FINDING 2022-010 Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-138-PN01, 21619-138-PN01, 22611-138-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for one of the two journal entries tested. For the one journal entry, we were unable to determine if the Special Education fund transfers in, totaling $619,180, and transfers out, totaling $554,684, were for allowable activities and costs for the program. In addition, we were unable to determine if the transfers were for transactions that occurred within the period of performance. The lack of internal controls and the failure to retain supporting documentation was isolated to the transfers noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 40 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.333 (Uniform Guidance) 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 Federal awards that are renewed quarterly or annually, from the date of the 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 200.334 (Revised Uniform Guidance) 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 Federal awards that are renewed quarterly or annually, from the date of the 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. . . ." 34 CFR 300.202(a) states: "General. Amounts provided to the LEA under Part B of the Act - (1) Must be expended in accordance with the applicable provisions of this part; (2) Must be used only to pay the excess costs of providing special education and related services to children with disabilities, consistent with paragraph (b) of this section; and (3) Must be used to supplement State, local, and other Federal funds and not to supplant those funds." 34 CFR 300.208 states: "(a) Uses. Notwithstanding ?? 300.202, 300.203(b), and 300.162(b), funds provided to an LEA under Part B of the Act may be used for the following activities: (1) Services and aids that also benefit nondisabled children. For the costs of special education and related services, and supplementary aids and services, provided in a regular class or other education-related setting to a child with a disability in accordance with the IEP of the child, even if one or more nondisabled children benefit from these services. (2) Early intervening services. To develop and implement coordinated, early intervening educational services in accordance with ? 300.226. (3) High cost special education and related services. To establish and implement cost or risk sharing funds, consortia, or cooperatives for the LEA itself, or for LEAs working in a consortium of which the LEA is a part, to pay for high cost special education and related services. (b) Administrative case management. An LEA may use funds received under Part B of the Act to purchase appropriate technology for recordkeeping, data collection, and related case management activities of teachers and related services personnel providing services described in the IEP of children with disabilities, that is needed for the implementation of those case management activities." INDIANA STATE BOARD OF ACCOUNTS 41 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 300.800 states: "The Secretary provides grants under section 619 of the Act to assist States to provide special education and related services in accordance with Part B of the Act ? (a) To children with disabilities aged three through five years; and (b) At a State's discretion, to two-year-old children with disabilities who will turn three during the school year." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . (g) Be adequately documented. . . ." 2 CFR 200.77 (Uniform Guidance) states: "Period of performance means the time during which the non-Federal entity may incur new obligations to carry out the work authorized under the Federal award. The Federal awarding agency or pass-through entity must include start and end dates of the period of performance in the Federal award (see ?? 200.210 Information contained in a Federal award paragraph (a)(5) and 200.331 Requirements for pass-through entities, paragraph (a)(1)(iv))." 2 CFR 200.1 (Revised Uniform Guidance) states in part: ". . . Period of performance means the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Identification of the period of performance in the Federal award per ? 200.211(b)(5) does not commit the awarding agency to fund the award beyond the currently approved budget period. . . ." 2 CFR 200.309 (Uniform Guidance) states: "A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in ? 200.461 Publication and printing costs) 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." 2CFR 200.309 (Revised Uniform Guidance) states: "If a Federal awarding agency or pass-through entity approves an extension, or if a recipient extends under ? 200.308(e)(2), the Period of Performance will be amended to end at the completion of the extension. If a termination occurs, the Period of Performance will be amended to end upon the effective date of termination. If a renewal award is issued, a distinct Period of Performance will begin." INDIANA STATE BOARD OF ACCOUNTS 42 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, related to the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs Known questioned costs of $1,173,864 were identified, as detailed in Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-010 Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-138-PN01, 21619-138-PN01, 22611-138-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for one of the two journal entries tested. For the one journal entry, we were unable to determine if the Special Education fund transfers in, totaling $619,180, and transfers out, totaling $554,684, were for allowable activities and costs for the program. In addition, we were unable to determine if the transfers were for transactions that occurred within the period of performance. The lack of internal controls and the failure to retain supporting documentation was isolated to the transfers noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 40 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.333 (Uniform Guidance) 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 Federal awards that are renewed quarterly or annually, from the date of the 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 200.334 (Revised Uniform Guidance) 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 Federal awards that are renewed quarterly or annually, from the date of the 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. . . ." 34 CFR 300.202(a) states: "General. Amounts provided to the LEA under Part B of the Act - (1) Must be expended in accordance with the applicable provisions of this part; (2) Must be used only to pay the excess costs of providing special education and related services to children with disabilities, consistent with paragraph (b) of this section; and (3) Must be used to supplement State, local, and other Federal funds and not to supplant those funds." 34 CFR 300.208 states: "(a) Uses. Notwithstanding ?? 300.202, 300.203(b), and 300.162(b), funds provided to an LEA under Part B of the Act may be used for the following activities: (1) Services and aids that also benefit nondisabled children. For the costs of special education and related services, and supplementary aids and services, provided in a regular class or other education-related setting to a child with a disability in accordance with the IEP of the child, even if one or more nondisabled children benefit from these services. (2) Early intervening services. To develop and implement coordinated, early intervening educational services in accordance with ? 