Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number 2022-008 Prior Year Finding Number N/A Compliance Requirement: Allowable Costs/Costs Principles Program: U.S. Department of Education Title I Grants to Local Educational Agencies ALN #: 84.010 Award #: Various Award Period: Various COVID-19 – Governor’s Emergency Education Relief (GEER) ALN #: 84.425C Award #: Various Award Period: Various COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund ALN #: 84.425D Award #: Various Award Period: Various COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR) ALN #: 84.425U Award #: 211941 Award Period: 03/24/2021 – 09/30/2023 COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth ALN #: 84.425W Award #: Various Award Period: Various Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following: 1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received. 2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance. 3. Records that identify adequately the source and application of funds for federally funded activities. 4. Effective control over, and accountability for, all funds, property, and other assets. The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended. Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences: • ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116. In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170. • ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081. Questioned Costs – Not Determinable. Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above. Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements. Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA. Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail. Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks. The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report. BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Criteria: Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds underHEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the U.S. Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329.Condition/context: A sample of 8 special reports from the population of 8 special reports was selected. For each report, the University was unable to provide support for submission or publication dates. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: Due to the turnover in the business office, the University was unable to locate support for the submission or publication dates, consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for submission or publication dates, data reported and documented review results in a material noncompliance with the reporting compliancerequirement.Repeat finding: YesRecommendation: We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report beposted to the University?s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature anddate.Views of responsible officials and planned corrective actions: Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY20 & FY21 on the University?s website by quarter. Going further it will be the Grant accountant?s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.
Criteria: Under the Coronavirus Aid, Relief, and Economic Security Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act 314(e) institutions that received funds underHEERF I and HEERF II are required to submit a report to the secretary on how the school used its HEERF funds. While the American Rescue Plan did not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, the U.S. Department of Education exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329.Condition/context: A sample of 8 special reports from the population of 8 special reports was selected. For each report, the University was unable to provide support for submission or publication dates. In addition, the University could not provide consistent institutional records for the data included in the reports nor could they provide support that the reports were reviewed prior to posting.Our sample was not, and was not intended to be, statistically valid.Questioned costs: None.Cause/Effect: Due to the turnover in the business office, the University was unable to locate support for the submission or publication dates, consistent institutional records for the data included in the reports or documented review of the reports prior to posting. The lack of support for submission or publication dates, data reported and documented review results in a material noncompliance with the reporting compliancerequirement.Repeat finding: YesRecommendation: We recommend the University update previously posted reports to accurately reflect the actual expenditures during the time period covered by the report. We recommend each report beposted to the University?s website on separate documents by quarter and should not be cumulative. We also recommend the University implement a process to ensure the submission dates and publication dates are maintained to ensure compliance with the reporting due dates and that the data submitted in the reports is properly supported by institutional records. Lastly, we recommend each report be properly reviewed by someone other than the preparer and that the review be documented with a signature anddate.Views of responsible officials and planned corrective actions: Heritage University will update the previously posted reports to accurately reflect the actual expenditures during FY20 & FY21 on the University?s website by quarter. Going further it will be the Grant accountant?s practice that the submission dates and publication dates are maintained and documented with reporting due dates. All documents will be reviewed and approved by the VP of Administration/CFO with dated signatures.
Reference Number: 2022-003Federal Agency: U.S. Department of EducationFederal Program: Education Stabilization FundAssistance Listing Number: 84.425FAward Number and Period: P425F200021; May 4, 2020 ? June 30, 2023Compliance Requirement: ReportingType of Finding: Significant Deficiency in Internal Controls over Compliance, Other MattersCriteria or specific requirement:2 CFR, Part 200, Section 200.328 requires that unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information.Condition:The College was unable to provide supporting documentation that agreed to the quarterly and annual reports submitted for the grant.Context:As part of the testing of the reporting requirement, CLA identified 2 errors in the quarterly reports out of the 4 tested, and an error in the annual report.Cause:The College did not have appropriate controls to ensure documentation for the quarterly and annual reporting was properly maintained.Effect:The College annual reporting may not be accurate and supported.Repeat Finding: NoQuestioned Costs:NoneRecommendation:We recommend the College review current procedures to ensure documentation is maintained to support the amounts submitted on quarterly and annual reports.Views of Responsible Officials:Management agrees with the finding.
