Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - 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 - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - 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 - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - 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 - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - 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 - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - 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 - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Federal Agency: U. S. Department of Health and Human Services Federal Program Name: Research and Development Cluster Assistance Listing Number: 93.323, 93.847 Federal Award Identification Number and Year: G231006 (23/24), R01DK108054 (23/24) Pass-Through Agency: WV Department of Health and Human Resources Pass-Through Number(s): G231006 Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal awards 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. Condition: In a sample of transactions that were in the expense detail supporting the total federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA), transactions were identified as being incurred after the end date of the period of availability. Questioned costs: $3,320 Context: In a sample size of twenty-eight expenditure transactions, five were incurred after the end date of the period of availability. Cause: Four of the exceptions were the result of the department administering the grant not submitting a revised internal form to update the funding source. These transactions were not included on the final invoice to the awarding agency but were included in the SEFA. One of the exceptions was the result of clerical entry error. • • Effect: Amounts are included on the SEFA for the fiscal period ended June 30, 2024, that were incurred after the end date of the period of performance. Repeat finding: No. Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U. S. Department of Health and Human Services Federal Program Name: Research and Development Cluster Assistance Listing Number: 93.323, 93.847 Federal Award Identification Number and Year: G231006 (23/24), R01DK108054 (23/24) Pass-Through Agency: WV Department of Health and Human Resources Pass-Through Number(s): G231006 Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal awards 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. Condition: In a sample of transactions that were in the expense detail supporting the total federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA), transactions were identified as being incurred after the end date of the period of availability. Questioned costs: $3,320 Context: In a sample size of twenty-eight expenditure transactions, five were incurred after the end date of the period of availability. Cause: Four of the exceptions were the result of the department administering the grant not submitting a revised internal form to update the funding source. These transactions were not included on the final invoice to the awarding agency but were included in the SEFA. One of the exceptions was the result of clerical entry error. • • Effect: Amounts are included on the SEFA for the fiscal period ended June 30, 2024, that were incurred after the end date of the period of performance. Repeat finding: No. Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U. S. Department of Health and Human Services Federal Program Name: Research and Development Cluster Assistance Listing Number: 93.323, 93.847 Federal Award Identification Number and Year: G231006 (23/24), R01DK108054 (23/24) Pass-Through Agency: WV Department of Health and Human Resources Pass-Through Number(s): G231006 Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal awards 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. Condition: In a sample of transactions that were in the expense detail supporting the total federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA), transactions were identified as being incurred after the end date of the period of availability. Questioned costs: $3,320 Context: In a sample size of twenty-eight expenditure transactions, five were incurred after the end date of the period of availability. Cause: Four of the exceptions were the result of the department administering the grant not submitting a revised internal form to update the funding source. These transactions were not included on the final invoice to the awarding agency but were included in the SEFA. One of the exceptions was the result of clerical entry error. • • Effect: Amounts are included on the SEFA for the fiscal period ended June 30, 2024, that were incurred after the end date of the period of performance. Repeat finding: No. Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U. S. Department of Health and Human Services Federal Program Name: Research and Development Cluster Assistance Listing Number: 93.323, 93.847 Federal Award Identification Number and Year: G231006 (23/24), R01DK108054 (23/24) Pass-Through Agency: WV Department of Health and Human Resources Pass-Through Number(s): G231006 Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal awards 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. Condition: In a sample of transactions that were in the expense detail supporting the total federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA), transactions were identified as being incurred after the end date of the period of availability. Questioned costs: $3,320 Context: In a sample size of twenty-eight expenditure transactions, five were incurred after the end date of the period of availability. Cause: Four of the exceptions were the result of the department administering the grant not submitting a revised internal form to update the funding source. These transactions were not included on the final invoice to the awarding agency but were included in the SEFA. One of the exceptions was the result of clerical entry error. • • Effect: Amounts are included on the SEFA for the fiscal period ended June 30, 2024, that were incurred after the end date of the period of performance. Repeat finding: No. Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U. S. Department of Health and Human Services Federal Program Name: Research and Development Cluster Assistance Listing Number: 93.323, 93.847 Federal Award Identification Number and Year: G231006 (23/24), R01DK108054 (23/24) Pass-Through Agency: WV Department of Health and Human Resources Pass-Through Number(s): G231006 Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal awards 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. Condition: In a sample of transactions that were in the expense detail supporting the total federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA), transactions were identified as being incurred after the end date of the period of availability. Questioned costs: $3,320 Context: In a sample size of twenty-eight expenditure transactions, five were incurred after the end date of the period of availability. Cause: Four of the exceptions were the result of the department administering the grant not submitting a revised internal form to update the funding source. These transactions were not included on the final invoice to the awarding agency but were included in the SEFA. One of the exceptions was the result of clerical entry error. • • Effect: Amounts are included on the SEFA for the fiscal period ended June 30, 2024, that were incurred after the end date of the period of performance. Repeat finding: No. Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U. S. Department of Health and Human Services Federal Program Name: Substance Abuse and Mental Health Services Projects Assistance Listing Number: 93.243 Federal Award Identification Number and Year: H79TI080332 (23/24) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal awards 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. Condition: In a sample of transactions that were in the expense detail supporting the total federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA), transactions were identified as being incurred after the end date of the period of availability. Questioned costs: N/A Context: In a sample size of fourteen expenditure transactions, one was incurred after the end date of the period of availability. • • Cause: Transaction was related to a payroll period that began prior to the end date of the period of performance and ended after said date. Effect: Amounts are included on the SEFA for the fiscal period ended June 30, 2024, that were incurred after the end date of the period of performance. Repeat finding: No. Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U. S. Department of Health and Human Services Federal Program Name: Substance Abuse and Mental Health Services Projects Assistance Listing Number: 93.243 Federal Award Identification Number and Year: H79TI080332 (23/24) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal awards 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. Condition: In a sample of transactions that were in the expense detail supporting the total federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA), transactions were identified as being incurred after the end date of the period of availability. Questioned costs: N/A Context: In a sample size of fourteen expenditure transactions, one was incurred after the end date of the period of availability. • • Cause: Transaction was related to a payroll period that began prior to the end date of the period of performance and ended after said date. Effect: Amounts are included on the SEFA for the fiscal period ended June 30, 2024, that were incurred after the end date of the period of performance. Repeat finding: No. Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U. S. Department of Health and Human Services Federal Program Name: Substance Abuse and Mental Health Services Projects Assistance Listing Number: 93.243 Federal Award Identification Number and Year: H79TI080332 (23/24) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal awards 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. Condition: In a sample of transactions that were in the expense detail supporting the total federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA), transactions were identified as being incurred after the end date of the period of availability. Questioned costs: N/A Context: In a sample size of fourteen expenditure transactions, one was incurred after the end date of the period of availability. • • Cause: Transaction was related to a payroll period that began prior to the end date of the period of performance and ended after said date. Effect: Amounts are included on the SEFA for the fiscal period ended June 30, 2024, that were incurred after the end date of the period of performance. Repeat finding: No. Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U. S. Department of Health and Human Services Federal Program Name: Substance Abuse and Mental Health Services Projects Assistance Listing Number: 93.243 Federal Award Identification Number and Year: H79TI080332 (23/24) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal awards 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. Condition: In a sample of transactions that were in the expense detail supporting the total federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA), transactions were identified as being incurred after the end date of the period of availability. Questioned costs: N/A Context: In a sample size of fourteen expenditure transactions, one was incurred after the end date of the period of availability. • • Cause: Transaction was related to a payroll period that began prior to the end date of the period of performance and ended after said date. Effect: Amounts are included on the SEFA for the fiscal period ended June 30, 2024, that were incurred after the end date of the period of performance. Repeat finding: No. Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U. S. Department of Health and Human Services Federal Program Name: Substance Abuse and Mental Health Services Projects Assistance Listing Number: 93.243 Federal Award Identification Number and Year: H79TI080332 (23/24) Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal awards 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. Condition: In a sample of transactions that were in the expense detail supporting the total federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA), transactions were identified as being incurred after the end date of the period of availability. Questioned costs: N/A Context: In a sample size of fourteen expenditure transactions, one was incurred after the end date of the period of availability. • • Cause: Transaction was related to a payroll period that began prior to the end date of the period of performance and ended after said date. Effect: Amounts are included on the SEFA for the fiscal period ended June 30, 2024, that were incurred after the end date of the period of performance. Repeat finding: No. Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U. S. Department of Health and Human Services Federal Program Name: Research and Development Cluster Assistance Listing Number: 93.323, 93.847 Federal Award Identification Number and Year: G231006 (23/24), R01DK108054 (23/24) Pass-Through Agency: WV Department of Health and Human Resources Pass-Through Number(s): G231006 Award Period: July 1, 2023, to June 30, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Other Matters Criteria or specific requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal awards 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. Condition: In a sample of transactions that were in the expense detail supporting the total federal expenditures on the Schedule of Expenditures of Federal Awards (SEFA), transactions were identified as being incurred after the end date of the period of availability. Questioned costs: $3,320 Context: In a sample size of twenty-eight expenditure transactions, five were incurred after the end date of the period of availability. Cause: Four of the exceptions were the result of the department administering the grant not submitting a revised internal form to update the funding source. These transactions were not included on the final invoice to the awarding agency but were included in the SEFA. One of the exceptions was the result of clerical entry error. • • Effect: Amounts are included on the SEFA for the fiscal period ended June 30, 2024, that were incurred after the end date of the period of performance. Repeat finding: No. Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Views of responsible officials: There is no disagreement with the audit finding.