300.226. (3) High cost special education and related services. To establish and implement cost or risk sharing funds, consortia, or cooperatives for the LEA itself, or for LEAs working in a consortium of which the LEA is a part, to pay for high cost special education and related services. (b) Administrative case management. An LEA may use funds received under Part B of the Act to purchase appropriate technology for recordkeeping, data collection, and related case management activities of teachers and related services personnel providing services described in the IEP of children with disabilities, that is needed for the implementation of those case management activities." INDIANA STATE BOARD OF ACCOUNTS 41 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 300.800 states: "The Secretary provides grants under section 619 of the Act to assist States to provide special education and related services in accordance with Part B of the Act ? (a) To children with disabilities aged three through five years; and (b) At a State's discretion, to two-year-old children with disabilities who will turn three during the school year." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . (g) Be adequately documented. . . ." 2 CFR 200.77 (Uniform Guidance) states: "Period of performance means the time during which the non-Federal entity may incur new obligations to carry out the work authorized under the Federal award. The Federal awarding agency or pass-through entity must include start and end dates of the period of performance in the Federal award (see ?? 200.210 Information contained in a Federal award paragraph (a)(5) and 200.331 Requirements for pass-through entities, paragraph (a)(1)(iv))." 2 CFR 200.1 (Revised Uniform Guidance) states in part: ". . . Period of performance means the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Identification of the period of performance in the Federal award per ? 200.211(b)(5) does not commit the awarding agency to fund the award beyond the currently approved budget period. . . ." 2 CFR 200.309 (Uniform Guidance) states: "A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in ? 200.461 Publication and printing costs) 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." 2CFR 200.309 (Revised Uniform Guidance) states: "If a Federal awarding agency or pass-through entity approves an extension, or if a recipient extends under ? 200.308(e)(2), the Period of Performance will be amended to end at the completion of the extension. If a termination occurs, the Period of Performance will be amended to end upon the effective date of termination. If a renewal award is issued, a distinct Period of Performance will begin." INDIANA STATE BOARD OF ACCOUNTS 42 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, related to the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs Known questioned costs of $1,173,864 were identified, as detailed in Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-010 Subject: Special Education Cluster (IDEA) - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Federal Agency: Department of Education Federal Programs: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 21611-138-PN01, 21619-138-PN01, 22611-138-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not designed nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. The School Corporation had not established an effective system of internal controls to ensure that proper documentation was retained for audit. The School Corporation was unable to provide supporting documentation for one of the two journal entries tested. For the one journal entry, we were unable to determine if the Special Education fund transfers in, totaling $619,180, and transfers out, totaling $554,684, were for allowable activities and costs for the program. In addition, we were unable to determine if the transfers were for transactions that occurred within the period of performance. The lack of internal controls and the failure to retain supporting documentation was isolated to the transfers noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 40 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.333 (Uniform Guidance) 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 Federal awards that are renewed quarterly or annually, from the date of the 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 200.334 (Revised Uniform Guidance) 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 Federal awards that are renewed quarterly or annually, from the date of the 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. . . ." 34 CFR 300.202(a) states: "General. Amounts provided to the LEA under Part B of the Act - (1) Must be expended in accordance with the applicable provisions of this part; (2) Must be used only to pay the excess costs of providing special education and related services to children with disabilities, consistent with paragraph (b) of this section; and (3) Must be used to supplement State, local, and other Federal funds and not to supplant those funds." 34 CFR 300.208 states: "(a) Uses. Notwithstanding ?? 300.202, 300.203(b), and 300.162(b), funds provided to an LEA under Part B of the Act may be used for the following activities: (1) Services and aids that also benefit nondisabled children. For the costs of special education and related services, and supplementary aids and services, provided in a regular class or other education-related setting to a child with a disability in accordance with the IEP of the child, even if one or more nondisabled children benefit from these services. (2) Early intervening services. To develop and implement coordinated, early intervening educational services in accordance with ? 300.226. (3) High cost special education and related services. To establish and implement cost or risk sharing funds, consortia, or cooperatives for the LEA itself, or for LEAs working in a consortium of which the LEA is a part, to pay for high cost special education and related services. (b) Administrative case management. An LEA may use funds received under Part B of the Act to purchase appropriate technology for recordkeeping, data collection, and related case management activities of teachers and related services personnel providing services described in the IEP of children with disabilities, that is needed for the implementation of those case management activities." INDIANA STATE BOARD OF ACCOUNTS 41 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 34 CFR 300.800 states: "The Secretary provides grants under section 619 of the Act to assist States to provide special education and related services in accordance with Part B of the Act ? (a) To children with disabilities aged three through five years; and (b) At a State's discretion, to two-year-old children with disabilities who will turn three during the school year." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . (g) Be adequately documented. . . ." 2 CFR 200.77 (Uniform Guidance) states: "Period of performance means the time during which the non-Federal entity may incur new obligations to carry out the work authorized under the Federal award. The Federal awarding agency or pass-through entity must include start and end dates of the period of performance in the Federal award (see ?? 