Reference Number: 2022-003Federal Agency: U.S. Department of EducationFederal Program: Education Stabilization FundAssistance Listing Number: 84.425FAward Number and Period: P425F200021; May 4, 2020 ? June 30, 2023Compliance Requirement: ReportingType of Finding: Significant Deficiency in Internal Controls over Compliance, Other MattersCriteria or specific requirement:2 CFR, Part 200, Section 200.328 requires that unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information.Condition:The College was unable to provide supporting documentation that agreed to the quarterly and annual reports submitted for the grant.Context:As part of the testing of the reporting requirement, CLA identified 2 errors in the quarterly reports out of the 4 tested, and an error in the annual report.Cause:The College did not have appropriate controls to ensure documentation for the quarterly and annual reporting was properly maintained.Effect:The College annual reporting may not be accurate and supported.Repeat Finding: NoQuestioned Costs:NoneRecommendation:We recommend the College review current procedures to ensure documentation is maintained to support the amounts submitted on quarterly and annual reports.Views of Responsible Officials:Management agrees with the finding.
Reference Number: 2022-003Federal Agency: U.S. Department of EducationFederal Program: Education Stabilization FundAssistance Listing Number: 84.425FAward Number and Period: P425F200021; May 4, 2020 ? June 30, 2023Compliance Requirement: ReportingType of Finding: Significant Deficiency in Internal Controls over Compliance, Other MattersCriteria or specific requirement:2 CFR, Part 200, Section 200.328 requires that unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information.Condition:The College was unable to provide supporting documentation that agreed to the quarterly and annual reports submitted for the grant.Context:As part of the testing of the reporting requirement, CLA identified 2 errors in the quarterly reports out of the 4 tested, and an error in the annual report.Cause:The College did not have appropriate controls to ensure documentation for the quarterly and annual reporting was properly maintained.Effect:The College annual reporting may not be accurate and supported.Repeat Finding: NoQuestioned Costs:NoneRecommendation:We recommend the College review current procedures to ensure documentation is maintained to support the amounts submitted on quarterly and annual reports.Views of Responsible Officials:Management agrees with the finding.
FINDING 2022-002Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS17SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)One of five annual reports required to be completed during the audit period contained materialerrors. The Elementary and Secondary School Emergency Relief (ESSER I), Year 1 annual data reportoverstated total expenditures made between March 13, 2020, and September, 30, 2020, by $130,918. Inaddition, documentation provided for the number of full-time employee positions did not support theamounts reported.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS18SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not in place at the School Corporation to ensure compliancewith requirements related to the grant agreement and the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS17SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)One of five annual reports required to be completed during the audit period contained materialerrors. The Elementary and Secondary School Emergency Relief (ESSER I), Year 1 annual data reportoverstated total expenditures made between March 13, 2020, and September, 30, 2020, by $130,918. Inaddition, documentation provided for the number of full-time employee positions did not support theamounts reported.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.INDIANA STATE BOARD OF ACCOUNTS18SOUTHWEST DUBOIS COUNTY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)EffectThe failure to establish an effective internal control system enabled material noncompliance to goundetected. Noncompliance with the grant agreement and the Reporting compliance requirement couldresult in the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish internal controls to ensurecompliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-010Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Modified OpinionINDIANA STATE BOARD OF ACCOUNTS33BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed or implemented at the School Corporation toensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. For three of the four Reportstested, the Reports were not supported by the unit's records. The financial information provided did notagree to the data submitted in the Reports; therefore, we could not determine the accuracy of the Reports.Additionally, seven of seven key line items selected for testing could not be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in?? 200.328 and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."INDIANA STATE BOARD OF ACCOUNTS34BLACKFORD COUNTY SCHOOLSSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to design and implement an effective internal control system enabled noncompliance togo undetected with the Reporting compliance requirement.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.INDIANA STATE BOARD OF ACCOUNTS35
