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.
Reference Number: 2024-010 Prior Year Finding: 2023-008 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: Admin 24A55UI000063 (10/1/2023-12/31/2026), DUA 23A60UD000013 (7/14/2023 - 7/14/2026) 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 Department of Labor (Department) charged costs to the federal grant prior to the allowable start of the period of performance. Context: Sixty transactions were selected for testing and the following exceptions were noted: • Five of sixty transactions were charged to the award before the allowable period of performance. The grant award start date was October 1, 2023, but costs were incurred in July, August, and September 2023. Cause: The Department’s procedures and internal controls were not operating sufficiently to ensure that expenditures charged to the program 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. Questioned costs: $2,980, which represents the total incurred before the allowable period of performance. Recommendation: We recommend the Department review and enhance its procedures and controls to ensure that prior to charging costs to the program, they are incurred within an award’s allowable period of performance. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-010 Prior Year Finding: 2023-008 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: Admin 24A55UI000063 (10/1/2023-12/31/2026), DUA 23A60UD000013 (7/14/2023 - 7/14/2026) 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 Department of Labor (Department) charged costs to the federal grant prior to the allowable start of the period of performance. Context: Sixty transactions were selected for testing and the following exceptions were noted: • Five of sixty transactions were charged to the award before the allowable period of performance. The grant award start date was October 1, 2023, but costs were incurred in July, August, and September 2023. Cause: The Department’s procedures and internal controls were not operating sufficiently to ensure that expenditures charged to the program 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. Questioned costs: $2,980, which represents the total incurred before the allowable period of performance. Recommendation: We recommend the Department review and enhance its procedures and controls to ensure that prior to charging costs to the program, they are incurred within an award’s allowable period of performance. Views of responsible officials: Management agrees with the finding.
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.
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.
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.
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.
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.