Effect Without the proper implementation of an effectively designed system of internal control, the College cannot ensure reporting for TRIO Cluster is accurate and in agreement with supporting records. Noncompliance with the reporting requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure reporting for the TRIO Cluster programs agree with supporting records of the College. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: TRIO Cluster - Reporting Federal Agency: US Department of Education Federal Programs: Student Support Services, Upward Bound Assistance Listings Numbers: 84.042A, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 20 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context An effective internal control system was not in place at the College to ensure compliance with requirements related to the Reporting compliance requirement. The following errors in the reporting of key line items (per Part 4 of the Compliance Supplement) on the fiscal year 2023 Annual Performance Report (APR) were noted: For Student Support Services at the Indianapolis campus, key line items were tested for 16 students. For 2 students, field 27 "College Grade Level (at the end of academic year)" was inaccurately reported. For Student Support Services at the Richmond campus, key line items were tested for 17 students. o For 1 student, field 18 "Date of First Project Service" was inaccurately reported. o For 2 students, field 19 "College Grade Level (entry into project)" was inaccurately reported. o For 3 students, field 23 "Enrollment Status (at the end of academic year)" was inaccurately reported. o For 2 students, field 24 "Academic Standing" was inaccurately reported. o For 1 student, field 27 "College Grade Level (at end of academic year)" was inaccurately reported. For Upward Bound at the Indianapolis campus, key line items were tested for 6 students. For 4 students, field 28 "Participation Level for reporting year" was inaccurately reported. For Upward Bound at the Muncie campus, key line items were tested for 6 students. o For 2 students, field 16 "Eligibility" was inaccurately reported. o For 1 student, field 17 "At Risk: Reading Language Arts or Math Proficiency Not Achieved (at time of initial selection)" was inaccurately reported. The lack of effective internal controls and noncompliance was a systemic issue at 4 of the 7 campuses that were reported on the TRIO Program during the audit period. 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). . . ." INDIANA STATE BOARD OF ACCOUNTS 21 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.329(c)(1) states in part: "The recipient or subrecipient must submit performance reports as required by the Federal award. . . ." 34 CFR 646.32(c) states in part: "Recordkeeping. A grantee must maintain participant records that show– (1) The basis for the grantee's determination that each participant is eligible to participate in the project under sec. 646.3; (2) The grantee's basis for determining the academic need for each participant; (3) The services that are provided to each participant; (4) The performance and progress of each participant by cohort for the duration of the participant's attendance at the grantee's institution . . ." Cause The College's management had not developed an effective system of internal controls that would have ensured compliance with the Reporting compliance requirement. The College had not developed policies and procedures to verify that TRIO Cluster reporting agreed with supporting records. Effect Without the proper implementation of an effectively designed system of internal control, the College cannot ensure reporting for TRIO Cluster is accurate and in agreement with supporting records. Noncompliance with the reporting requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure reporting for the TRIO Cluster programs agree with supporting records of the College. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-004 Subject: TRIO Cluster - Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program Federal Agency: US Department of Education Federal Program: Upward Bound Program Assistance Listings Number: 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P047A221086, P047A221077 Compliance Requirement: Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program Audit Finding: Significant Deficiency Condition and Context An effective internal control system was not in place at the College to ensure compliance with the Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program compliance requirement. Applications for 15 participants in the Upward Bound Program were tested for evidence of review by 2 members of the TRIO staff. For 2 of the 15 applications tested, both from the Indianapolis campus, there was no documentation of a dual review at the Indianapolis campus. The lack of internal controls was isolated to one campus during the audit period. 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). . . ." Cause The College's management was unable to provide evidence of review of applications for the TRIO Program was performed. This was due to policies and procedures not being adequate to retain the documentation for the TRIO Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the Special Tests and Provisions - Core Curriculum Instruction in the Upward Bound Program compliance requirement could have resulted in the loss of federal funds to the College. INDIANA STATE BOARD OF ACCOUNTS 23 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal control procedures for federal programs are retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Information on the federal program: Subject: Child Nutrition Cluster – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For one of the two small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The sample item amount disbursed was $126,265 in FY23 and $59,748 in FY24 for food service equipment. The School Corporation was unable to provide support for the number of quotes obtained and a signed contract. The School Corporation was also not able to provide support that a suspension and debarment check was performed on the vendor. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that the School Corporation’s procurement policy is adhered to and quotes are obtained from an adequate number of qualified sources as required for small purchase method procurements. We also recommend the School Corporation’s management ensure vendors with annual aggregate disbursements over $25,000 charged to the food service fund have a suspension and debarment check performed.
Information on the federal program: Subject: Child Nutrition Cluster – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For one of the two small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The sample item amount disbursed was $126,265 in FY23 and $59,748 in FY24 for food service equipment. The School Corporation was unable to provide support for the number of quotes obtained and a signed contract. The School Corporation was also not able to provide support that a suspension and debarment check was performed on the vendor. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that the School Corporation’s procurement policy is adhered to and quotes are obtained from an adequate number of qualified sources as required for small purchase method procurements. We also recommend the School Corporation’s management ensure vendors with annual aggregate disbursements over $25,000 charged to the food service fund have a suspension and debarment check performed.
Information on the federal program: Subject: Child Nutrition Cluster – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For one of the two small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The sample item amount disbursed was $126,265 in FY23 and $59,748 in FY24 for food service equipment. The School Corporation was unable to provide support for the number of quotes obtained and a signed contract. The School Corporation was also not able to provide support that a suspension and debarment check was performed on the vendor. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that the School Corporation’s procurement policy is adhered to and quotes are obtained from an adequate number of qualified sources as required for small purchase method procurements. We also recommend the School Corporation’s management ensure vendors with annual aggregate disbursements over $25,000 charged to the food service fund have a suspension and debarment check performed.