Finding number: 2024-011 Federal agency: U.S. Department of Education Pass-through agency: Commonwealth Department of Elementary and Secondary Education Program: Student Support and Academic Enrichment Program ALN #: 84.424 Award number: 0309-000548-2024-0035 Award year: September 12, 2023 to September 30, 2025 Finding: Internal Control and Compliance over Period of Performance Prior Year Finding: No Type of Finding: Material Weakness and Material Noncompliance Criteria Period of Performance 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. LEAs and SEAs must obligate funds during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. This maximum period includes a 15-month period of initial availability plus a 12-month period for carryover. Additionally, 2 CFR 200.303 indicates that non-Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our testing of period of performance associated with those expenditures charged to grant awards which began during fiscal year 2024 and cost transfers, we noted noncompliance for 2 expenditures out of a sample of 4. Per review of the underlying vendor invoices, the service period for these expenditures started prior to the award start date of September 12, 2023.Cause This appears to be due to an insufficient review of invoices to ensure the underlying services performed by vendors are within the grant awards outlined grant period. Effect Insufficient review of vendor invoices increases the risk of costs being charged to a grant award outside its approved budget period. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: $1,250,864 Recommendation We recommend that the Boston Public Schools (BPS) re-enforce its policies and procedures to ensure their review of expenditures charged to the award also includes a detailed review of the underlying vendor service period. View of Responsible Officials from the Auditee BPS will take a multi-step approach to ensuring accuracy of spending to the grant award period: 1. Reinforce our existing practice of ensuring that period of service is reflected on Purchase Orders, which it was for the PO’s in question. 2. Working with major suppliers to ensure they understand the grant funded nature of their program and the eligible dates of service, which are outlined on the Purchase Order 3. Review / Update training for our Accounts Payable team on ensuring that the period of service on an invoice matches the period of service on the Purchase Order 4. Review / Update training for our State & Federal Grants, Programs, and Compliance teams to ensure that expenses are reviewed before the end of the grant period to ensure compliance with federal regulations.
2024 -007 - Noncompliance with Period of Performance Requirements State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2021, 2022 Award Numbers: 80NSSC21M0165, DE-FE0031919 Compliance Requirement: Period of Performance Repeat Finding: No See Schedule of Findings and Questioned Costs for chart/table. Condition: UL Lafayette did not ensure that all expenses charged to federal Research and Development (R&D) awards complied with the period of performance requirements. From a population of 166 R&D grants with expenses totaling $6,720,454 and periods of performance starting or ending during the fiscal year ending June 30, 2024, a non-statistical sample of 17 grants was tested for compliance with period of performance requirements. For two (11.8%) of the 17 grants tested, expenses totaling $63,790 were identified as noncompliant with the period of performance requirements. One grant had expenses totaling $28,833 that were incurred after the period of performance. For the other grant, UL Lafayette failed to liquidate obligations totaling $34,957 incurred during the period of performance within 120 days after the end the period of performance as required by federal regulations. Criteria: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance [2 CFR sections 200.308, 200.309, and 200.403(h)]. Additionally, 2 CFR 200.344 states that the recipient must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the conclusion of the period of performance. Cause: UL Lafayette did not have sufficient internal controls to ensure that only expenses incurred during the period of performance were charged to R&D grants and that obligations were liquidated timely. Effect: Noncompliance with the period of performance requirements resulted in $63,790 in questioned costs and increases the risk that expenses could be disallowed and not reimbursed by the awarding agency. Recommendation: Management should strengthen their procedures and internal controls that are in place to ensure that all expenses incurred on federal R&D grants comply with the period of performance requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-62).