200.210 Information contained in a Federal award paragraph (a)(5) and 200.331 Requirements for pass-through entities, paragraph (a)(1)(iv))." 2 CFR 200.1 (Revised Uniform Guidance) states in part: ". . . Period of performance means the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Identification of the period of performance in the Federal award per ? 200.211(b)(5) does not commit the awarding agency to fund the award beyond the currently approved budget period. . . ." 2 CFR 200.309 (Uniform Guidance) states: "A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in ? 200.461 Publication and printing costs) 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." 2CFR 200.309 (Revised Uniform Guidance) states: "If a Federal awarding agency or pass-through entity approves an extension, or if a recipient extends under ? 200.308(e)(2), the Period of Performance will be amended to end at the completion of the extension. If a termination occurs, the Period of Performance will be amended to end upon the effective date of termination. If a renewal award is issued, a distinct Period of Performance will begin." INDIANA STATE BOARD OF ACCOUNTS 42 SCOTT COUNTY SCHOOL DISTRICT 2 SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Management had not developed nor implemented a system of internal controls that would have ensured compliance, or that supporting documentation would have been maintained and made available for audit, related to the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. Effect The failure to establish an effective system of internal controls and to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with compliance requirements listed above. Questioned Costs Known questioned costs of $1,173,864 were identified, as detailed in Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure documentation will be maintained and made available for audit and comply with the grant agreement and the Activities Allowed or Unallowed, the Allowable Costs/Cost Principles, and the Period of Performance compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2022-004 PERIOD OF PERFORMANCE Federal Program Information: Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.309 states that “a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance.” Condition: During our testing of period of performance, it was noted that for 13 of 25 transactions tested, proper supporting documentation could not be provided. Additionally, for 16 of 25 transactions tested, there was no evidence of proper review and approval of the transactions. Questioned Costs: $15,158 – Assistance Listing #17.258/#17.259/#17.278 Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board did not have proper internal controls in place to ensure that proper supporting documentation was maintained for all transactions, and that all transactions were properly reviewed and approved prior to payment. Effect: The Board could have had expenditures that were outside the proper period of performance of the grant. Recommendation: We recommend that the Board implement internal controls and policies to ensure that supporting documentation is maintained for all transactions, and that a member of management who is knowledgeable of the period of performance is reviewing and approving all transactions prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2022-004 PERIOD OF PERFORMANCE Federal Program Information: Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.309 states that “a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance.” Condition: During our testing of period of performance, it was noted that for 13 of 25 transactions tested, proper supporting documentation could not be provided. Additionally, for 16 of 25 transactions tested, there was no evidence of proper review and approval of the transactions. Questioned Costs: $15,158 – Assistance Listing #17.258/#17.259/#17.278 Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board did not have proper internal controls in place to ensure that proper supporting documentation was maintained for all transactions, and that all transactions were properly reviewed and approved prior to payment. Effect: The Board could have had expenditures that were outside the proper period of performance of the grant. Recommendation: We recommend that the Board implement internal controls and policies to ensure that supporting documentation is maintained for all transactions, and that a member of management who is knowledgeable of the period of performance is reviewing and approving all transactions prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2022-004 PERIOD OF PERFORMANCE Federal Program Information: Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.309 states that “a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance.” Condition: During our testing of period of performance, it was noted that for 13 of 25 transactions tested, proper supporting documentation could not be provided. Additionally, for 16 of 25 transactions tested, there was no evidence of proper review and approval of the transactions. Questioned Costs: $15,158 – Assistance Listing #17.258/#17.259/#17.278 Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board did not have proper internal controls in place to ensure that proper supporting documentation was maintained for all transactions, and that all transactions were properly reviewed and approved prior to payment. Effect: The Board could have had expenditures that were outside the proper period of performance of the grant. Recommendation: We recommend that the Board implement internal controls and policies to ensure that supporting documentation is maintained for all transactions, and that a member of management who is knowledgeable of the period of performance is reviewing and approving all transactions prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2022-004 PERIOD OF PERFORMANCE Federal Program Information: Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.309 states that “a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance.” Condition: During our testing of period of performance, it was noted that for 13 of 25 transactions tested, proper supporting documentation could not be provided. Additionally, for 16 of 25 transactions tested, there was no evidence of proper review and approval of the transactions. Questioned Costs: $15,158 – Assistance Listing #17.258/#17.259/#17.278 Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board did not have proper internal controls in place to ensure that proper supporting documentation was maintained for all transactions, and that all transactions were properly reviewed and approved prior to payment. Effect: The Board could have had expenditures that were outside the proper period of performance of the grant. Recommendation: We recommend that the Board implement internal controls and policies to ensure that supporting documentation is maintained for all transactions, and that a member of management who is knowledgeable of the period of performance is reviewing and approving all transactions prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2022-004 PERIOD OF PERFORMANCE Federal Program Information: Federal Agency and Program Name, Federal Assistance Listing Number U.S. Department of Labor, WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” 2 CFR 200.309 states that “a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance.” Condition: During our testing of period of performance, it was noted that for 13 of 25 transactions tested, proper supporting documentation could not be provided. Additionally, for 16 of 25 transactions tested, there was no evidence of proper review and approval of the transactions. Questioned Costs: $15,158 – Assistance Listing #17.258/#17.259/#17.278 Context: Total federal expenditures for the WIOA Cluster were $3,927,799 for the year ended June 30, 2022. Cause: The Board did not have proper internal controls in place to ensure that proper supporting documentation was maintained for all transactions, and that all transactions were properly reviewed and approved prior to payment. Effect: The Board could have had expenditures that were outside the proper period of performance of the grant. Recommendation: We recommend that the Board implement internal controls and policies to ensure that supporting documentation is maintained for all transactions, and that a member of management who is knowledgeable of the period of performance is reviewing and approving all transactions prior to payment. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