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersINDIANA STATE BOARD OF ACCOUNTS22MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with the requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation filed the four required Elementary and Secondary School EmergencyRelief (ESSER) annual data reports. However, the ESSER I, Year 1 and ESSER I, Year 2 reports werenot supported by the School Corporation's records. For each of the reports, two key line items wereselected for verification, none of the line items tested were supported by the School Corporation's records.For the ESSER I, Year 2 report the data included expenditures for two months beyond the reporting period.The lack of internal controls and noncompliance were applicable to the ESSER I grant during theaudit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."INDIANA STATE BOARD OF ACCOUNTS23MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not designed, nor implemented a system of internal controls that would haveensured compliance or that supporting documentation would have been maintained and available for auditrelated to the Reporting compliance requirement.EffectThe failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Noncompliancewith the grant agreement and the Reporting compliance requirement could result in the loss of future federalfunds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grantagreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Number: 84.425DFederal Award Number and Year (or Other Identifying Number): S425D200013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersINDIANA STATE BOARD OF ACCOUNTS22MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)Condition and ContextAn effective internal control system was not designed nor implemented at the School Corporationto ensure compliance with the requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation filed the four required Elementary and Secondary School EmergencyRelief (ESSER) annual data reports. However, the ESSER I, Year 1 and ESSER I, Year 2 reports werenot supported by the School Corporation's records. For each of the reports, two key line items wereselected for verification, none of the line items tested were supported by the School Corporation's records.For the ESSER I, Year 2 report the data included expenditures for two months beyond the reporting period.The lack of internal controls and noncompliance were applicable to the ESSER I grant during theaudit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report,respectively, as reported to the Federal awarding agency or pass-through entity in the case ofa subrecipient. . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . .(3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federalawards, authorizations, obligations, unobligated balances, assets, expenditures,income and interest and be supported by source documentation. . . ."INDIANA STATE BOARD OF ACCOUNTS23MONROE COUNTY COMMUNITY SCHOOL CORPORATIONSCHEDULE OF FINDINGS AND QUESTIONED COSTS(Continued)34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."CauseManagement had not designed, nor implemented a system of internal controls that would haveensured compliance or that supporting documentation would have been maintained and available for auditrelated to the Reporting compliance requirement.EffectThe failure to retain and provide appropriate supporting documentation prevented the determination of the School Corporation's compliance with the Reporting compliance requirement. Noncompliancewith the grant agreement and the Reporting compliance requirement could result in the loss of future federalfunds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and available for audit and comply with the grantagreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report, respectively,as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report, respectively,as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report, respectively,as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-005Subject: COVID-19 - Education Stabilization Fund - ReportingFederal Agency: Department of EducationFederal Program: COVID-19 - Education Stabilization FundAssistance Listings Numbers: 84.425D, 84.425UFederal Award Numbers and Years (or Other Identifying Numbers): S425D20013, S425D210013,S425U210013Pass-Through Entity: Indiana Department of EducationCompliance Requirement: ReportingAudit Findings: Material Weakness, Other MattersCondition and ContextAn effective internal control system was not designed, nor implemented, at the School Corporationto ensure compliance with requirements related to the grant agreement and the Reporting compliancerequirement.The School Corporation completed and submitted four annual Data Collection reports (Reports) forthe Elementary and Secondary School Emergency Relief (ESSER) grants. The Reports were prepared byone employee without an oversite or review process in place to prevent, or detect and correct, errors.Additionally, one of the four Reports tested was not supported by the School Corporation's records.The financial information provided did not agree to all the data submitted in the Report; therefore, we couldnot determine the accuracy of the Report. Additionally, two of six key line items selected for testing couldnot be traced to supporting documentation.The lack of internal controls and noncompliance were systemic issues throughout the audit period.Criteria2 CFR 200.303 states in part:"The non-Federal entity must:(a) Establish and maintain effective internal control over the Federal award that providesreasonable assurance that the non-Federal entity is managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federalaward. These internal controls should be in compliance with guidance in 'Standards forInternal Control in the Federal Government' issued by the Comptroller General of theUnited States or the 'Internal Control Integrated Framework', issued by the Committee ofSponsoring Organizations of the Treadway Commission (COSO). . . ."2 CFR 200.302(b) states in part:"The financial management system of each non-Federal entity must provide for the following:. . .(2) Accurate, current, and complete disclosure of the financial results of each Federalaward or program in accordance with the reporting requirements set forth in ?? 200.328and 200.329. . . ."34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and formatthat assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out otherresponsibilities under the program."2 CFR 200.334 states in part:"Financial records, supporting documents, statistical records, and all other non-Federal entityrecords pertinent to a Federal award must be retained for a period of three years from the dateof submission of the final expenditure report or, for Federal awards that are renewed quarterlyor annually, from the date of the submission of the quarterly or annual financial report, respectively,as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.. . ."34 CFR 76.731 states: "A State and a subgrantee shall keep records to show its compliance withprogram requirements."CauseManagement had not developed a system of internal controls that would have ensured compliancewith the Reporting compliance requirement.EffectThe failure to establish an effective internal control system enabled noncompliance to go undetected.Noncompliance with the grant agreement and the Reporting compliance requirement could resultin the loss of future federal funds to the School Corporation.Questioned CostsThere were no questioned costs identified.RecommendationWe recommended that the School Corporation's management establish effective internal controlsto ensure compliance and comply with the grant agreement and the Reporting compliance requirement.Views of Responsible OfficialsFor the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