2024 -007 - Noncompliance with Period of Performance Requirements State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2021, 2022 Award Numbers: 80NSSC21M0165, DE-FE0031919 Compliance Requirement: Period of Performance Repeat Finding: No See Schedule of Findings and Questioned Costs for chart/table. Condition: UL Lafayette did not ensure that all expenses charged to federal Research and Development (R&D) awards complied with the period of performance requirements. From a population of 166 R&D grants with expenses totaling $6,720,454 and periods of performance starting or ending during the fiscal year ending June 30, 2024, a non-statistical sample of 17 grants was tested for compliance with period of performance requirements. For two (11.8%) of the 17 grants tested, expenses totaling $63,790 were identified as noncompliant with the period of performance requirements. One grant had expenses totaling $28,833 that were incurred after the period of performance. For the other grant, UL Lafayette failed to liquidate obligations totaling $34,957 incurred during the period of performance within 120 days after the end the period of performance as required by federal regulations. Criteria: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance [2 CFR sections 200.308, 200.309, and 200.403(h)]. Additionally, 2 CFR 200.344 states that the recipient must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the conclusion of the period of performance. Cause: UL Lafayette did not have sufficient internal controls to ensure that only expenses incurred during the period of performance were charged to R&D grants and that obligations were liquidated timely. Effect: Noncompliance with the period of performance requirements resulted in $63,790 in questioned costs and increases the risk that expenses could be disallowed and not reimbursed by the awarding agency. Recommendation: Management should strengthen their procedures and internal controls that are in place to ensure that all expenses incurred on federal R&D grants comply with the period of performance requirements. Management’s Response and Corrective Action Plan: Management concurred with the finding and outlined a plan of corrective action (B-62).
2024-007 – Period of Performance Federal Agency: National Science Foundation and U.S. Department of Education Federal Program Title: Research and Development Cluster Federal Assistance Listing Numbers: 84.017 and 47.081 Federal Award Identification Number and Year: Various Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: 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. Condition: Two grants were identified as having ended in a prior year but were still incurring expenditures that are included on the SEFA in fiscal year 2024. Questioned Costs: N/A Context: During the testing of the SEFA for the period, it was noted that two of the grants tested had end dates before the beginning of the fiscal year (7/1/2023) but had costs incurred and reported on the SEFA for fiscal year 2024. The University did not receive extensions on these grants. Cause: Internal controls ensuring that costs are not reported on the SEFA after the end of the period of performance were not functioning as designed. Effect: The current year SEFA included expenses that were incurred after the grant ended. Repeat Finding: No. Recommendation: We recommend that the University review and revise their current procedures in place and provide training to employees within the grant and finance functions related to the grant reconciliation and recording process to ensure expenses are reflected prior to the grant ending and recorded in the correct period on the SEFA. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-007 – Period of Performance Federal Agency: National Science Foundation and U.S. Department of Education Federal Program Title: Research and Development Cluster Federal Assistance Listing Numbers: 84.017 and 47.081 Federal Award Identification Number and Year: Various Award Period: 7/1/2023 – 6/30/2024 Type of Finding: Other Matters and Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: 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. Condition: Two grants were identified as having ended in a prior year but were still incurring expenditures that are included on the SEFA in fiscal year 2024. Questioned Costs: N/A Context: During the testing of the SEFA for the period, it was noted that two of the grants tested had end dates before the beginning of the fiscal year (7/1/2023) but had costs incurred and reported on the SEFA for fiscal year 2024. The University did not receive extensions on these grants. Cause: Internal controls ensuring that costs are not reported on the SEFA after the end of the period of performance were not functioning as designed. Effect: The current year SEFA included expenses that were incurred after the grant ended. Repeat Finding: No. Recommendation: We recommend that the University review and revise their current procedures in place and provide training to employees within the grant and finance functions related to the grant reconciliation and recording process to ensure expenses are reflected prior to the grant ending and recorded in the correct period on the SEFA. Views of Responsible Officials: There is no disagreement with the audit finding and the University is in the process of implementing corrective procedures.
2024-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Criteria: Per 2 CFR section 200.309 of the Uniform Guidance, a non-federal entity may charge to a Federal award only 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 that were authorized by the Federal awarding agency or pass-through entity. Condition: Costs were recorded for service periods prior to grant approval date. Cause: The District did not properly identify service periods for costs reported under grant. Effect: The District expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $155,246 Repeat Finding from Prior Year: No Recommendation: The District should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are within the approved grant period. Views of Responsible Official: Management agrees with the finding.