Finding Number 2022-007 Prior Year Finding Number N/A Compliance Requirement: Period of Performance Program: U.S. Department of Education Special Education-Grants for Infants and Families ALN #: 84.181A Award #: 210299, 220134 Award Period: 07/01/2020 – 09/30/2021 07/01/2021 - 09/30/2022 Criteria – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. 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 (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition – We sampled and selected 7 out of 21 expenditures and noted 3 expenditures were not properly reviewed. For compliance with period of performance requirements; the three transactions were incurred before the beginning of the period of performance for the respective grants. Questioned Costs – Not determinable. Context – This is a condition identified per review of the School System compliance with the specified requirements using a statistically valid sample. The known amount of the 3 transactions incurred outside the grant period amounted to $16,302. The total amount of the 7 samples selected was $52,039. The total amount of the 21 expenditures was $229,430. Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding. Cause – The School System does not appear to have adequate policies and procedures in place to ensure compliance with the required period of performance stipulations. Recommendation – We recommend that the School System strengthen its processes with respect to setting up and charging expenditures between various grant awards. We also recommend that DOE enhance its review process to properly determine the activities of each grant relative to the appropriate period of performance. Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The Infants and Toddlers Supervisor will conduct monthly reviews of outstanding purchase orders in Oracle, addressing issues promptly with the Business Operation Officer/Financial Analyst. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number 2022-007 Prior Year Finding Number N/A Compliance Requirement: Period of Performance Program: U.S. Department of Education Special Education-Grants for Infants and Families ALN #: 84.181A Award #: 210299, 220134 Award Period: 07/01/2020 – 09/30/2021 07/01/2021 - 09/30/2022 Criteria – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. 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 (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition – We sampled and selected 7 out of 21 expenditures and noted 3 expenditures were not properly reviewed. For compliance with period of performance requirements; the three transactions were incurred before the beginning of the period of performance for the respective grants. Questioned Costs – Not determinable. Context – This is a condition identified per review of the School System compliance with the specified requirements using a statistically valid sample. The known amount of the 3 transactions incurred outside the grant period amounted to $16,302. The total amount of the 7 samples selected was $52,039. The total amount of the 21 expenditures was $229,430. Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding. Cause – The School System does not appear to have adequate policies and procedures in place to ensure compliance with the required period of performance stipulations. Recommendation – We recommend that the School System strengthen its processes with respect to setting up and charging expenditures between various grant awards. We also recommend that DOE enhance its review process to properly determine the activities of each grant relative to the appropriate period of performance. Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The Infants and Toddlers Supervisor will conduct monthly reviews of outstanding purchase orders in Oracle, addressing issues promptly with the Business Operation Officer/Financial Analyst. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
2022-002: U.S. Department of the TreasuryCoronavirus Relief Fund (CRF)COVID-19 ? Supplemental Coronavirus Relief Funding for School Districts,CFDA 21.019Period of Performance - NoncomplianceGrant AwardNumber:21-340-07000 passed through the State of Nevada Department of Education.Criteria: The OMB Compliance Supplement requires that charges to federal awardsconsist of only allowable costs incurred during the approved budget period of afederal award?s period of performance and any costs incurred before the federalawarding agency or pass-through entity made the federal award that wereauthorized by the federal awarding agency or pass-through entity (2 CFRsections 200.308 and 200.309.Condition, Cause,and Effect/Potential Effect:While the District?s expenditures for the program are consistent with the March1, 2020 through December 31, 2021 Period of Performance for this federalprogram, the expenditures charged occurred prior to the date of sub-grant awardprovided by the State of Nevada Department of Education. The subgrant awardstates that the Period of Performance for the Sub-grant award would beDecember 10, 2021 ? December 31, 2021, and was signed by the pass-throughentity on December 21, 2021. Prior to acceptance, the District informed thepass-through entity that they intended to use the funds as reimbursement forcosts incurred during July through October of 2021, and pass-through entitypersonnel verbally assured District management that this would be acceptable.However, the pass-through entity did not amend the sub-grant period ofperformance, resulting in non-compliance with the sub-grant award.Questioned Costs: None noted.Context: Based on a nonstatistical sample of all costs charged to the program, it wasfound that all costs were incurred prior to the sub-grant award period. This wasan isolated instance resulting from a unique situation that arose and was out ofthe District?s control, and is not the result of a systematic problem.Repeat Findingfrom Prior Year: NoRecommendation: We recommend that the District obtain written documentation of any promisedrevisions to sub-grant awards prior to expending funds from the pass-throughentity in the future.Views ofResponsibleOfficials:Management agrees with this finding, however, since this was an un-correctedadministrative error on the part of the pass-through entity, and not due to actionsof District management, we were not able to avoid spending outside the narrowsub-grant?s period of performance.
