FINDING 2024-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder and excel files. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I Annual Data Report, two ESSER II Annual Data Reports, and two ESSER III Annual Data Reports, for a total of five reports. There was no documented evidence provided for audit that supported an oversight or review process was in place to prevent, and detect and correct, errors on the five reports. Of the five reports tested, two contained the following errors: ESSER II, Year 3 Annual Data Report Key line items "Addressing Physical Health and Safety Uses: Personnel Services - Benefits" and "Addressing Physical Health and Safety Uses: Supplies" were understated by $19,243 and $664,540, respectively. INDIANA STATE BOARD OF ACCOUNTS 26 WEST NOBLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Expenses for the report, which covered the period of July 1, 2022 to June 30, 2023, totaled $1,002,932; however, the ledger had total expenses for the award, for that period, of $817,390. ESSER III, Year 3 Annual Data Report Key line items "Mandatory Subgrant Funds - Exclusive of Learning Loss Set-Aside - Mental Health Supports for Students and Staff Uses: Personnel Services - Salaries" and "Mandatory Subgrant Funds - Learning Loss Set-Aside - Mental Health Supports for Students and Staff Uses: Personnel Services - Benefits" were overstated by $46,500 and $3,500, respectively. Expenses for the report, which covered the period of July 1, 2022 to June 30, 2023, totaled $2,072,695; however, the ledger had total expenses for the award, for that period, of $2,074,793. The lack in internal controls was systemic throughout the audit period. The noncompliance was isolated to fiscal year 2023-2024. 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 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." INDIANA STATE BOARD OF ACCOUNTS 27 WEST NOBLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Due to staffing changes, the documentation for an oversight and review process was not identified and presented for audit. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, errors on reports remained undetected and uncorrected. Noncompliance with the grant agreement and the compliance requirement could result in the loss of federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder and excel files. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I Annual Data Report, two ESSER II Annual Data Reports, and two ESSER III Annual Data Reports, for a total of five reports. There was no documented evidence provided for audit that supported an oversight or review process was in place to prevent, and detect and correct, errors on the five reports. Of the five reports tested, two contained the following errors: ESSER II, Year 3 Annual Data Report Key line items "Addressing Physical Health and Safety Uses: Personnel Services - Benefits" and "Addressing Physical Health and Safety Uses: Supplies" were understated by $19,243 and $664,540, respectively. INDIANA STATE BOARD OF ACCOUNTS 26 WEST NOBLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Expenses for the report, which covered the period of July 1, 2022 to June 30, 2023, totaled $1,002,932; however, the ledger had total expenses for the award, for that period, of $817,390. ESSER III, Year 3 Annual Data Report Key line items "Mandatory Subgrant Funds - Exclusive of Learning Loss Set-Aside - Mental Health Supports for Students and Staff Uses: Personnel Services - Salaries" and "Mandatory Subgrant Funds - Learning Loss Set-Aside - Mental Health Supports for Students and Staff Uses: Personnel Services - Benefits" were overstated by $46,500 and $3,500, respectively. Expenses for the report, which covered the period of July 1, 2022 to June 30, 2023, totaled $2,072,695; however, the ledger had total expenses for the award, for that period, of $2,074,793. The lack in internal controls was systemic throughout the audit period. The noncompliance was isolated to fiscal year 2023-2024. 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 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." INDIANA STATE BOARD OF ACCOUNTS 27 WEST NOBLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Due to staffing changes, the documentation for an oversight and review process was not identified and presented for audit. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, errors on reports remained undetected and uncorrected. Noncompliance with the grant agreement and the compliance requirement could result in the loss of federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder and excel files. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I Annual Data Report, two ESSER II Annual Data Reports, and two ESSER III Annual Data Reports, for a total of five reports. There was no documented evidence provided for audit that supported an oversight or review process was in place to prevent, and detect and correct, errors on the five reports. Of the five reports tested, two contained the following errors: ESSER II, Year 3 Annual Data Report Key line items "Addressing Physical Health and Safety Uses: Personnel Services - Benefits" and "Addressing Physical Health and Safety Uses: Supplies" were understated by $19,243 and $664,540, respectively. INDIANA STATE BOARD OF ACCOUNTS 26 WEST NOBLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Expenses for the report, which covered the period of July 1, 2022 to June 30, 2023, totaled $1,002,932; however, the ledger had total expenses for the award, for that period, of $817,390. ESSER III, Year 3 Annual Data Report Key line items "Mandatory Subgrant Funds - Exclusive of Learning Loss Set-Aside - Mental Health Supports for Students and Staff Uses: Personnel Services - Salaries" and "Mandatory Subgrant Funds - Learning Loss Set-Aside - Mental Health Supports for Students and Staff Uses: Personnel Services - Benefits" were overstated by $46,500 and $3,500, respectively. Expenses for the report, which covered the period of July 1, 2022 to June 30, 2023, totaled $2,072,695; however, the ledger had total expenses for the award, for that period, of $2,074,793. The lack in internal controls was systemic throughout the audit period. The noncompliance was isolated to fiscal year 2023-2024. 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 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." INDIANA STATE BOARD OF ACCOUNTS 27 WEST NOBLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Due to staffing changes, the documentation for an oversight and review process was not identified and presented for audit. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, errors on reports remained undetected and uncorrected. Noncompliance with the grant agreement and the compliance requirement could result in the loss of federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-006 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder and excel files. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation submitted one ESSER I Annual Data Report, two ESSER II Annual Data Reports, and two ESSER III Annual Data Reports, for a total of five reports. There was no documented evidence provided for audit that supported an oversight or review process was in place to prevent, and detect and correct, errors on the five reports. Of the five reports tested, two contained the following errors: ESSER II, Year 3 Annual Data Report Key line items "Addressing Physical Health and Safety Uses: Personnel Services - Benefits" and "Addressing Physical Health and Safety Uses: Supplies" were understated by $19,243 and $664,540, respectively. INDIANA STATE BOARD OF ACCOUNTS 26 WEST NOBLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Expenses for the report, which covered the period of July 1, 2022 to June 30, 2023, totaled $1,002,932; however, the ledger had total expenses for the award, for that period, of $817,390. ESSER III, Year 3 Annual Data Report Key line items "Mandatory Subgrant Funds - Exclusive of Learning Loss Set-Aside - Mental Health Supports for Students and Staff Uses: Personnel Services - Salaries" and "Mandatory Subgrant Funds - Learning Loss Set-Aside - Mental Health Supports for Students and Staff Uses: Personnel Services - Benefits" were overstated by $46,500 and $3,500, respectively. Expenses for the report, which covered the period of July 1, 2022 to June 30, 2023, totaled $2,072,695; however, the ledger had total expenses for the award, for that period, of $2,074,793. The lack in internal controls was systemic throughout the audit period. The noncompliance was isolated to fiscal year 2023-2024. 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 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following: . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." 34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance with program requirements." INDIANA STATE BOARD OF ACCOUNTS 27 WEST NOBLE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Due to staffing changes, the documentation for an oversight and review process was not identified and presented for audit. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the School Corporation's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, errors on reports remained undetected and uncorrected. Noncompliance with the grant agreement and the compliance requirement could result in the loss of federal funds to the School Corporation. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish effective internal controls to ensure compliance and comply with the grant agreement and the Reporting compliance requirement. 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: Special Education Cluster (IDEA) - Matching, Level of Effort, Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): H027A200084, H027A210084, H027A220084, H027A230084, H027X210084, H173A200104, H173A210104, H173A220104, H173A230104, H173X210104 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context Earmarking A portion of the School Corporation's Special Education allocation was required to be set aside for the mandatory Coordinated Early Intervening Services (CEIS) reservation as well as the nonproportionate share reservation. The required amount to be set aside was indicated in the Special Education grant application. The School Corporation is responsible for monitoring each required set aside throughout the life of the grant to ensure the obligation is met. The School Corporation did not separate the earmarking for the mandatory CEIS reservation from the nonpublic proportionate share. The same expenditures in the amount of $2,647 were earmarked in both earmarking categories. In addition, the School Corporation did not have actual expenditure amounts to account for the fiscal year 2021 preschool grant nonproportionate share amount. The expenditures used were a percentage of total expenditures. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. INDIANA STATE BOARD OF ACCOUNTS 20 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Level of Effort - Individual Transactions (Vendor) The Form 9 (financial) data was submitted by the School Corporation to the Indiana Department of Education (IDOE) semiannually. The data reported included the School Corporation's expenditures recorded during that period. The IDOE calculated Maintenance of Effort based on the expenditure information submitted on the Form 9 for that fiscal year. To verify amounts used by the IDOE in their computation were derived from the ledger of the School Corporation, costs were reviewed to ensure they were recorded properly as to account and object code and reported correctly on the Form 9. In fiscal year 2021, Form 9 testing, 5 out of 25 expenditure codes were not properly supported by the School Corporation's records. In 2022, Form 9 testing, 6 out of 25 expenditures were not properly supported by the School Corporation's records. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. The lack of internal controls and noncompliance were systemic issues throughout 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). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 21 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The School Corporation did not have policies and procedures in place to properly maintain documentation of expenses allocated to earmarking requirements and to verify that expenditures were reported accurately on the Form 9. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation of the earmarking requirement could not be determined, and the reported Form 9 expenditures were not properly supported by financial records. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure Form 9 reporting is accurate and earmarking requirements are met. 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: Special Education Cluster (IDEA) - Matching, Level of Effort, Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): H027A200084, H027A210084, H027A220084, H027A230084, H027X210084, H173A200104, H173A210104, H173A220104, H173A230104, H173X210104 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context Earmarking A portion of the School Corporation's Special Education allocation was required to be set aside for the mandatory Coordinated Early Intervening Services (CEIS) reservation as well as the nonproportionate share reservation. The required amount to be set aside was indicated in the Special Education grant application. The School Corporation is responsible for monitoring each required set aside throughout the life of the grant to ensure the obligation is met. The School Corporation did not separate the earmarking for the mandatory CEIS reservation from the nonpublic proportionate share. The same expenditures in the amount of $2,647 were earmarked in both earmarking categories. In addition, the School Corporation did not have actual expenditure amounts to account for the fiscal year 2021 preschool grant nonproportionate share amount. The expenditures used were a percentage of total expenditures. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. INDIANA STATE BOARD OF ACCOUNTS 20 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Level of Effort - Individual Transactions (Vendor) The Form 9 (financial) data was submitted by the School Corporation to the Indiana Department of Education (IDOE) semiannually. The data reported included the School Corporation's expenditures recorded during that period. The IDOE calculated Maintenance of Effort based on the expenditure information submitted on the Form 9 for that fiscal year. To verify amounts used by the IDOE in their computation were derived from the ledger of the School Corporation, costs were reviewed to ensure they were recorded properly as to account and object code and reported correctly on the Form 9. In fiscal year 2021, Form 9 testing, 5 out of 25 expenditure codes were not properly supported by the School Corporation's records. In 2022, Form 9 testing, 6 out of 25 expenditures were not properly supported by the School Corporation's records. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. The lack of internal controls and noncompliance were systemic issues throughout 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). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 21 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The School Corporation did not have policies and procedures in place to properly maintain documentation of expenses allocated to earmarking requirements and to verify that expenditures were reported accurately on the Form 9. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation of the earmarking requirement could not be determined, and the reported Form 9 expenditures were not properly supported by financial records. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure Form 9 reporting is accurate and earmarking requirements are met. 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: Special Education Cluster (IDEA) - Matching, Level of Effort, Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): H027A200084, H027A210084, H027A220084, H027A230084, H027X210084, H173A200104, H173A210104, H173A220104, H173A230104, H173X210104 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context Earmarking A portion of the School Corporation's Special Education allocation was required to be set aside for the mandatory Coordinated Early Intervening Services (CEIS) reservation as well as the nonproportionate share reservation. The required amount to be set aside was indicated in the Special Education grant application. The School Corporation is responsible for monitoring each required set aside throughout the life of the grant to ensure the obligation is met. The School Corporation did not separate the earmarking for the mandatory CEIS reservation from the nonpublic proportionate share. The same expenditures in the amount of $2,647 were earmarked in both earmarking categories. In addition, the School Corporation did not have actual expenditure amounts to account for the fiscal year 2021 preschool grant nonproportionate share amount. The expenditures used were a percentage of total expenditures. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. INDIANA STATE BOARD OF ACCOUNTS 20 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Level of Effort - Individual Transactions (Vendor) The Form 9 (financial) data was submitted by the School Corporation to the Indiana Department of Education (IDOE) semiannually. The data reported included the School Corporation's expenditures recorded during that period. The IDOE calculated Maintenance of Effort based on the expenditure information submitted on the Form 9 for that fiscal year. To verify amounts used by the IDOE in their computation were derived from the ledger of the School Corporation, costs were reviewed to ensure they were recorded properly as to account and object code and reported correctly on the Form 9. In fiscal year 2021, Form 9 testing, 5 out of 25 expenditure codes were not properly supported by the School Corporation's records. In 2022, Form 9 testing, 6 out of 25 expenditures were not properly supported by the School Corporation's records. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. The lack of internal controls and noncompliance were systemic issues throughout 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). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 21 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The School Corporation did not have policies and procedures in place to properly maintain documentation of expenses allocated to earmarking requirements and to verify that expenditures were reported accurately on the Form 9. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation of the earmarking requirement could not be determined, and the reported Form 9 expenditures were not properly supported by financial records. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure Form 9 reporting is accurate and earmarking requirements are met. 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: Special Education Cluster (IDEA) - Matching, Level of Effort, Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): H027A200084, H027A210084, H027A220084, H027A230084, H027X210084, H173A200104, H173A210104, H173A220104, H173A230104, H173X210104 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context Earmarking A portion of the School Corporation's Special Education allocation was required to be set aside for the mandatory Coordinated Early Intervening Services (CEIS) reservation as well as the nonproportionate share reservation. The required amount to be set aside was indicated in the Special Education grant application. The School Corporation is responsible for monitoring each required set aside throughout the life of the grant to ensure the obligation is met. The School Corporation did not separate the earmarking for the mandatory CEIS reservation from the nonpublic proportionate share. The same expenditures in the amount of $2,647 were earmarked in both earmarking categories. In addition, the School Corporation did not have actual expenditure amounts to account for the fiscal year 2021 preschool grant nonproportionate share amount. The expenditures used were a percentage of total expenditures. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. INDIANA STATE BOARD OF ACCOUNTS 20 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Level of Effort - Individual Transactions (Vendor) The Form 9 (financial) data was submitted by the School Corporation to the Indiana Department of Education (IDOE) semiannually. The data reported included the School Corporation's expenditures recorded during that period. The IDOE calculated Maintenance of Effort based on the expenditure information submitted on the Form 9 for that fiscal year. To verify amounts used by the IDOE in their computation were derived from the ledger of the School Corporation, costs were reviewed to ensure they were recorded properly as to account and object code and reported correctly on the Form 9. In fiscal year 2021, Form 9 testing, 5 out of 25 expenditure codes were not properly supported by the School Corporation's records. In 2022, Form 9 testing, 6 out of 25 expenditures were not properly supported by the School Corporation's records. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. The lack of internal controls and noncompliance were systemic issues throughout 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). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 21 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The School Corporation did not have policies and procedures in place to properly maintain documentation of expenses allocated to earmarking requirements and to verify that expenditures were reported accurately on the Form 9. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation of the earmarking requirement could not be determined, and the reported Form 9 expenditures were not properly supported by financial records. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure Form 9 reporting is accurate and earmarking requirements are met. 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: Special Education Cluster (IDEA) - Matching, Level of Effort, Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): H027A200084, H027A210084, H027A220084, H027A230084, H027X210084, H173A200104, H173A210104, H173A220104, H173A230104, H173X210104 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context Earmarking A portion of the School Corporation's Special Education allocation was required to be set aside for the mandatory Coordinated Early Intervening Services (CEIS) reservation as well as the nonproportionate share reservation. The required amount to be set aside was indicated in the Special Education grant application. The School Corporation is responsible for monitoring each required set aside throughout the life of the grant to ensure the obligation is met. The School Corporation did not separate the earmarking for the mandatory CEIS reservation from the nonpublic proportionate share. The same expenditures in the amount of $2,647 were earmarked in both earmarking categories. In addition, the School Corporation did not have actual expenditure amounts to account for the fiscal year 2021 preschool grant nonproportionate share amount. The expenditures used were a percentage of total expenditures. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. INDIANA STATE BOARD OF ACCOUNTS 20 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Level of Effort - Individual Transactions (Vendor) The Form 9 (financial) data was submitted by the School Corporation to the Indiana Department of Education (IDOE) semiannually. The data reported included the School Corporation's expenditures recorded during that period. The IDOE calculated Maintenance of Effort based on the expenditure information submitted on the Form 9 for that fiscal year. To verify amounts used by the IDOE in their computation were derived from the ledger of the School Corporation, costs were reviewed to ensure they were recorded properly as to account and object code and reported correctly on the Form 9. In fiscal year 2021, Form 9 testing, 5 out of 25 expenditure codes were not properly supported by the School Corporation's records. In 2022, Form 9 testing, 6 out of 25 expenditures were not properly supported by the School Corporation's records. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. The lack of internal controls and noncompliance were systemic issues throughout 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). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 21 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The School Corporation did not have policies and procedures in place to properly maintain documentation of expenses allocated to earmarking requirements and to verify that expenditures were reported accurately on the Form 9. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation of the earmarking requirement could not be determined, and the reported Form 9 expenditures were not properly supported by financial records. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure Form 9 reporting is accurate and earmarking requirements are met. 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: Special Education Cluster (IDEA) - Matching, Level of Effort, Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): H027A200084, H027A210084, H027A220084, H027A230084, H027X210084, H173A200104, H173A210104, H173A220104, H173A230104, H173X210104 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context Earmarking A portion of the School Corporation's Special Education allocation was required to be set aside for the mandatory Coordinated Early Intervening Services (CEIS) reservation as well as the nonproportionate share reservation. The required amount to be set aside was indicated in the Special Education grant application. The School Corporation is responsible for monitoring each required set aside throughout the life of the grant to ensure the obligation is met. The School Corporation did not separate the earmarking for the mandatory CEIS reservation from the nonpublic proportionate share. The same expenditures in the amount of $2,647 were earmarked in both earmarking categories. In addition, the School Corporation did not have actual expenditure amounts to account for the fiscal year 2021 preschool grant nonproportionate share amount. The expenditures used were a percentage of total expenditures. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. INDIANA STATE BOARD OF ACCOUNTS 20 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Level of Effort - Individual Transactions (Vendor) The Form 9 (financial) data was submitted by the School Corporation to the Indiana Department of Education (IDOE) semiannually. The data reported included the School Corporation's expenditures recorded during that period. The IDOE calculated Maintenance of Effort based on the expenditure information submitted on the Form 9 for that fiscal year. To verify amounts used by the IDOE in their computation were derived from the ledger of the School Corporation, costs were reviewed to ensure they were recorded properly as to account and object code and reported correctly on the Form 9. In fiscal year 2021, Form 9 testing, 5 out of 25 expenditure codes were not properly supported by the School Corporation's records. In 2022, Form 9 testing, 6 out of 25 expenditures were not properly supported by the School Corporation's records. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. The lack of internal controls and noncompliance were systemic issues throughout 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). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 21 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The School Corporation did not have policies and procedures in place to properly maintain documentation of expenses allocated to earmarking requirements and to verify that expenditures were reported accurately on the Form 9. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation of the earmarking requirement could not be determined, and the reported Form 9 expenditures were not properly supported by financial records. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure Form 9 reporting is accurate and earmarking requirements are met. 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: Special Education Cluster (IDEA) - Matching, Level of Effort, Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, Special Education Preschool Grants, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): H027A200084, H027A210084, H027A220084, H027A230084, H027X210084, H173A200104, H173A210104, H173A220104, H173A230104, H173X210104 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Other Matters Condition and Context Earmarking A portion of the School Corporation's Special Education allocation was required to be set aside for the mandatory Coordinated Early Intervening Services (CEIS) reservation as well as the nonproportionate share reservation. The required amount to be set aside was indicated in the Special Education grant application. The School Corporation is responsible for monitoring each required set aside throughout the life of the grant to ensure the obligation is met. The School Corporation did not separate the earmarking for the mandatory CEIS reservation from the nonpublic proportionate share. The same expenditures in the amount of $2,647 were earmarked in both earmarking categories. In addition, the School Corporation did not have actual expenditure amounts to account for the fiscal year 2021 preschool grant nonproportionate share amount. The expenditures used were a percentage of total expenditures. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. INDIANA STATE BOARD OF ACCOUNTS 20 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Level of Effort - Individual Transactions (Vendor) The Form 9 (financial) data was submitted by the School Corporation to the Indiana Department of Education (IDOE) semiannually. The data reported included the School Corporation's expenditures recorded during that period. The IDOE calculated Maintenance of Effort based on the expenditure information submitted on the Form 9 for that fiscal year. To verify amounts used by the IDOE in their computation were derived from the ledger of the School Corporation, costs were reviewed to ensure they were recorded properly as to account and object code and reported correctly on the Form 9. In fiscal year 2021, Form 9 testing, 5 out of 25 expenditure codes were not properly supported by the School Corporation's records. In 2022, Form 9 testing, 6 out of 25 expenditures were not properly supported by the School Corporation's records. The School Corporation did have internal controls in place; however, they were not effective in preventing these errors. The lack of internal controls and noncompliance were systemic issues throughout 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). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 21 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The School Corporation did not have policies and procedures in place to properly maintain documentation of expenses allocated to earmarking requirements and to verify that expenditures were reported accurately on the Form 9. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation of the earmarking requirement could not be determined, and the reported Form 9 expenditures were not properly supported by financial records. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure Form 9 reporting is accurate and earmarking requirements are met. 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: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Allowable Costs/Cost Principles. Federal funds may only be used to pay staff for work that has occurred supporting the objective of the federal program. As such, proper time and effort documentation is to be maintained by the School Corporation. The purpose of time and effort recording is to provide documentation of the time spent working on specific federal programs to ensure charges are accurate for each program. Reimbursements were prepared by one employee and reviewed by another employee prior to submission; however, this internal control was not effective in preventing noncompliance with allowable costs/cost principles. INDIANA STATE BOARD OF ACCOUNTS 22 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Out of 14 employees tested, 1 employee was paid 50 percent of their salary from the COVID-19 - Education Stabilization Funds (ESF) grant and 50 percent of their salary from another funding source. The School Corporation was not able to provide documentation that supported the hours paid from the ESF grant. The ineffective internal controls were systemic throughout the audit period. The noncompliance was isolated to payrolls for September and October of 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 23 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) While across the board stipends are not permitted, LEAs may pay staff for COVID-related work that has been documented. Most, if not all, staff likely had extra responsibilities as well as time and effort to respond to the pandemic. ESSER funds can be used to pay staff for that work and LEAs are responsible for documenting that this work occurred. (Indiana Department of Education, ESSER III Frequently Asked Questions (FAQs) updated August 16, 2021) Cause A proper system of internal controls over the payroll disbursements for employees who worked with both federal and nonfederal programs was not properly designed or implemented by management. The School Corporation did not maintain a record of the actual time spent working on extra responsibilities for COVID-related work to ensure allowability. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation could not be determined for reimbursements for one employee's payroll for September and October of 2022. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls to ensure that disbursement documentation will be obtained, retained, and made available for audit and that the disbursements comply with the Allowable Costs/Cost Principles compliance requirement.