2024-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Criteria: Per 2 CFR section 200.309 of the Uniform Guidance, a non-federal entity may charge to a Federal award only 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 that were authorized by the Federal awarding agency or pass-through entity. Condition: Costs were recorded for service periods prior to grant approval date. Cause: The District did not properly identify service periods for costs reported under grant. Effect: The District expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $155,246 Repeat Finding from Prior Year: No Recommendation: The District should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are within the approved grant period. Views of Responsible Official: Management agrees with the finding.
2024-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Criteria: Per 2 CFR section 200.309 of the Uniform Guidance, a non-federal entity may charge to a Federal award only 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 that were authorized by the Federal awarding agency or pass-through entity. Condition: Costs were recorded for service periods prior to grant approval date. Cause: The District did not properly identify service periods for costs reported under grant. Effect: The District expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $155,246 Repeat Finding from Prior Year: No Recommendation: The District should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are within the approved grant period. Views of Responsible Official: Management agrees with the finding.
2024-001 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 Criteria: Per 2 CFR section 200.309 of the Uniform Guidance, a non-federal entity may charge to a Federal award only 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 that were authorized by the Federal awarding agency or pass-through entity. Condition: Costs were recorded for service periods prior to grant approval date. Cause: The District did not properly identify service periods for costs reported under grant. Effect: The District expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $155,246 Repeat Finding from Prior Year: No Recommendation: The District should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are within the approved grant period. Views of Responsible Official: Management agrees with the finding.
Finding No. 2024-003 Assistance Listing Program Title and Number: 64.033 Supportive Services for Veteran Families Criteria 2 CFR § 200.308, 200.309 and 200.403(h)) A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. Condition During period of performance testing for the Supportive Services for Veteran Families (SSVF) Program, eight instances were identified where expenses were incurred outside of the allowable timeframe. Cause This noncompliance may have resulted from inadequate controls to validate expense dates during approval and/or lack of staff training on period-of-performance requirements Effect There is an increased audit risk for federal fund misuse and a potential for unallowable expense reimbursement repayment. Recommendation 1. Implement pre-approval controls: Require date validation for all expenses against the award’s period of performance. 2. Conduct training: Educate staff on 2 CFR requirements and period-of-performance limitations. 3. Perform periodic reviews: Monitor compliance quarterly to detect outliers. Management’s Response Management agrees with this finding, see the Corrective Action Plan.
Assistance Listing Program Title and Number: Continuum of Care Program 14.267 Criteria 2 CFR § 200.308, 200.309 and 200.403(h)) A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. Condition During period of performance testing for the Continuum of Care Program two instances were identified where expenses were incurred outside of the allowable timeframe. The sample size was extended to address this deficiency, and no additional exceptions were noted. Cause This noncompliance may have resulted from inadequate controls to validate expense dates during approval and/or lack of staff training on period-of-performance requirements Effect There is an increased audit risk for federal fund misuse and a potential for unallowable expense reimbursement repayment. Recommendation 1. Implement pre-approval controls: Require date validation for all expenses against the award’s period of performance. 2. Conduct training: Educate staff on 2 CFR requirements and period-of-performance limitations. 3. Perform periodic reviews: Monitor compliance quarterly to detect outliers. Management’s Response Management agrees with this finding, see the Corrective Action Plan.
Federal Agency: Department of Health and Human Services Federal Program: Teenage Pregnancy Prevention Program Federal Assistance Listing Number(s): 93.297 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Compliance – Other Matters Criteria or Specific Requirement: According to 2 CFR § 200.309, costs must be incurred during the period of performance specified in the federal award. Costs incurred outside this period are unallowable unless explicitly authorized by the awarding agency. Condition: During testing, it was noted that costs totaling $6,933 were charged to the award outside the designated period of performance. Specifically, these costs were incurred before the start date of the award. Questioned Costs: $6,933 Context: Of the costs tested it was identified five of eight transactions sampled were incurred prior to the period of performance start date listed in the notification of award. The total dollar amount was $6,933 and related to payroll incurred prior to the start date of the award but paid after the start date. Cause: The Organization did not have adequate internal controls to ensure that costs were only charged within the period of performance. There was a lack of communication between the finance department and program managers regarding the start date of the award. Effect: Questioned costs were identified. Repeat Finding: No Recommendation: We recommend the Organization implement stronger internal controls to monitor the period of performance on its federal awards. This includes regular training for staff on compliance requirements and establishing clear communication channels between finance and program departments. Views of Responsible Official: There is no disagreement with the audit finding.