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Finding Number: 2022-004Prior Year Finding: NoFederal Agency: U.S. Department of EducationFederal Program: COVID-19 - Elementary and Secondary Schools EmergencyRelief Fund (ESSER)Assistance Listing: 84.425C, D, U, WPass-Through Entity: Maryland State Department of EducationPass-Through AwardNumber and Period:201787-01 (3/13/20 ? 9/30/22)Compliance Requirement: Allowable Costs/Cost PrinciplesType of Finding Significant Deficiency in Internal Control over Compliance,Other MattersCriteria or specific requirement:Compliance: Per 2 CFR section 403, except where otherwise authorized by statute, costs must meetthe following general criteria in order to be allowable under Federal awards:(a) Be necessary and reasonable for the performance of the Federal award and be allocablethereto under these principles.(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award asto types or amount of cost items.(c) Be consistent with policies and procedures that apply uniformly to both federally-financed andother activities of the non-Federal entity.(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a directcost if any other cost incurred for the same purpose in like circumstances has been allocated tothe Federal award as an indirect cost.(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, forstate and local governments and Indian tribes only, as otherwise provided for in this part.(f) Not be included as a cost or used to meet cost sharing or matching requirements of any otherfederally-financed program in either the current or a prior period. See also ? 200.306(b).(g) Be adequately documented. See also ?? 200.300 through 200.309 of this part.(h) Cost must be incurred during the approved budget period. The Federal awarding agency isauthorized, at its discretion, to waive prior written approvals to carry forward unobligatedbalances to subsequent budget periods pursuant to ? 200.308(e)(3). Frequently Asked Question C-16 for Elementary and Secondary School Emergency Relief Programs(ESSER), dated May 2021, states in part, that when an LEA has other means of providing for foodservices, such as through the U.S. Department of Agriculture (USDA) or other Federal programs, theDepartment encourages LEAs to use those Federal funds with the specific purpose of providing foodservices to students prior to using ESSER or GEER funds for this purpose.Control ? Per 2 CFR section 200.303(a), a non-federal entity must: Establish and maintain effectiveinternal control over the federal award that provides reasonable assurance that the non-federal entity ismanaging the federal award in compliance with federal statutes, regulations, and the terms andconditions of the federal award. These internal controls should comply with the guidance in "Standardsfor Internal Control in the Federal Government" issued by the Comptroller General of the United Statesor the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizationsof the Treadway Commission (COSO).Condition/Context:The Board charged $3,059,646 to the food service fund to cover salary costs. ESSER programrequirements allow salary costs to be charged to the program only if other Federal funds are notavailable to cover additional labor costs associated with serving meals to students during the pandemicor for other COVID-19 related expenses. The reimbursement rate under the Child Nutrition Cluster(CNC) was sufficient to cover the total costs of operating the food service program for the fiscal year.Since Federal program funds were available to cover these costs under the CNC, the portion chargedto ESSER is unallowable.Questioned Costs:$3,059,646Cause:The Board's internal control processes did not prevent salary costs from being charged to both CNCand ESSER.Effect:The Board charged costs to the program when the expenditures had also been charged to CNC.Recommendation:We recommend that the Board review its policies and procedures to verify that controls are in place toensure expenditures are not reimbursed under more than one Federal Program.Views of responsible officials:Management agrees with the finding.