Information on the federal program: Subject: Child Nutrition Cluster – Internal Controls Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Number: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2023, FY2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Finding: Material Weakness Criteria: 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this part." 2 CFR 200.320 states in part: "The non-Federal Entity must use one of the following methods of procurement. . . . (b) Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. . . ." Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the Child Nutrition Program and Procurement compliance requirements. Cause: The School Corporation's management had not developed a system of internal controls that would have ensured compliance with the Procurement and Suspension and Debarment compliance requirement. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. A lack of segregation of duties within an internal control system could have also allowed noncompliance with the compliance requirements and allowed the misuse and mismanagement of federal funds and assets by not having proper oversight, reviews, and approvals over the activities of the programs. Questioned Costs: There were no questioned costs identified. Context: For one of the two small purchase method procurements sampled for testing, we noted that the School Corporation, did not obtain quotes from an adequate number of qualified sources. The sample item amount disbursed was $126,265 in FY23 and $59,748 in FY24 for food service equipment. The School Corporation was unable to provide support for the number of quotes obtained and a signed contract. The School Corporation was also not able to provide support that a suspension and debarment check was performed on the vendor. Identification as a repeat finding, if applicable: No. Recommendation: We recommended that the School Corporation's management establish a system of internal controls related to ensure that the School Corporation’s procurement policy is adhered to and quotes are obtained from an adequate number of qualified sources as required for small purchase method procurements. We also recommend the School Corporation’s management ensure vendors with annual aggregate disbursements over $25,000 charged to the food service fund have a suspension and debarment check performed.
Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via National Student Loan Data System (NSLDS) within 15 days of receipt. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days to ensure attendance changes for students are reported within 60 days of the change. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half -time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Further, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition Found During our audit we found one (1) of forty (40) students selected for testing whose change in enrollment status was not timely transmitted to NSLDS. KPMG notes that for this exception, the College reported the status change 144 days after they became aware of the status change. In addition, we identified two (2) of forty (40) students selected whose enrollment status was incorrectly reported. In all instances, the College reported the student as withdrawn, however, the student had graduated from the College. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government's payment of interest subsidies. Questioned Costs No questioned costs identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This was not a finding in the prior year. Recommendation We recommend that the College review its processes to ensure that all enrollment changes are reported as intended within the required 60-day time frame. The College should work with NSC as needed to ensure proper protocols of transmission to NSLDS occur. Additionally, a review of the submitted enrollment changes to the NSLDS should be performed to ensure current student status is properly reflected. View of College Officials The identified conditions relate to students who graduated off-cycle. To mitigate the risk of future status change reporting issues, the College is implementing an additional monthly review process that will generate a report of students who have separated from the College. This report will be reconciled with student status changes transmitted by the National Student Clearinghouse (NSC) to the National Student Loan Database System (NSLDS), and any necessary corrections will be made immediately. These corrective actions are being implemented in Spring 2025.
Criteria According to 34 CFR Section 685.309, under the Federal Direct loan program, institutions must complete and return the Enrollment Reporting roster file via National Student Loan Data System (NSLDS) within 15 days of receipt. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days to ensure attendance changes for students are reported within 60 days of the change. An institution must notify the Secretary of Education if it discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half -time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. Further, in accordance with 2 CFR 200.303(a), non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition Found During our audit we found one (1) of forty (40) students selected for testing whose change in enrollment status was not timely transmitted to NSLDS. KPMG notes that for this exception, the College reported the status change 144 days after they became aware of the status change. In addition, we identified two (2) of forty (40) students selected whose enrollment status was incorrectly reported. In all instances, the College reported the student as withdrawn, however, the student had graduated from the College. Possible Asserted Effect Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, deferments, grace periods, and repayment schedules, as well as the federal government's payment of interest subsidies. Questioned Costs No questioned costs identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding This was not a finding in the prior year. Recommendation We recommend that the College review its processes to ensure that all enrollment changes are reported as intended within the required 60-day time frame. The College should work with NSC as needed to ensure proper protocols of transmission to NSLDS occur. Additionally, a review of the submitted enrollment changes to the NSLDS should be performed to ensure current student status is properly reflected. View of College Officials The identified conditions relate to students who graduated off-cycle. To mitigate the risk of future status change reporting issues, the College is implementing an additional monthly review process that will generate a report of students who have separated from the College. This report will be reconciled with student status changes transmitted by the National Student Clearinghouse (NSC) to the National Student Loan Database System (NSLDS), and any necessary corrections will be made immediately. These corrective actions are being implemented in Spring 2025.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.
Federal Agency: U.S. Department of Treasury Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A220035 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 231072 Award Period: 10/1/2022 - 9/30/2024 Type of Finding: Material Weakness in Control over Compliance, Material Noncompliance (Modified Opinion) Criteria or Specific Requirement: Compliance: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were not suspended or debarred. Questioned Costs: None noted. Context: The School Board could not provide documentation for two out of four vendors regarding ensuring the vendor was not suspended or debarred at the time of contract. Cause: The Board's procedures and internal controls over suspension and debarment were not sufficient to ensure that all vendors' suspension and debarment status was verified timely. Effect: Failure to verify the suspension and debarment status of vendors may result in the procurement of goods or services from vendors that are suspended or debarred and result in unallowable expenditures charged to the program. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023-001. Recommendation: We recommend that the Board review its policies and procedures to ensure they include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to entering into covered transactions. Views of responsible officials: Management acknowledges the finding. Current procedures mandate suspension and debarment verification prior to entering into contracts or agreements with vendors. However, due to the timing of the policy implementation, there were vendor contracts executed and payments processed after the prior year's finding but before corrective action could be implemented.