FINDING 2024-004 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Allowable Costs/Cost Principles. Federal funds may only be used to pay staff for work that has occurred supporting the objective of the federal program. As such, proper time and effort documentation is to be maintained by the School Corporation. The purpose of time and effort recording is to provide documentation of the time spent working on specific federal programs to ensure charges are accurate for each program. Reimbursements were prepared by one employee and reviewed by another employee prior to submission; however, this internal control was not effective in preventing noncompliance with allowable costs/cost principles. INDIANA STATE BOARD OF ACCOUNTS 22 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Out of 14 employees tested, 1 employee was paid 50 percent of their salary from the COVID-19 - Education Stabilization Funds (ESF) grant and 50 percent of their salary from another funding source. The School Corporation was not able to provide documentation that supported the hours paid from the ESF grant. The ineffective internal controls were systemic throughout the audit period. The noncompliance was isolated to payrolls for September and October of 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 23 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) While across the board stipends are not permitted, LEAs may pay staff for COVID-related work that has been documented. Most, if not all, staff likely had extra responsibilities as well as time and effort to respond to the pandemic. ESSER funds can be used to pay staff for that work and LEAs are responsible for documenting that this work occurred. (Indiana Department of Education, ESSER III Frequently Asked Questions (FAQs) updated August 16, 2021) Cause A proper system of internal controls over the payroll disbursements for employees who worked with both federal and nonfederal programs was not properly designed or implemented by management. The School Corporation did not maintain a record of the actual time spent working on extra responsibilities for COVID-related work to ensure allowability. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation could not be determined for reimbursements for one employee's payroll for September and October of 2022. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls to ensure that disbursement documentation will be obtained, retained, and made available for audit and that the disbursements comply with the Allowable Costs/Cost Principles compliance requirement.
FINDING 2024-004 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Allowable Costs/Cost Principles. Federal funds may only be used to pay staff for work that has occurred supporting the objective of the federal program. As such, proper time and effort documentation is to be maintained by the School Corporation. The purpose of time and effort recording is to provide documentation of the time spent working on specific federal programs to ensure charges are accurate for each program. Reimbursements were prepared by one employee and reviewed by another employee prior to submission; however, this internal control was not effective in preventing noncompliance with allowable costs/cost principles. INDIANA STATE BOARD OF ACCOUNTS 22 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Out of 14 employees tested, 1 employee was paid 50 percent of their salary from the COVID-19 - Education Stabilization Funds (ESF) grant and 50 percent of their salary from another funding source. The School Corporation was not able to provide documentation that supported the hours paid from the ESF grant. The ineffective internal controls were systemic throughout the audit period. The noncompliance was isolated to payrolls for September and October of 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 23 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) While across the board stipends are not permitted, LEAs may pay staff for COVID-related work that has been documented. Most, if not all, staff likely had extra responsibilities as well as time and effort to respond to the pandemic. ESSER funds can be used to pay staff for that work and LEAs are responsible for documenting that this work occurred. (Indiana Department of Education, ESSER III Frequently Asked Questions (FAQs) updated August 16, 2021) Cause A proper system of internal controls over the payroll disbursements for employees who worked with both federal and nonfederal programs was not properly designed or implemented by management. The School Corporation did not maintain a record of the actual time spent working on extra responsibilities for COVID-related work to ensure allowability. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation could not be determined for reimbursements for one employee's payroll for September and October of 2022. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls to ensure that disbursement documentation will be obtained, retained, and made available for audit and that the disbursements comply with the Allowable Costs/Cost Principles compliance requirement.
FINDING 2024-004 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Allowable Costs/Cost Principles. Federal funds may only be used to pay staff for work that has occurred supporting the objective of the federal program. As such, proper time and effort documentation is to be maintained by the School Corporation. The purpose of time and effort recording is to provide documentation of the time spent working on specific federal programs to ensure charges are accurate for each program. Reimbursements were prepared by one employee and reviewed by another employee prior to submission; however, this internal control was not effective in preventing noncompliance with allowable costs/cost principles. INDIANA STATE BOARD OF ACCOUNTS 22 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Out of 14 employees tested, 1 employee was paid 50 percent of their salary from the COVID-19 - Education Stabilization Funds (ESF) grant and 50 percent of their salary from another funding source. The School Corporation was not able to provide documentation that supported the hours paid from the ESF grant. The ineffective internal controls were systemic throughout the audit period. The noncompliance was isolated to payrolls for September and October of 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 23 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) While across the board stipends are not permitted, LEAs may pay staff for COVID-related work that has been documented. Most, if not all, staff likely had extra responsibilities as well as time and effort to respond to the pandemic. ESSER funds can be used to pay staff for that work and LEAs are responsible for documenting that this work occurred. (Indiana Department of Education, ESSER III Frequently Asked Questions (FAQs) updated August 16, 2021) Cause A proper system of internal controls over the payroll disbursements for employees who worked with both federal and nonfederal programs was not properly designed or implemented by management. The School Corporation did not maintain a record of the actual time spent working on extra responsibilities for COVID-related work to ensure allowability. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation could not be determined for reimbursements for one employee's payroll for September and October of 2022. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls to ensure that disbursement documentation will be obtained, retained, and made available for audit and that the disbursements comply with the Allowable Costs/Cost Principles compliance requirement.
FINDING 2024-004 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Allowable Costs/Cost Principles. Federal funds may only be used to pay staff for work that has occurred supporting the objective of the federal program. As such, proper time and effort documentation is to be maintained by the School Corporation. The purpose of time and effort recording is to provide documentation of the time spent working on specific federal programs to ensure charges are accurate for each program. Reimbursements were prepared by one employee and reviewed by another employee prior to submission; however, this internal control was not effective in preventing noncompliance with allowable costs/cost principles. INDIANA STATE BOARD OF ACCOUNTS 22 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Out of 14 employees tested, 1 employee was paid 50 percent of their salary from the COVID-19 - Education Stabilization Funds (ESF) grant and 50 percent of their salary from another funding source. The School Corporation was not able to provide documentation that supported the hours paid from the ESF grant. The ineffective internal controls were systemic throughout the audit period. The noncompliance was isolated to payrolls for September and October of 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.430(i) states in part: "Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . (iv) Encompass federally-assisted and all other activities compensated by the recipient or subrecipient on an integrated basis but may include the use of subsidiary records as defined in the recipient's or subrecipient's written policy; . . . (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. . . ." INDIANA STATE BOARD OF ACCOUNTS 23 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) While across the board stipends are not permitted, LEAs may pay staff for COVID-related work that has been documented. Most, if not all, staff likely had extra responsibilities as well as time and effort to respond to the pandemic. ESSER funds can be used to pay staff for that work and LEAs are responsible for documenting that this work occurred. (Indiana Department of Education, ESSER III Frequently Asked Questions (FAQs) updated August 16, 2021) Cause A proper system of internal controls over the payroll disbursements for employees who worked with both federal and nonfederal programs was not properly designed or implemented by management. The School Corporation did not maintain a record of the actual time spent working on extra responsibilities for COVID-related work to ensure allowability. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the proper allocation could not be determined for reimbursements for one employee's payroll for September and October of 2022. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management design and implement a system of internal controls to ensure that disbursement documentation will be obtained, retained, and made available for audit and that the disbursements comply with the Allowable Costs/Cost Principles compliance requirement.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context Internal controls were in place over reporting where two individuals were involved in submitting and reviewing the reports prior to submission. However, the internal controls were not effective in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Reporting. INDIANA STATE BOARD OF ACCOUNTS 24 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation was required to submit an annual data report to the Indiana Department of Education. Data to be submitted includes, but is not limited to, current period expenditure, prior period expenditure, and expenditures per activity. During the audit period, the School Corporation submitted 2021-2022 expenditures for ESSER II - Year 3 and ESSER III - Year 3 instead of reporting 2022-2023 expenditures for ESSER II - Year 3 and ESSER III - Year 3. The lack of effective internal controls was systemic throughout the audit period. The noncompliance was isolated to the ESSER II - Year 3 and ESSER III - Year 3 reporting. 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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation had policies and procedures in place over proper reporting on its annual data report; however, officials indicated their understanding of the guidance provided as to which year's expenditures were to be reported was different than what was required. INDIANA STATE BOARD OF ACCOUNTS 25 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Expenditures reported on the annual data report for ESSER II and ESSER III year 3 were not accurate. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure expenditures on the annual data reporting for ESSER II and ESSER III are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context Internal controls were in place over reporting where two individuals were involved in submitting and reviewing the reports prior to submission. However, the internal controls were not effective in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Reporting. INDIANA STATE BOARD OF ACCOUNTS 24 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation was required to submit an annual data report to the Indiana Department of Education. Data to be submitted includes, but is not limited to, current period expenditure, prior period expenditure, and expenditures per activity. During the audit period, the School Corporation submitted 2021-2022 expenditures for ESSER II - Year 3 and ESSER III - Year 3 instead of reporting 2022-2023 expenditures for ESSER II - Year 3 and ESSER III - Year 3. The lack of effective internal controls was systemic throughout the audit period. The noncompliance was isolated to the ESSER II - Year 3 and ESSER III - Year 3 reporting. 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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation had policies and procedures in place over proper reporting on its annual data report; however, officials indicated their understanding of the guidance provided as to which year's expenditures were to be reported was different than what was required. INDIANA STATE BOARD OF ACCOUNTS 25 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Expenditures reported on the annual data report for ESSER II and ESSER III year 3 were not accurate. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure expenditures on the annual data reporting for ESSER II and ESSER III are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context Internal controls were in place over reporting where two individuals were involved in submitting and reviewing the reports prior to submission. However, the internal controls were not effective in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Reporting. INDIANA STATE BOARD OF ACCOUNTS 24 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation was required to submit an annual data report to the Indiana Department of Education. Data to be submitted includes, but is not limited to, current period expenditure, prior period expenditure, and expenditures per activity. During the audit period, the School Corporation submitted 2021-2022 expenditures for ESSER II - Year 3 and ESSER III - Year 3 instead of reporting 2022-2023 expenditures for ESSER II - Year 3 and ESSER III - Year 3. The lack of effective internal controls was systemic throughout the audit period. The noncompliance was isolated to the ESSER II - Year 3 and ESSER III - Year 3 reporting. 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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation had policies and procedures in place over proper reporting on its annual data report; however, officials indicated their understanding of the guidance provided as to which year's expenditures were to be reported was different than what was required. INDIANA STATE BOARD OF ACCOUNTS 25 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Expenditures reported on the annual data report for ESSER II and ESSER III year 3 were not accurate. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure expenditures on the annual data reporting for ESSER II and ESSER III are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context Internal controls were in place over reporting where two individuals were involved in submitting and reviewing the reports prior to submission. However, the internal controls were not effective in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Reporting. INDIANA STATE BOARD OF ACCOUNTS 24 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation was required to submit an annual data report to the Indiana Department of Education. Data to be submitted includes, but is not limited to, current period expenditure, prior period expenditure, and expenditures per activity. During the audit period, the School Corporation submitted 2021-2022 expenditures for ESSER II - Year 3 and ESSER III - Year 3 instead of reporting 2022-2023 expenditures for ESSER II - Year 3 and ESSER III - Year 3. The lack of effective internal controls was systemic throughout the audit period. The noncompliance was isolated to the ESSER II - Year 3 and ESSER III - Year 3 reporting. 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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation had policies and procedures in place over proper reporting on its annual data report; however, officials indicated their understanding of the guidance provided as to which year's expenditures were to be reported was different than what was required. INDIANA STATE BOARD OF ACCOUNTS 25 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Expenditures reported on the annual data report for ESSER II and ESSER III year 3 were not accurate. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure expenditures on the annual data reporting for ESSER II and ESSER III are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context Internal controls were in place over reporting where two individuals were involved in submitting and reviewing the reports prior to submission. However, the internal controls were not effective in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Reporting. INDIANA STATE BOARD OF ACCOUNTS 24 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation was required to submit an annual data report to the Indiana Department of Education. Data to be submitted includes, but is not limited to, current period expenditure, prior period expenditure, and expenditures per activity. During the audit period, the School Corporation submitted 2021-2022 expenditures for ESSER II - Year 3 and ESSER III - Year 3 instead of reporting 2022-2023 expenditures for ESSER II - Year 3 and ESSER III - Year 3. The lack of effective internal controls was systemic throughout the audit period. The noncompliance was isolated to the ESSER II - Year 3 and ESSER III - Year 3 reporting. 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 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation had policies and procedures in place over proper reporting on its annual data report; however, officials indicated their understanding of the guidance provided as to which year's expenditures were to be reported was different than what was required. INDIANA STATE BOARD OF ACCOUNTS 25 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Expenditures reported on the annual data report for ESSER II and ESSER III year 3 were not accurate. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure expenditures on the annual data reporting for ESSER II and ESSER III are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
(1) Summary of Auditors’ Results Financial Statements a. Type of report issued on whether the financial statements were prepared in accordance with generally accepted accounting principles: Unmodified b. Internal control deficiencies over financial reporting disclosed by the audit of the financial statements: • Material weaknesses: No • Significant deficiencies: No c. Noncompliance material to the financial statements: No Federal Awards d. Internal control deficiencies over major programs disclosed by the audit: • Material weaknesses: Yes • Significant deficiencies: No e. Type of report issued on compliance for major programs: Qualified f. Audit findings that are required to be reported in accordance with 2 CFR 200.516(a): Yes g. Major programs: • Student Financial Assistance Cluster – Various ALNs h. Dollar threshold used to distinguish between Type A and Type B programs: $750,000 i. Auditee qualified as a low-risk auditee: Yes (2) Findings Relating to the Financial Statements Reported in Accordance with Government Auditing Standards None (3) Findings and Questioned Costs Relating to Federal Awards Finding Number: 2024-001 Program: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Federal Award #’s: P063P235372, P268K225372 Federal Award Years: July 1, 2023 to June 30, 2024 Federal Agencies: U.S. Department of Education Pass-Through Entity: N/A – Direct Award Compliance Requirement: Enrollment Reporting Finding Type: Material Weakness and Material Noncompliance Criteria: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update and verify student enrollment statuses, program information and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Financial Aid Professionals (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS within 15 days. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition found: During our testwork over student enrollment reporting, we noted Regent did not report all changes to students’ status within the required 60 days. For a sample of 40 students who were recipients of Direct Loans or Pell Grants between July 1, 2023 and June 30, 2024 and that had been identified as having withdrawn, graduated, or modified their enrollment status as defined by Regent’s Satisfactory Academic Progress Policy through a change in course load, the following was noted: For 33 students out of the 40 selected for compliance testing, Regent did not transmit the students’ status change to NSLDS within 60 days. Additionally, based on management’s further investigation, it was determined that there were multiple submissions during the year that were delayed and resulted in enrollment reporting being outside of the 60- day window. Additionally, while Regent has controls in place to ensure that enrollment changes are reported timely to the National Student Clearinghouse (NSC), the control does not ensure that any required correspondence with NSC to resolve data matters is happening timely. Cause: For the students noted above, management communicated that there were delays in the data transmission from the NSC and the NSLDS. While the data was provided to the NSC in a timely manner, there were issues with the data that needed to be resolved between Regent and the NSC in order to proceed with the submission to NSLDS. For the reasons noted above, we determined the related control in place at Regent, which is designed to address the timeliness of the transmission reports, is not designed at a level to verify the timeliness of the data transmission to the NSC nor ensure that any subsequent issues are resolved timely and that the data is ultimately submitted to the NSLDS timely. Proper perspective: Regent’s policy is to submit enrollment data to the NSC on a predetermined schedule that allows Regent to comply with the enrollment reporting requirements. For our sample of 40 students with status changes, we identified 33 students where the status change was not reported within 60 days. Upon further review by management, there were a total of 13 submissions for which the delay in the resolution of issues between Regent and the NSC resulted in the enrollment information being reported outside of the 60-day reporting requirement. As a result of these delays, there were a significant number of changes that were not reporting timely. Possible asserted effect: Untimely submission of student enrollment information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, graces periods, and repayment schedules, as well as the federal government’s payment and interest schedules. Questioned costs: None noted. Statistical sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat finding: A similar finding was not reported in the prior year. Recommendation: We recommend that Regent implement additional controls to ensure that the transmission reports are received by NSLDS timely. Additionally, we recommend Regent evaluate its processes and procedures when submitting data to the NSC to ensure that any data issues impacting the timeliness of the transmissions are resolved. Views of responsible officials: Regent agrees with this finding. Regent intends to strengthen its controls and quality assurance measures over the timeliness of enrollment information to NSLDS.