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 – 1,152 items totaling $1,077,416 • ALN No. 93.788 – 1,222 items totaling $2,537,080 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 - 41 items totaling $25,810, including projected errors over the total population totaling $191,145 • ALN No. 93.788 - 10 items totaling $72,347, including projected errors over the total population totaling $207,012 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 - $25,810 • ALN No. 93.788 - $72,347 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 – Repeat finding (see 2023-003) 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 – 1,152 items totaling $1,077,416 • ALN No. 93.788 – 1,222 items totaling $2,537,080 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 - 41 items totaling $25,810, including projected errors over the total population totaling $191,145 • ALN No. 93.788 - 10 items totaling $72,347, including projected errors over the total population totaling $207,012 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 - $25,810 • ALN No. 93.788 - $72,347 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 – Repeat finding (see 2023-003) 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 Health and Human Services Federal program title: Block Grants for Community Mental Health Services Assistance Listing Number: 93.958 Pass-Through Agency: Illinois Department of Human Services Pass-Through Number: 45CCB03514; 45CCB04278; 45CCB00648 Award Period: 07/01/2023 – 06/30/2024 Type of Finding: Material Weakness in Internal Control over Compliance and Immaterial Noncompliance Criteria or specific requirement: 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. Condition: Costs outside of the period of performance were charged to the grant. Questioned Costs: $7,311 Context: Four (4) of the twenty (20) transactions selected for testing. Cause: Oversight. Effect: The Organization may allocate unallowable costs to the federal grant. Repeat Finding: Yes, prior year finding number was 2023-004 Recommendation: Management should review and revise its process for allocating costs to federal grants to include additional layers of review and so that costs for which some or all are from outside of the period of performance, may be appropriately excluded from the federal grant. Views of responsible officials: There is no disagreement with the audit finding.
Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Period of Performance Significant Deficiency in Internal Control over Compliance Criteria: A good system of internal control includes an adequate system for ensuring all expenditures are properly recorded in the applicable federal grant period in accordance with 2 CFR 200.309. Condition: In our testing of period of performance, we noted one instance of a fiscal year 2023 expenditure recorded during fiscal year 2024 and therefore not allowable under the terms of the grant. Cause: Procedures are not in place to adequately identify period of performance requirements. Effect: A lack of internal controls over period of performance could result in recording expenditures in the improper grant period resulting in non-compliance with the provisions of applicable grant requirements. Questioned Costs: None reported. Context/Sampling: Nonstatistical sampling was used. Sample size was 40 of 255 transactions. and included $525,686 of $828,578 federal awards. Repeat Finding from Prior Year: No Recommendation: RAED should review internal control procedures to ensure federal expenditures are being properly recorded in appropriate grant periods. Views of Responsible Officials: There is no disagreement with the audit finding.
Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Period of Performance Significant Deficiency in Internal Control over Compliance Criteria: A good system of internal control includes an adequate system for ensuring all expenditures are properly recorded in the applicable federal grant period in accordance with 2 CFR 200.309. Condition: In our testing of period of performance, we noted one instance of a fiscal year 2023 expenditure recorded during fiscal year 2024 and therefore not allowable under the terms of the grant. Cause: Procedures are not in place to adequately identify period of performance requirements. Effect: A lack of internal controls over period of performance could result in recording expenditures in the improper grant period resulting in non-compliance with the provisions of applicable grant requirements. Questioned Costs: None reported. Context/Sampling: Nonstatistical sampling was used. Sample size was 40 of 255 transactions. and included $525,686 of $828,578 federal awards. Repeat Finding from Prior Year: No Recommendation: RAED should review internal control procedures to ensure federal expenditures are being properly recorded in appropriate grant periods. Views of Responsible Officials: There is no disagreement with the audit finding.
Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Period of Performance Significant Deficiency in Internal Control over Compliance Criteria: A good system of internal control includes an adequate system for ensuring all expenditures are properly recorded in the applicable federal grant period in accordance with 2 CFR 200.309. Condition: In our testing of period of performance, we noted one instance of a fiscal year 2023 expenditure recorded during fiscal year 2024 and therefore not allowable under the terms of the grant. Cause: Procedures are not in place to adequately identify period of performance requirements. Effect: A lack of internal controls over period of performance could result in recording expenditures in the improper grant period resulting in non-compliance with the provisions of applicable grant requirements. Questioned Costs: None reported. Context/Sampling: Nonstatistical sampling was used. Sample size was 40 of 255 transactions. and included $525,686 of $828,578 federal awards. Repeat Finding from Prior Year: No Recommendation: RAED should review internal control procedures to ensure federal expenditures are being properly recorded in appropriate grant periods. Views of Responsible Officials: There is no disagreement with the audit finding.