Reference Number:2022-021Prior Year Finding:NoFederal Agency:Department of Health and Human ServicesState Agency:Department of Children and FamiliesFederal Program:Social Services Block GrantAssistance Listing Number:93.667Award Number and Year:G-2200NJSOSR (10/1/2021 ? 3/30/2023)Compliance Requirement:Period of PerformanceType of FindingSignificant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance ? 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Social Services Block Grant funds must be expended by the state in the fiscal year allotted or in the succeeding fiscal year.Control ? Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Children and Families (Department) charged costs to the program that were incurred outside of the grant award?s period of performance.Context:Four of forty expenditure transactions selected for testing, totaling $842, were incurred prior to the award start date of October 1, 2021.Questioned costs:$842, the total of expenditures charged to the program that were incurred outside of the grant award?s period of performance.Cause:Accounting staff identified and charged program costs to the incorrect grant. The Department?s review process did not detect the errors nor take timely corrective action.Effect:The Department was not compliant with the grant?s period of performance which could result in the grantor?s disallowance of the costs.Recommendation:We recommend that the Department review and enhance its procedures and controls to ensure that expenditures charged to the program are incurred within the grant?s period of performance.Views of responsible officials:The Department of Children and Families (DCF) will review and enhance its procedures and controls to ensure that expenditures charged to the program are incurred within each grant award?s specified period of performance.Further, as the federal SSBG grant award cited has a period of performance that remains open through September 2023, DCF has adjusted the four transactions that were posted incorrectly to another available funding source and ensured that all transactions presently recorded are now in compliance and within the specified period of performance.
Reference Number:2022-024Prior Year Finding:NoFederal Agency:Social Security AdministrationState Agency:Department of Labor and Workforce DevelopmentFederal Program:Disability Insurance/SSI ClusterAssistance Listing Number:96.001Award Number and Year:04-2204NJD100 (10/1/2021 ? 3/30/2023), 04-2104NJD100 (10/1/2020 ? 3/30/2022), 04-2004NJD100 (10/1/2019 ? 3/30/2021)Compliance Requirement:Period of PerformanceType of FindingSignificant Deficiency in Internal Control Over Compliance, Other MattersCriteria or specific requirement:Compliance ? 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods.Control ? Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Labor and Workforce Development (Department) charged costs to the program that were incurred outside of the grant award?s period of performance.Context:Two of six expenditure transactions selected for testing, totaling $435, were incurred prior to the award start date of October 1, 2021.Questioned costs:$435, the total of expenditures charged to the program that were incurred outside of the grant?s period of performance.Cause:Accounting staff identified and charged program costs to the incorrect grant. The Program?s review process did not detect the errors nor take timely corrective action.Effect:The Department was not compliant with the grant?s period of performance which could result in the grantor?s disallowance of the costs.Recommendation:We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant?s period of performance.Views of responsible officials:The New Jersey Department of Labor and Workforce Development (DLWD) has a policy in place for processing tuition reimbursements that are performed by the Department?s Accounts Payable unit. The policy was reviewed by the Office of Finance & Accounting (F&A) and internal control procedures were enhanced to ensure that fiscal cutoff measures were appropriately addressed. Tuition reimbursement procedures include having the requests forwarded to the responsible Supervising Analyst in the Appropriations/Accounting unit for final review and approval to ensure the proper fiscal period is charged. The correcting transactions were completed during the Single Audit timeframe to remediate the findings by charging and reimbursing the proper fiscal year accounts. The DLWD will continue its efforts to ensure compliance and that all charges applied to Federal awards are within the specified period of performance going forward.
Finding 2022-001- Activities Allowed or Unallowed, Allowable Costs- Significant Deficiency Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No.: 21.027 Federal Agency: Department of the Treasury ? Pass-through from the State of California Award No.: WWID 4SSO10370 & CA 1910156 Award Year: Fiscal year 2021-2022 Category of Finding: Activities Allowed or Unallowed, Allowable Costs Criteria or Specific Requirement: Allowable Costs - 2 CFR Part 200.403 Factors affecting allowability of costs except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also ? 200.306(b). (g) Be adequately documented. See also ?? 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3). Per California Water and Wastewater Arrearage Payment Program Guidelines amended on January 19, 2022, providers that accrued residential and commercial customer arrearages during the COVID-19 pandemic bill relief period (March 4, 2020 through June 15, 2021) are eligible for the water and wastewater arrearages funding. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The City did not have an effective system of internal control in place to ensure the correct COVID-19 pandemic relief period was applied to identify eligible customers to have their bills paid with federal grant funds. Context: Crowe selected a total of 60 payment transactions, consisting of 30 water bills and 30 wastewater bills that were included in the arrearage program. We noted that one of the water bills selected for testing had a service date from June 28, 2021 in the amount $77.88. Upon further discussion with City management we noted the City applied the incorrect pandemic relief period to the program. Instead of a date of June 15, 2021, the City was using June 30, 2021 as the cutoff date. Management subsequently reviewed the entire population of the bills and quantified that there were 93 water bills with aggregate amount of $20,199 and 81 wastewater bills with aggregate amount of $15,331 ineligible for the funding. Cause: The City applied the incorrect pandemic relief period to the program. Instead of a date of June 15, 2021, the City was using June 30, 2021 as the cutoff date. Effect or Potential Effect: There were 93 water bills with totaled amount of $20,199 and 81 wastewater bills with totaled amount of $15,331 ineligible for the funding. Questioned Costs: $35,530 Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that the City implement internal controls to review the eligibility period for water and wastewater arrearages funding to identify the correct eligible applicants prior to disbursement. Views of Responsible Officials: Payments applied to the 93 water bills and 81 wastewater bills will be reversed on the customer?s accounts. A notice will be issued to customers via mail and email (where possible) of the discrepancy. The funds will be returned to the State pursuant to their outlined procedures. Moving forward, the City will ensure that there is a multi-layered approval process to review the eligibility period of any State funding to identify the correct eligible applicants prior to disbursement. For future funding related to water and/or waster bills, the list of eligible applicants will be compiled by an analyst within the department and will be reviewed by the Revenue Services Manager and Assistant Finance Director prior to disbursement.