(1) Summary of Auditors’ Results Financial Statements a. Type of report issued on whether the financial statements were prepared in accordance with generally accepted accounting principles: Unmodified b. Internal control deficiencies over financial reporting disclosed by the audit of the financial statements: • Material weaknesses: No • Significant deficiencies: No c. Noncompliance material to the financial statements: No Federal Awards d. Internal control deficiencies over major programs disclosed by the audit: • Material weaknesses: Yes • Significant deficiencies: No e. Type of report issued on compliance for major programs: Qualified f. Audit findings that are required to be reported in accordance with 2 CFR 200.516(a): Yes g. Major programs: • Student Financial Assistance Cluster – Various ALNs h. Dollar threshold used to distinguish between Type A and Type B programs: $750,000 i. Auditee qualified as a low-risk auditee: Yes (2) Findings Relating to the Financial Statements Reported in Accordance with Government Auditing Standards None (3) Findings and Questioned Costs Relating to Federal Awards Finding Number: 2024-001 Program: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Federal Award #’s: P063P235372, P268K225372 Federal Award Years: July 1, 2023 to June 30, 2024 Federal Agencies: U.S. Department of Education Pass-Through Entity: N/A – Direct Award Compliance Requirement: Enrollment Reporting Finding Type: Material Weakness and Material Noncompliance Criteria: Under the Pell grant and the Direct and Federal Family Education Loan programs, institutions are required to report enrollment information via the National Student Loan Data System (NSLDS) (OMB No. 845-0035). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update and verify student enrollment statuses, program information and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Financial Aid Professionals (NSLDSFAP) website. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS within 15 days. An institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in the data elements for the Campus Record and the Program Record identified above, and submit the changes electronically through the batch method, spreadsheet submittal or the NSLDS website. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition found: During our testwork over student enrollment reporting, we noted Regent did not report all changes to students’ status within the required 60 days. For a sample of 40 students who were recipients of Direct Loans or Pell Grants between July 1, 2023 and June 30, 2024 and that had been identified as having withdrawn, graduated, or modified their enrollment status as defined by Regent’s Satisfactory Academic Progress Policy through a change in course load, the following was noted: For 33 students out of the 40 selected for compliance testing, Regent did not transmit the students’ status change to NSLDS within 60 days. Additionally, based on management’s further investigation, it was determined that there were multiple submissions during the year that were delayed and resulted in enrollment reporting being outside of the 60- day window. Additionally, while Regent has controls in place to ensure that enrollment changes are reported timely to the National Student Clearinghouse (NSC), the control does not ensure that any required correspondence with NSC to resolve data matters is happening timely. Cause: For the students noted above, management communicated that there were delays in the data transmission from the NSC and the NSLDS. While the data was provided to the NSC in a timely manner, there were issues with the data that needed to be resolved between Regent and the NSC in order to proceed with the submission to NSLDS. For the reasons noted above, we determined the related control in place at Regent, which is designed to address the timeliness of the transmission reports, is not designed at a level to verify the timeliness of the data transmission to the NSC nor ensure that any subsequent issues are resolved timely and that the data is ultimately submitted to the NSLDS timely. Proper perspective: Regent’s policy is to submit enrollment data to the NSC on a predetermined schedule that allows Regent to comply with the enrollment reporting requirements. For our sample of 40 students with status changes, we identified 33 students where the status change was not reported within 60 days. Upon further review by management, there were a total of 13 submissions for which the delay in the resolution of issues between Regent and the NSC resulted in the enrollment information being reported outside of the 60-day reporting requirement. As a result of these delays, there were a significant number of changes that were not reporting timely. Possible asserted effect: Untimely submission of student enrollment information affects the determinations that lenders and servicers of students’ loans make related to in-school status, deferments, graces periods, and repayment schedules, as well as the federal government’s payment and interest schedules. Questioned costs: None noted. Statistical sampling: The sample was not intended to be, and was not, a statistically valid sample. Repeat finding: A similar finding was not reported in the prior year. Recommendation: We recommend that Regent implement additional controls to ensure that the transmission reports are received by NSLDS timely. Additionally, we recommend Regent evaluate its processes and procedures when submitting data to the NSC to ensure that any data issues impacting the timeliness of the transmissions are resolved. Views of responsible officials: Regent agrees with this finding. Regent intends to strengthen its controls and quality assurance measures over the timeliness of enrollment information to NSLDS.
2024-002 Program: CDBG – Entitlement/Special Purpose Grants Cluster Financial Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: All Grant Award Number: All Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the preparer and approver of required reports. Condition: We identified one (1) instance in which the City did not retain evidence to document the individual who reviewed and approved the required reports prior to submission. This consisted of one (1) financial report. Cause: The City's procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A nonstatistical sample of two (2) out of four (4) cash on hand reports were selected for reporting testing. Repeat Finding from the Prior Year(s): Yes. Recommendation: The City has implemented the appropriate changes subsequent to the end of fiscal year 2024. During fiscal year 2024, the City had not fully implemented corrective actions. We recommend the City continue performing the corrective actions they made. Views of Responsible Official: The City concurs with the finding. See separate corrective action plan.
2024-002 Program: CDBG – Entitlement/Special Purpose Grants Cluster Financial Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: All Grant Award Number: All Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the preparer and approver of required reports. Condition: We identified one (1) instance in which the City did not retain evidence to document the individual who reviewed and approved the required reports prior to submission. This consisted of one (1) financial report. Cause: The City's procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A nonstatistical sample of two (2) out of four (4) cash on hand reports were selected for reporting testing. Repeat Finding from the Prior Year(s): Yes. Recommendation: The City has implemented the appropriate changes subsequent to the end of fiscal year 2024. During fiscal year 2024, the City had not fully implemented corrective actions. We recommend the City continue performing the corrective actions they made. Views of Responsible Official: The City concurs with the finding. See separate corrective action plan.
2024-002 Program: CDBG – Entitlement/Special Purpose Grants Cluster Financial Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: All Grant Award Number: All Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the preparer and approver of required reports. Condition: We identified one (1) instance in which the City did not retain evidence to document the individual who reviewed and approved the required reports prior to submission. This consisted of one (1) financial report. Cause: The City's procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A nonstatistical sample of two (2) out of four (4) cash on hand reports were selected for reporting testing. Repeat Finding from the Prior Year(s): Yes. Recommendation: The City has implemented the appropriate changes subsequent to the end of fiscal year 2024. During fiscal year 2024, the City had not fully implemented corrective actions. We recommend the City continue performing the corrective actions they made. Views of Responsible Official: The City concurs with the finding. See separate corrective action plan.