Department of Education, Passed through Minnesota Department of Education Federal Financial Assistance Listing 84.027/84.173 Special Education Cluster Period of Performance Significant Deficiency in Internal Control over Compliance Criteria: A good system of internal control includes an adequate system for ensuring all expenditures are properly recorded in the applicable federal grant period in accordance with 2 CFR 200.309. Condition: In our testing of period of performance, we noted one instance of a fiscal year 2023 expenditure recorded during fiscal year 2024 and therefore not allowable under the terms of the grant. Cause: Procedures are not in place to adequately identify period of performance requirements. Effect: A lack of internal controls over period of performance could result in recording expenditures in the improper grant period resulting in non-compliance with the provisions of applicable grant requirements. Questioned Costs: None reported. Context/Sampling: Nonstatistical sampling was used. Sample size was 40 of 255 transactions. and included $525,686 of $828,578 federal awards. Repeat Finding from Prior Year: No Recommendation: RAED should review internal control procedures to ensure federal expenditures are being properly recorded in appropriate grant periods. Views of Responsible Officials: There is no disagreement with the audit finding.
Information on the federal program: Subject: Special Education Cluster – Internal Controls Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027X Federal Award Numbers and Years (or Other Identifying Numbers): 22611-122-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Period of Performance Audit Finding: Material Weakness Criteria: 2 CFR section 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.309 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. Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the period of performance compliance requirement. Cause: The School Corporation's management had not developed a system of internal controls to ensure compliance with the period of performance requirement. The School Corporation did not have a design control in place to ensure that service provider invoices were paid before the required liquidation date. Effect: The failure to establish an effective internal control system placed the School Corporation at risk of noncompliance with the grant agreement and the compliance requirements. Questioned Costs: There were no questioned costs identified. Context: The School Corporation pays one hundred percent of its Special Education Cluster funding to one service provider. From review of the expense population, we noted 2 payments to the service provider where the service provider was not paid until after liquidation date of December 29, 2023. The School Corporation did not pay the service provider until April 30, 2024 for $258,488 for the services provided. Identification as a repeat finding: No. Recommendation: We recommend the School Corporation implement procedures to ensure the invoices are paid before the required liquidation date. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
2024-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Criteria: Per 2 CFR section 200.309 grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Per 2 CFR section 200.343(b) grant obligations must be liquidated not later than 120 calendar days after the end of the grant period. Condition: Costs were liquidated after 120 calendar days after the end of the grant period. Cause: The School was not aware of the 120 calendar day liquidation period. Effect: The Town expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $36,118.21 Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are liquidated within 120 calendar days after the end of the grant period. Views of Responsible Official: Management agrees with the finding.
2024-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Criteria: Per 2 CFR section 200.309 grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Per 2 CFR section 200.343(b) grant obligations must be liquidated not later than 120 calendar days after the end of the grant period. Condition: Costs were liquidated after 120 calendar days after the end of the grant period. Cause: The School was not aware of the 120 calendar day liquidation period. Effect: The Town expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $36,118.21 Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are liquidated within 120 calendar days after the end of the grant period. Views of Responsible Official: Management agrees with the finding.
2024-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Criteria: Per 2 CFR section 200.309 grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Per 2 CFR section 200.343(b) grant obligations must be liquidated not later than 120 calendar days after the end of the grant period. Condition: Costs were liquidated after 120 calendar days after the end of the grant period. Cause: The School was not aware of the 120 calendar day liquidation period. Effect: The Town expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $36,118.21 Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are liquidated within 120 calendar days after the end of the grant period. Views of Responsible Official: Management agrees with the finding.
2024-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Criteria: Per 2 CFR section 200.309 grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Per 2 CFR section 200.343(b) grant obligations must be liquidated not later than 120 calendar days after the end of the grant period. Condition: Costs were liquidated after 120 calendar days after the end of the grant period. Cause: The School was not aware of the 120 calendar day liquidation period. Effect: The Town expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $36,118.21 Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are liquidated within 120 calendar days after the end of the grant period. Views of Responsible Official: Management agrees with the finding.
2024-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Criteria: Per 2 CFR section 200.309 grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Per 2 CFR section 200.343(b) grant obligations must be liquidated not later than 120 calendar days after the end of the grant period. Condition: Costs were liquidated after 120 calendar days after the end of the grant period. Cause: The School was not aware of the 120 calendar day liquidation period. Effect: The Town expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $36,118.21 Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are liquidated within 120 calendar days after the end of the grant period. Views of Responsible Official: Management agrees with the finding.