Block Grants for Prevention and Treatment of Substance Abuse ALN No. 93.959 U.S. Department of Health and Human Services Opioid STR ALN No. 93.788 U.S. Department of Health and Human Services Criteria or Specific Requirement – Activities Allowed and Unallowed and Cost Principles – 2 CFR Part 200, Subpart E, and Period of Performance – 2 CFR sections 200.308, 200.309, and 200.403(h) Condition – A sample of 80 expenditures were selected from each of the following populations: • ALN No. 93.959 – 1,839 items totaling $1,243,944 • ALN No. 93.788 – 1,502 items totaling $2,285,983 The samples were not, and are not intended to be, statistically valid. Of the 80 expenditures tested from each grant program, the following were determined to lack appropriate supporting documentation to support being charged to grant program: • ALN No. 93.959 - 51 items totaling $26,145, including projected errors over the total population totaling $348,063 • ALN No. 93.788 - 6 items totaling $18,183, including projected errors over the total population totaling $165,074 The Organization did not have adequate supporting documentation demonstrating actual time and effort reporting and lacked evidence of supporting invoices. Cause – The Organization charged budgeted percentages to the grant programs without a system in place to monitor and track that actual time and effort was consistent with budgeted percentages. In addition, the Organization charged expenditures to the grant programs without evidence of supporting invoices. Effect or potential effect – Costs charged to the grant programs could have varied from actual time and effort. In addition, costs charged to the grant could not be supported by actual invoices. Questioned costs – • ALN No. 93.959 - $26,145 • ALN No. 93.788 - $18,183 Context – The Organization did not have a reasonable methodology of allocating costs to these grant programs and did not maintain proper supporting invoices. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – Management should implement policies and procedures that strengthen internal control over compliance in relation to activities allowed and cost principles. The policy and procedure should be designed to ensure that a reasonable allocation methodology is implemented and followed or that time and effort is certified by the employee on a regular basis. In addition, management should implement a document retention policy consistent with 2 CFR 200.334.
Block Grants for Prevention and Treatment of Substance Abuse ALN No. 93.959 U.S. Department of Health and Human Services Opioid STR ALN No. 93.788 U.S. Department of Health and Human Services Criteria or Specific Requirement – Activities Allowed and Unallowed and Cost Principles – 2 CFR Part 200, Subpart E, and Period of Performance – 2 CFR sections 200.308, 200.309, and 200.403(h) Condition – A sample of 80 expenditures were selected from each of the following populations: • ALN No. 93.959 – 1,839 items totaling $1,243,944 • ALN No. 93.788 – 1,502 items totaling $2,285,983 The samples were not, and are not intended to be, statistically valid. Of the 80 expenditures tested from each grant program, the following were determined to lack appropriate supporting documentation to support being charged to grant program: • ALN No. 93.959 - 51 items totaling $26,145, including projected errors over the total population totaling $348,063 • ALN No. 93.788 - 6 items totaling $18,183, including projected errors over the total population totaling $165,074 The Organization did not have adequate supporting documentation demonstrating actual time and effort reporting and lacked evidence of supporting invoices. Cause – The Organization charged budgeted percentages to the grant programs without a system in place to monitor and track that actual time and effort was consistent with budgeted percentages. In addition, the Organization charged expenditures to the grant programs without evidence of supporting invoices. Effect or potential effect – Costs charged to the grant programs could have varied from actual time and effort. In addition, costs charged to the grant could not be supported by actual invoices. Questioned costs – • ALN No. 93.959 - $26,145 • ALN No. 93.788 - $18,183 Context – The Organization did not have a reasonable methodology of allocating costs to these grant programs and did not maintain proper supporting invoices. Identification as a repeat finding, if applicable – Not a repeat finding Recommendation – Management should implement policies and procedures that strengthen internal control over compliance in relation to activities allowed and cost principles. The policy and procedure should be designed to ensure that a reasonable allocation methodology is implemented and followed or that time and effort is certified by the employee on a regular basis. In addition, management should implement a document retention policy consistent with 2 CFR 200.334.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Compliance Requirement: Period of Performance Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance. Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance. Questioned Costs: Under the reportable limit Context: For 1 of the 4 transactions tested was outside the period of performance. Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance. Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001. Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Compliance Requirement: Period of Performance Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance. Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance. Questioned Costs: Under the reportable limit Context: For 1 of the 4 transactions tested was outside the period of performance. Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance. Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001. Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Compliance Requirement: Period of Performance Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance. Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance. Questioned Costs: Under the reportable limit Context: For 1 of the 4 transactions tested was outside the period of performance. Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance. Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001. Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Compliance Requirement: Period of Performance Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance. Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance. Questioned Costs: Under the reportable limit Context: For 1 of the 4 transactions tested was outside the period of performance. Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance. Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001. Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Compliance Requirement: Period of Performance Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance. Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance. Questioned Costs: Under the reportable limit Context: For 1 of the 4 transactions tested was outside the period of performance. Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance. Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001. Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Compliance Requirement: Period of Performance Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance. Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance. Questioned Costs: Under the reportable limit Context: For 1 of the 4 transactions tested was outside the period of performance. Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance. Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001. Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Compliance Requirement: Period of Performance Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance. Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance. Questioned Costs: Under the reportable limit Context: For 1 of the 4 transactions tested was outside the period of performance. Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance. Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001. Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Compliance Requirement: Period of Performance Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance. Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance. Questioned Costs: Under the reportable limit Context: For 1 of the 4 transactions tested was outside the period of performance. Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance. Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001. Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Compliance Requirement: Period of Performance Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance. Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance. Questioned Costs: Under the reportable limit Context: For 1 of the 4 transactions tested was outside the period of performance. Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance. Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001. Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: Department of Education Federal Program: Special Education Cluster Pass-Through Agency: Massachusetts State Department of Elementary and Secondary Education Pass-Through Number(s): Various – See Schedule of Expenditures of Federal Awards Assistance Listing Numbers: 84.027, 84.173 Type of Finding: • Significant Deficiency in Internal Control Over Compliance • Other Matters Compliance Requirement: Period of Performance Criteria or specific requirement: 2 CFR Part 200, 200.309 states that a non-federal agency may charge to the federal award only allowable costs incurred during the period of performance. Condition: The District did not have adequate controls designed to ensure expenditures charged to the grant were incurred during the period of performance. Questioned Costs: Under the reportable limit Context: For 1 of the 4 transactions tested was outside the period of performance. Cause: Procedures are not in place to ensure expenditures charged to the grant were incurred during the period of performance. Effect: The expenditures incurred prior to and subsequent to period of performance dates are subject to disallowance and are considered questioned costs. Repeat Finding: The finding is a repeat of the finding in the immediate prior year Prior year finding number was 2021-001. Recommendation: We recommend procedures be implemented to ensure that all costs charged to the grant are incurred within the grant period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Finding No. 2022–007 – Activities Allowed or Unallowed, Eligible Uses – FEMA Federal Program ALN 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Program Name of Federal Agency U.S. Department of Homeland Security Pass-through Entity Central Office of Recovery, Reconstruction and Resiliency (COR3) Category Non-compliance / Material weakness in internal controls over compliance Compliance Requirement Activities Allowed or Unallowed, Eligible Uses Criteria As per 2 CFR section 200.403(g), except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: • Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. • Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. • Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. • Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. • Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. • Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also § 200.306(b). • Be adequately documented. See also §§ 200.300 through 200.309 of this part. • Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3). Condition During the closeout procedures, the Central Office of Recovery, Reconstruction and Resiliency (COR3) office performed a 100% validation on Rental Equipment, supporting documents including contract summary record, invoices, and proofs of payment. As a result of the validation, the total validated amount is $979,259 from an original amount of $1,260,775 submitted by the Corporation for reimbursement. Cause The Corporation claimed ineligible days in rent of equipment, certain invoices were claimed at a greater monthly rate, various expenses were claimed using retroactive memorandum of necessity as well as other transactions were found to not be eligible due to non-compliance with Puerto Rican Contract law, failing to comply with the proper documentation as required by the regulation. Effect The Corporation has to return a total amount of $281,516 due to the unallowed activities that were claimed to the fund. Questioned Cost The known questioned cost was calculated by the amount deemed to be unallowable activity of $281,516. Context • An amount of $26,127 was deducted from invoice #16307820 due to the dates 9/3/18 to 9/15/18 that falls in the 100% cost share." This amount was claimed under a different PW. • For chillers, invoice 16307877 was partially covered (15 days eligible), invoice 16308069 was partially covered (12 days eligible), and invoice 16308131 was partially covered (14 days eligible) due to the service order execution date. • For generators, invoices 16307884, 16307953, 16308033, 16308092, 16308146, 16308207, 16308270, 16308318, 16308357, 16308402, 16308449 and 16308476 were partially covered due to the maximum contract amount. • For generators, invoices 16307820, 16308622, 16308665, and 16308706 were found to not be eligible for reimbursement due to both retroactive execution as well as non-compliance with Puerto Rican Contract law. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation The management of the Corporation should reinforce its procedures of the administration of federal funds to ensure the compliance with the requirements with each program. Also, the Corporation should establish communication with the Central Office of Recovery, Reconstruction and Resiliency in order to obtain instructions for the correction of the non-compliance event and the related questioned cost. Views of responsible officials and planned corrective actions The Corporation’s management and responsible officers agree with this finding. Please refer to the corrective action plan section for the Corporation’s response on pages 89 to 98.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge 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 (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.