2024-002 Program: CDBG – Entitlement/Special Purpose Grants Cluster Financial Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: All Grant Award Number: All Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the preparer and approver of required reports. Condition: We identified one (1) instance in which the City did not retain evidence to document the individual who reviewed and approved the required reports prior to submission. This consisted of one (1) financial report. Cause: The City's procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A nonstatistical sample of two (2) out of four (4) cash on hand reports were selected for reporting testing. Repeat Finding from the Prior Year(s): Yes. Recommendation: The City has implemented the appropriate changes subsequent to the end of fiscal year 2024. During fiscal year 2024, the City had not fully implemented corrective actions. We recommend the City continue performing the corrective actions they made. Views of Responsible Official: The City concurs with the finding. See separate corrective action plan.
2024-002 Program: CDBG – Entitlement/Special Purpose Grants Cluster Financial Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: All Grant Award Number: All Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the preparer and approver of required reports. Condition: We identified one (1) instance in which the City did not retain evidence to document the individual who reviewed and approved the required reports prior to submission. This consisted of one (1) financial report. Cause: The City's procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A nonstatistical sample of two (2) out of four (4) cash on hand reports were selected for reporting testing. Repeat Finding from the Prior Year(s): Yes. Recommendation: The City has implemented the appropriate changes subsequent to the end of fiscal year 2024. During fiscal year 2024, the City had not fully implemented corrective actions. We recommend the City continue performing the corrective actions they made. Views of Responsible Official: The City concurs with the finding. See separate corrective action plan.
2024-002 Program: CDBG – Entitlement/Special Purpose Grants Cluster Financial Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: All Grant Award Number: All Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the preparer and approver of required reports. Condition: We identified one (1) instance in which the City did not retain evidence to document the individual who reviewed and approved the required reports prior to submission. This consisted of one (1) financial report. Cause: The City's procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A nonstatistical sample of two (2) out of four (4) cash on hand reports were selected for reporting testing. Repeat Finding from the Prior Year(s): Yes. Recommendation: The City has implemented the appropriate changes subsequent to the end of fiscal year 2024. During fiscal year 2024, the City had not fully implemented corrective actions. We recommend the City continue performing the corrective actions they made. Views of Responsible Official: The City concurs with the finding. See separate corrective action plan.
2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.
2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.
2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.
2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.
2024-004 Program: Highway Planning and Construction Financial Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: We noted for eight (8) out of eight (8) certified payrolls selected for testing, the City did not document their review and approval of certified payroll submission. In addition, for two (2) out of eight (8) weeks of certified payroll selected for testing, we noted the contractor or subcontractor did not submit the certified payroll in a timely manner. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective procedures over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected eight (8) of twenty-one (21) certified payrolls for testing. Repeat Finding from the Prior Year(s): No. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.
2024-003 Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: Multiple Grant Award Number: Multiple Compliance Requirements: Special Tests and Provisions – Wage Rate Requirements Type of Finding: Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) 40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326. 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes internal controls over maintaining records of the receipt and review of certified payrolls. Condition: In March 2024, the City implemented procedural changes to their certified payroll review process. Until February 2024, the City did not retain evidence to document the individual who reviewed the certified payroll for each week in which work was performed by construction contractors and subcontractors. Due to backlog, the City was not able to catch up on certifications until August 2024 which was after the fiscal year had ended. For fifty-four (54) of sixty (60) weeks of certified payroll submissions selected for testing, we noted that the City did not review the contractors’ submissions of certified payroll in a timely manner. For six (6) out of sixty (60) weeks of certified payroll submissions selected, we noted that a statement of non-performance was submitted. However, the tracking spreadsheet provided to the City by its 3rd party project manager indicated that work had been performed. For nineteen (19) out of sixty (60) weeks of certified payroll submissions selected, we noted that the contractor or subcontractor had not submitted the weekly certified payroll in a timely manner. The contractor had submitted their certified payroll several weeks after the week of work performed. Cause: The City’s procedures did not include documenting the review of the certified payroll received. In addition, the City did not have the necessary internal controls in place to ensure the accuracy of the tracking of work weeks being performed as well as the contractor’s and subcontractor’s timely submittal of certified payroll. Effect: Ineffective controls over this area of compliance could result in noncompliance with the wage rate compliance requirements. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was used. We selected sixty (60) out of all weeks indicated as work weeks for the City’s project for testing. However, due to the condition noted above, the population of work weeks could not be verified. Repeat Finding from the Prior Year(s): Yes, 2023-003. Recommendation: We recommend that the City strengthen its internal controls to ensure that timely reviews of certified payroll submissions are being performed by the City. This could include performing procedures to ensure that information being provided to the City by its consultant project managers is accurate and that the required certified payroll is being submitted by contractors and subcontractors in a timely manner. View of Responsible Official and Planned Corrective Actions The City concurs with the finding. See separate corrective action plan.
U.S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number 21.027, Passed through the City of Las Vegas and Clark Country – Compliance and Internal Control Systems Over Compliance, Reporting Criteria: As defined in 2 CFR 200.303, the auditee is required to establish, document, and maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions are executed in compliance with the terms and conditions of the federal award, federal statutes, and regulations. Condition: The Organization does not consistently utilize the accrual basis of accounting when creating requests for reimbursement of expenditures under federal grant awards. Cause: Internal controls over compliance as related to the compliance requirement of reporting were not designed and/or operating effectively. Effect: An organization is required to select a basis of accounting upon which to present the schedule of expenditures of federal awards (SEFA). This basis selected is disclosed to users of the financial statements as part of the notes to the SEFA. Inconsistent application of the basis of accounting used to support requests for reimbursement may result in a SEFA that is misstated relative to the basis of accounting selected by management and disclosed to users of the financial statements. Recommendations: We recommend management design and implement a system of internal controls whereby expenditures submitted for federal reimbursement are recognized consistently on the basis of accounting selected by management (e.g., accrual vs. cash). Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding regarding the inconsistent use of the accrual basis of accounting for federal grant reimbursements. At the time of SEFA preparation, the methodology used was based on the reimbursement requests submitted throughout the year, which had been prepared on a cash basis. However, for the final reimbursement under the City of Las Vegas grant ending June 30, 2024, accrued payroll costs for work performed in June but paid in July were included to ensure full reporting of eligible grant activity. This deviation from the previously applied basis led to the noted inconsistency. Planned Corrective Actions: • Going forward, management will implement the following corrective actions: • A consistent accounting basis (accrual) will be selected and formally documented for all SEFA reporting and federal reimbursement requests. • Internal procedures will be updated to reflect the chosen basis and ensure it is applied uniformly across all reimbursement submissions. • A secondary review of SEFA reporting will be conducted by senior finance staff or the CEO to ensure consistency with the selected accounting method. • Staff will be trained annually on SEFA requirements and federal compliance standards under 2 CFR 200. These corrective actions will be completed by June 30, 2025.
U.S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number 21.027, Passed through the City of Las Vegas and Clark Country – Internal Control Systems Over Compliance, Allowable Costs Criteria: As defined in 2 CFR 200.303, the auditee is required to establish, document, and maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions are executed in compliance with the terms and conditions of the federal award, federal statutes, and regulations. Condition: On the March 2024 request for reimbursement, the number of hours submitted for reimbursement for one employee was inconsistent with the supporting documentation included in the reporting package. The number of hours submitted for reimbursement exceed the supporting documentation by sixteen hours. Cause: Internal controls over compliance as related to the compliance requirement of allowable costs were not designed and/or operating effectively. Effect: The number of hours submitted for reimbursement exceed the supporting documentation by sixteen hours. Although the known or projected amount of this excess did not rise to the level of a questioned costs compliance finding, there is a risk that in the absence of a well-designed and consistently implemented system of internal controls that unallowable costs will be submitted for reimbursement. Recommendations: We recommend management design and implement a system of internal controls whereby expenditures submitted for federal reimbursement are in accordance with allowable cost principles. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding regarding the discrepancy in reported hours for one employee on the March 2024 reimbursement request. The 16-hour variance was an unintentional clerical error during the preparation of the reimbursement package. The discrepancy was not material, but we agree that stronger controls are necessary to prevent such occurrences. Planned Corrective Actions: • To address this finding, management will: • Establish a formal review and approval process for all reimbursement packages, including verification of hours against supporting documentation (e.g., timesheets or payroll records). • Design and implement a checklist to be used during the preparation of reimbursement requests to ensure compliance with allowable cost principles. • Conduct periodic internal audits of submitted RFRs to confirm alignment with backup documentation. • Provide training to all relevant personnel on federal allowable cost requirements under 2 CFR 200. All corrective actions will be implemented by June 30, 2025, with ongoing monitoring thereafter.