Criteria: 2 CFR 200.328 requires non-Federal entities to submit performance reports at an interval required by the Federal awarding agency or pass-through entity. Further, at a minimum Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Condition: The Auditor requested support for reporting as required under various grant award agreements for assistance listing 14.218. The Auditor noted multiple instances in which required demographic information, monthly, quarterly, or cumulative annual reports were either not evidenced as being submitted or were not submitted timely. Cause: CAC staff did not submit reporting as required by the grant award agreements. Management tasked with reviewing the grant award compliance requirements and ensuring reporting compliance for report submissions did not properly review or maintain the record of the required grant award reporting submissions. Effect: CAC was not in compliance with the requirements of 2 CFR 200.328 and the terms and conditions of the grant agreements. Recommendation: CAC management should ensure all reporting requirements documented in awards contracts are summarized in a written format and easily accessible. Additionally, CAC staff associated with the program should be trained to ensure deadlines are met. Views of Responsible Official(s) and Planned Corrective Actions: See the accompanying "Management's Corrective Action Plan."
2022-005 — Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2021-002 and 2020-004) Federal program information: Funding agencies: U.S. Department of Interior and U.S. Department of Education Titles: Assistance to Tribally Controlled Community Colleges; Higher Education Institutional Aid; and Education Stabilization Fund ALN Number: 15.027, 84.031, and 84.425 Award years: Various Criteria: According to 2 CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. In addition, ALN 84.425 requires quarterly expenditure and budget reports. Condition: The College did not submit annual performance reports on time for all three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly reports required for ALN 84.425 were not submitted timely. Cause: The College did not have sufficient procedures in place to ensure that the reports were completed timely and accurately. Effect: The three annual reports and two quarterly reports examined were submitted after the required time and one report was inaccurate. Questioned Costs: None Context: The annual reports and two quarterly reports were not submitted timely and one report was not accurate. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and are accurate. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detail and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
2022-005 — Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2021-002 and 2020-004) Federal program information: Funding agencies: U.S. Department of Interior and U.S. Department of Education Titles: Assistance to Tribally Controlled Community Colleges; Higher Education Institutional Aid; and Education Stabilization Fund ALN Number: 15.027, 84.031, and 84.425 Award years: Various Criteria: According to 2 CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. In addition, ALN 84.425 requires quarterly expenditure and budget reports. Condition: The College did not submit annual performance reports on time for all three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly reports required for ALN 84.425 were not submitted timely. Cause: The College did not have sufficient procedures in place to ensure that the reports were completed timely and accurately. Effect: The three annual reports and two quarterly reports examined were submitted after the required time and one report was inaccurate. Questioned Costs: None Context: The annual reports and two quarterly reports were not submitted timely and one report was not accurate. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and are accurate. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detail and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
2022-005 — Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2021-002 and 2020-004) Federal program information: Funding agencies: U.S. Department of Interior and U.S. Department of Education Titles: Assistance to Tribally Controlled Community Colleges; Higher Education Institutional Aid; and Education Stabilization Fund ALN Number: 15.027, 84.031, and 84.425 Award years: Various Criteria: According to 2 CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. In addition, ALN 84.425 requires quarterly expenditure and budget reports. Condition: The College did not submit annual performance reports on time for all three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly reports required for ALN 84.425 were not submitted timely. Cause: The College did not have sufficient procedures in place to ensure that the reports were completed timely and accurately. Effect: The three annual reports and two quarterly reports examined were submitted after the required time and one report was inaccurate. Questioned Costs: None Context: The annual reports and two quarterly reports were not submitted timely and one report was not accurate. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and are accurate. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detail and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