2024-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Criteria: Per 2 CFR section 200.309 grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Per 2 CFR section 200.343(b) grant obligations must be liquidated not later than 120 calendar days after the end of the grant period. Condition: Costs were liquidated after 120 calendar days after the end of the grant period. Cause: The School was not aware of the 120 calendar day liquidation period. Effect: The Town expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $36,118.21 Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are liquidated within 120 calendar days after the end of the grant period. Views of Responsible Official: Management agrees with the finding.
2024-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Criteria: Per 2 CFR section 200.309 grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Per 2 CFR section 200.343(b) grant obligations must be liquidated not later than 120 calendar days after the end of the grant period. Condition: Costs were liquidated after 120 calendar days after the end of the grant period. Cause: The School was not aware of the 120 calendar day liquidation period. Effect: The Town expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $36,118.21 Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are liquidated within 120 calendar days after the end of the grant period. Views of Responsible Official: Management agrees with the finding.
2024-002 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Criteria: Per 2 CFR section 200.309 grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Per 2 CFR section 200.343(b) grant obligations must be liquidated not later than 120 calendar days after the end of the grant period. Condition: Costs were liquidated after 120 calendar days after the end of the grant period. Cause: The School was not aware of the 120 calendar day liquidation period. Effect: The Town expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $36,118.21 Repeat Finding from Prior Year: No Recommendation: The School should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are liquidated within 120 calendar days after the end of the grant period. Views of Responsible Official: Management agrees with the finding.
2024-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Criteria: Per 2 CFR section 200.309 grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Condition: Costs were charged to the grants for payroll and related benefits earned prior to the start of the grant period. Cause: Three grants were approved approximately sixty to ninety days after the start of the school year. Effect: The School expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $26,586 Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are within the period of performance for each award. Views of Responsible Official: Management agrees with the finding.
2024-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Criteria: Per 2 CFR section 200.309 grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Condition: Costs were charged to the grants for payroll and related benefits earned prior to the start of the grant period. Cause: Three grants were approved approximately sixty to ninety days after the start of the school year. Effect: The School expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $26,586 Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are within the period of performance for each award. Views of Responsible Official: Management agrees with the finding.
2024-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Criteria: Per 2 CFR section 200.309 grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Condition: Costs were charged to the grants for payroll and related benefits earned prior to the start of the grant period. Cause: Three grants were approved approximately sixty to ninety days after the start of the school year. Effect: The School expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $26,586 Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are within the period of performance for each award. Views of Responsible Official: Management agrees with the finding.
2024-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Criteria: Per 2 CFR section 200.309 grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Condition: Costs were charged to the grants for payroll and related benefits earned prior to the start of the grant period. Cause: Three grants were approved approximately sixty to ninety days after the start of the school year. Effect: The School expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $26,586 Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are within the period of performance for each award. Views of Responsible Official: Management agrees with the finding.
2024-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education Special Education Cluster (IDEA) – ALN 84.027 & 84.173 COVID-19 – Special Education Cluster (IDEA) – ALN 84.027X Criteria: Per 2 CFR section 200.309 grant funds may only be obligated upon the date of approval by the awarding agency through the end of the grant period. Condition: Costs were charged to the grants for payroll and related benefits earned prior to the start of the grant period. Cause: Three grants were approved approximately sixty to ninety days after the start of the school year. Effect: The School expended funds outside of the period of performance which resulted in questioned costs. Questioned Costs: $26,586 Repeat Finding from Prior Year: No. Recommendation: The School should implement procedures to properly monitor award performance dates to ensure that goods and services charged to federal grants are within the period of performance for each award. Views of Responsible Official: Management agrees with the finding.
Reference Number: 2024-007 Prior Year Finding: No Federal Agency: U.S. Department of Defense State Agency: Vermont State Military Department Federal Program: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing Number: 12.401 Award Number and Year: W912LN2421001 (10/1/2023 – 9/20/2024) 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: The Vermont State Military Department (Department) charged costs to the federal grant prior to the allowable start of the period of performance. Context: One of five transactions selected for testing was incurred prior to the award’s period of performance. The expense was for a transaction incurred in the month of September 2023 but the award’s period of performance began on 10/1/2023. Cause: The Department’s procedures were not operating sufficiently to ensure that expenditures charged to the program were incurred within the award’s period of performance. Internal controls did not prevent or detect the error. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Questioned costs: Below the reportable limit. Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Views of responsible officials: Management agrees with the finding.