U.S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number 21.027, Passed through the City of Las Vegas and Clark Country – Compliance and Internal Control Systems Over Compliance, Reporting Criteria: As defined in 2 CFR 200.303, the auditee is required to establish, document, and maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions are executed in compliance with the terms and conditions of the federal award, federal statutes, and regulations. Condition: The Organization does not consistently utilize the accrual basis of accounting when creating requests for reimbursement of expenditures under federal grant awards. Cause: Internal controls over compliance as related to the compliance requirement of reporting were not designed and/or operating effectively. Effect: An organization is required to select a basis of accounting upon which to present the schedule of expenditures of federal awards (SEFA). This basis selected is disclosed to users of the financial statements as part of the notes to the SEFA. Inconsistent application of the basis of accounting used to support requests for reimbursement may result in a SEFA that is misstated relative to the basis of accounting selected by management and disclosed to users of the financial statements. Recommendations: We recommend management design and implement a system of internal controls whereby expenditures submitted for federal reimbursement are recognized consistently on the basis of accounting selected by management (e.g., accrual vs. cash). Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding regarding the inconsistent use of the accrual basis of accounting for federal grant reimbursements. At the time of SEFA preparation, the methodology used was based on the reimbursement requests submitted throughout the year, which had been prepared on a cash basis. However, for the final reimbursement under the City of Las Vegas grant ending June 30, 2024, accrued payroll costs for work performed in June but paid in July were included to ensure full reporting of eligible grant activity. This deviation from the previously applied basis led to the noted inconsistency. Planned Corrective Actions: • Going forward, management will implement the following corrective actions: • A consistent accounting basis (accrual) will be selected and formally documented for all SEFA reporting and federal reimbursement requests. • Internal procedures will be updated to reflect the chosen basis and ensure it is applied uniformly across all reimbursement submissions. • A secondary review of SEFA reporting will be conducted by senior finance staff or the CEO to ensure consistency with the selected accounting method. • Staff will be trained annually on SEFA requirements and federal compliance standards under 2 CFR 200. These corrective actions will be completed by June 30, 2025.
U.S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number 21.027, Passed through the City of Las Vegas and Clark Country – Internal Control Systems Over Compliance, Allowable Costs Criteria: As defined in 2 CFR 200.303, the auditee is required to establish, document, and maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions are executed in compliance with the terms and conditions of the federal award, federal statutes, and regulations. Condition: On the March 2024 request for reimbursement, the number of hours submitted for reimbursement for one employee was inconsistent with the supporting documentation included in the reporting package. The number of hours submitted for reimbursement exceed the supporting documentation by sixteen hours. Cause: Internal controls over compliance as related to the compliance requirement of allowable costs were not designed and/or operating effectively. Effect: The number of hours submitted for reimbursement exceed the supporting documentation by sixteen hours. Although the known or projected amount of this excess did not rise to the level of a questioned costs compliance finding, there is a risk that in the absence of a well-designed and consistently implemented system of internal controls that unallowable costs will be submitted for reimbursement. Recommendations: We recommend management design and implement a system of internal controls whereby expenditures submitted for federal reimbursement are in accordance with allowable cost principles. Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding regarding the discrepancy in reported hours for one employee on the March 2024 reimbursement request. The 16-hour variance was an unintentional clerical error during the preparation of the reimbursement package. The discrepancy was not material, but we agree that stronger controls are necessary to prevent such occurrences. Planned Corrective Actions: • To address this finding, management will: • Establish a formal review and approval process for all reimbursement packages, including verification of hours against supporting documentation (e.g., timesheets or payroll records). • Design and implement a checklist to be used during the preparation of reimbursement requests to ensure compliance with allowable cost principles. • Conduct periodic internal audits of submitted RFRs to confirm alignment with backup documentation. • Provide training to all relevant personnel on federal allowable cost requirements under 2 CFR 200. All corrective actions will be implemented by June 30, 2025, with ongoing monitoring thereafter.
Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Equipment Property Management Federal Program: Congressional Directives (ALN 93.493) Federal Agency: Department of Health and Human Services Federal Award Number: 1CE1HS52890-01-00 Federal Award Year: September 30, 2023 through June 30, 2024 Criteria or Requirement Per 2 CFR section 200.313, property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Per 2 CFR 200.303, 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. Condition and Context For 4 out of 14 purchase transactions or 17 out of 20 individual assets, equipment exceeding the capitalization threshold per 2 CFR section 200.1 was not capitalized. Therefore, a property record did not exist for federally funded equipment purchased in the amount of $1,758,365. The total program expenditures were $3,652,263 for which $2,776,884 were capital equipment purchases and $875,379 were non-capital purchases. For the equipment that was capitalized and a property record was established, the property record did not properly identify the asset as federally funded. Cause and Potential Effect The University's internal controls for determining and documenting whether an equipment acquisition was a capital asset for which a property record should be created in the system with the required was not operating effectively. Accordingly, the University acquired federally funded equipment and a property record was not created. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample.Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over equipment purchases to ensure that a property record is created within the system containing the required information for all federally funded equipment. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002 Procurement – Suspension and Debarment Federal Program, Federal Agency, Federal Award Number, Federal Award Year Federal program ALN Federal Agency Federal Award Number Federal Award Year R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024 R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024 R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024 R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024 R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024 R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024 R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024 R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024 R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024 Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024 Criteria or Requirement Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction.Per 2 CFR 200.303, 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. Condition and Context For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement transactions, the University could not provide documentation to support that they checked suspension and debarment on a timely basis. The documentation provided evidenced that the University checked that the vendor was not suspended or debarred at some point after the covered transaction occurred. Cause and Potential Effect The University’s internal controls for determining and documenting whether a vendor was not suspended or debarred prior to entering into the covered procurement transaction with that vendor was not operating effectively. Accordingly, the University could have entered into a covered procurement transaction with a suspended or debarred vendor. Questioned Cost There were no questioned costs associated with the finding. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over suspension and debarment to ensure that, prior to entering into each covered procurement transaction, the University has checked to determine that the vendor is not suspended or debarred, and the results are documented. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.
Period of Performance Federal Program: Research and Development Cluster - Arthritis, Musculoskeletal and Skin Diseases Research (ALN 93.846) Federal Agency: Department of Health and Human Services Federal Award Number: R01AR071410 Federal Award Year: July 1, 2023 through June 30, 2024 Criteria or Requirement Per 2 CFR section 200.403(h), a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. Per 2 CFR 200.303, 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. Condition and Context For 1 of 40 transactions sampled for period of performance, purchase incurred after the period of performance was charged to the grant which is not allowable under the grant award or cost principles. Cause and Potential Effect The University's internal controls for determining a purchase is within the federal award’s period of performance was not operating effectively. Accordingly, the University has requested reimbursement for purchases incurred after the period of performance of the federal award. Questioned Cost There are known questioned costs of $16,017. The aggregated total sample for the 40 period of performance transactions was $2,132,385. The total population for research and development cluster expenditures aggregated $184,508,852. Statistically Valid Sample The sample was not intended to be, and was not, a statistically valid sample.Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit No. Recommendation We recommend the University enhance the precision of the controls over purchases to ensure the purchases are incurred within the federal award’s period of performance and if incurred subsequent to the federal award’s period of performance, are not charged to the federal agency. View of Responsible Officials Management of the University takes no exception to this reported finding. We have implemented the remedial actions as outlined in our Corrective Action Plan.