2022-005 — Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2021-002 and 2020-004) Federal program information: Funding agencies: U.S. Department of Interior and U.S. Department of Education Titles: Assistance to Tribally Controlled Community Colleges; Higher Education Institutional Aid; and Education Stabilization Fund ALN Number: 15.027, 84.031, and 84.425 Award years: Various Criteria: According to 2 CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. In addition, ALN 84.425 requires quarterly expenditure and budget reports. Condition: The College did not submit annual performance reports on time for all three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly reports required for ALN 84.425 were not submitted timely. Cause: The College did not have sufficient procedures in place to ensure that the reports were completed timely and accurately. Effect: The three annual reports and two quarterly reports examined were submitted after the required time and one report was inaccurate. Questioned Costs: None Context: The annual reports and two quarterly reports were not submitted timely and one report was not accurate. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and are accurate. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detail and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
2022-005 — Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2021-002 and 2020-004) Federal program information: Funding agencies: U.S. Department of Interior and U.S. Department of Education Titles: Assistance to Tribally Controlled Community Colleges; Higher Education Institutional Aid; and Education Stabilization Fund ALN Number: 15.027, 84.031, and 84.425 Award years: Various Criteria: According to 2 CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. In addition, ALN 84.425 requires quarterly expenditure and budget reports. Condition: The College did not submit annual performance reports on time for all three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly reports required for ALN 84.425 were not submitted timely. Cause: The College did not have sufficient procedures in place to ensure that the reports were completed timely and accurately. Effect: The three annual reports and two quarterly reports examined were submitted after the required time and one report was inaccurate. Questioned Costs: None Context: The annual reports and two quarterly reports were not submitted timely and one report was not accurate. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and are accurate. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detail and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
2022-005 — Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2021-002 and 2020-004) Federal program information: Funding agencies: U.S. Department of Interior and U.S. Department of Education Titles: Assistance to Tribally Controlled Community Colleges; Higher Education Institutional Aid; and Education Stabilization Fund ALN Number: 15.027, 84.031, and 84.425 Award years: Various Criteria: According to 2 CFR Section 200.328, nonfederal entities may be required to submit performance reports at least annually as required by the terms of the federal award. In addition, ALN 84.425 requires quarterly expenditure and budget reports. Condition: The College did not submit annual performance reports on time for all three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly reports required for ALN 84.425 were not submitted timely. Cause: The College did not have sufficient procedures in place to ensure that the reports were completed timely and accurately. Effect: The three annual reports and two quarterly reports examined were submitted after the required time and one report was inaccurate. Questioned Costs: None Context: The annual reports and two quarterly reports were not submitted timely and one report was not accurate. Recommendation: The College should ensure that all grant reports are prepared in a timely manner and are accurate. View of Responsible Officials: The College will ensure that all grant reports are reviewed in detail and information reported will be traced to the source reports by the reviewer. The College also implemented policies and procedures to ensure all grant reports are submitted prior to the due date.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
Reporting Federal Program Name Student Financial Assistance Cluster Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Higher Education Emergency Relief Fund (HEERF) HEERF Institutional Portion, ALN. 84.425F HEERF Minority Serving Institutions (MSIs), ALN. 84.425L Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Financial Reporting Student Financial Assistance Cluster According to 2 CFR section 200.328, the Federal agency must require only OMB-approved governmentwide data elements on recipient financial reports. OMB requires to use form SF-270 for Request for Advance or Reimbursement (Form 270, Request for Title IV Reimbursement or Heightened Cash Monitoring 2 [0MB No. 1845-0089]) - Applicable to ED programs (using the GS System). Special Reporting Higher Education Emergency Relief Fund (HEERF) According 2 CFR section 200.329 outlines the monitoring and reporting program performance requirements for Federal awards. It emphasizes the responsibility of the recipient and subrecipient for oversight and compliance with applicable Federal requirements. The CARES Act 18004(e) and the CRRSAA 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such a manner as the secretary may require.-19- ATLANTIC UNIVERSITY INC. (Non-Profit Organization) Schedule of Findings and Questioned Costs For the Year Ended June 30, 2022 SECTION III – FINDINGS AND QUESTIONED COSTS RELATING TO FEDERAL AWARDS, (Continued) Finding No. 2022–004 - Reporting, (Continued) Condition Financial Reporting Student Financial Assistance Cluster As part of our testing, we selected 6 fund request transactions proportionally among the grants as of June 30, 2022. We noted that in all transactions the Institution this not use Form 270, neither a similar document that was properly signed by an authorized official. Higher Education Emergency Relief Fund (HEERF) As part of our testing, we observed that in the quarterly report information was inaccurate, since the Student Portion expense information was not reported. Also, the report of March 2022 quarter was submitted late. Cause Student Financial Assistance Cluster The form was not prepared because the person in charge did not know that it was required. Higher Education Emergency Relief Fund (HEERF) The person in charge was unaware that Student portion information had to be included in the quarterly reports. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of HEERF program for USDE budgetary policy analysis. Questioned Cost None Context Student Financial Assistance Cluster Of the 62 funds requisitions for 2022, we selected 6 instances in which the Institution did not comply with the financial reporting requirements Higher Education Emergency Relief Fund (HEERF) Of four (4) quarterly reports for 2022, we selected all reports for examinations in which the Institution did not comply with the special reporting requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Views of Responsible Officials and Planned Corrective Actions The Institution management agrees with this finding. Please refer to the corrective action plan on pages 22-26. Recommendation Management should reassess the reporting procedures of the federal programs in which the Institution submits the information to the USDE to ensure they comply with the reporting timeframe. The Institution should enhance both electronic and manual procedures to ensure that the required reports are timely and accurately reported to USDE.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.328 which provides the Federal awarding agency must solicit only the standard, OMB-approved governmentwide data elements for collection of financial information. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Ohio Department of Education Grants Manual requires, at the end of the grant period, that entities submit a final expenditure report (FER). A FER must be submitted to show how grant funds were expended during the grant period. The amounts submitted by the School District in the Final Expenditure Report for the Education Stabilization Fund Elementary and Secondary School Emergency Relief Grant (ESSER II) (grant year 2022) understated when compared to the underlying system data. This was due to the Treasurer not including expenditures in the amount of $260,404 which were expended during Fiscal Year 2021. In addition, the amounts by object code submitted by the School District in the Final Expenditure Report for the Education Stabilization Fund American Rescue Plan Elementary and Secondary School Emergency Relief Grant (grant year 2022) varied from the underlying system data due to the Treasurer incorrectly posting Purchased Services of $11,733 as Supplies and not including Capital Outlay expenditures in the amount of $158,486. Total expenditures on the Final Expenditure Report were understated by $158,486 when compared to the underlying School District records. These error postings were the result of a lack of proper internal controls and due care when preparing the reports. The Treasurer should properly compile and review the annual Final Expenditure Reports, verifying the correct information is provided to the grantor.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.328 which provides the Federal awarding agency must solicit only the standard, OMB-approved governmentwide data elements for collection of financial information. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Ohio Department of Education Grants Manual requires, at the end of the grant period, that entities submit a final expenditure report (FER). A FER must be submitted to show how grant funds were expended during the grant period. The amounts submitted by the School District in the Final Expenditure Report for the Education Stabilization Fund Elementary and Secondary School Emergency Relief Grant (ESSER II) (grant year 2022) understated when compared to the underlying system data. This was due to the Treasurer not including expenditures in the amount of $260,404 which were expended during Fiscal Year 2021. In addition, the amounts by object code submitted by the School District in the Final Expenditure Report for the Education Stabilization Fund American Rescue Plan Elementary and Secondary School Emergency Relief Grant (grant year 2022) varied from the underlying system data due to the Treasurer incorrectly posting Purchased Services of $11,733 as Supplies and not including Capital Outlay expenditures in the amount of $158,486. Total expenditures on the Final Expenditure Report were understated by $158,486 when compared to the underlying School District records. These error postings were the result of a lack of proper internal controls and due care when preparing the reports. The Treasurer should properly compile and review the annual Final Expenditure Reports, verifying the correct information is provided to the grantor.
U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – CFDA 21.027 Criteria: Per 2 CFR section 200.328 of the Uniform Guidance, each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the federal awarding agency. The compliance supplement identifies four Key Line Items required to be reported to the federal awarding agency which include (1) current period obligation, (2) cumulative obligation, (3) current period expenditure and (4) cumulative expenditure. Condition: As of the June 30, 2022 reporting date, the City’s Project and Expenditure Reports overstated expenditures by $274,713 and overstated obligations by $14,045,059. Cause: The City did not reconcile the Project and Expenditure report with the City’s general ledger before submitting and reported the unpaid balance of one contract as expended. The City also considered City departments as subrecipients which caused them to report departmental agreements as obligations. Effect: The City did not properly report grant expenditures and obligations in the Project and Expenditure reporting. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The City should implement procedures to reconcile the financial information in the Project and Expenditure reports to the City’s general ledger and contract files before submission. Views of Responsible Official: Management agrees with the finding.