Late Reporting and Noncompliance with Reporting Requirements Federal Agency: U.S. Department of the Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Award Numbers: 22-LGLR-26/SLRFP4346 Award Year: 2022 Type of Finding: Significant deficiency in internal control over compliance and noncompliance Criteria: In accordance with 2 CFR part 200, subpart D, section 200.328 / 31 CFR section 35.4(c), the recipients are to report annually and quarterly on a timely basis to the U.S. Department of Treasury. Condition and context: The annual report was submitted late, after the deadline. The quarterly report submission dates could not be substantiated. Cause: Due to high amounts of turnover, the Borough was not able to complete the reports within the time requirement. Effect: Late submission of grant progress reports may result in delaying the issuance of funds, or continuation of the award. Questioned Costs: None noted. Repeat finding: This is not a repeat finding and due to the turnover it is considered an isolated instance. Recommendation: We recommend that the client implements a stronger set of internal controls that would ensure proper and timely reporting. Management’s Response: Management concurs with the finding. See Corrective Action Plan.
Late Reporting and Noncompliance with Reporting Requirements Federal Agency: U.S. Department of the Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Award Numbers: 22-LGLR-26/SLRFP4346 Award Year: 2022 Type of Finding: Significant deficiency in internal control over compliance and noncompliance Criteria: In accordance with 2 CFR part 200, subpart D, section 200.328 / 31 CFR section 35.4(c), the recipients are to report annually and quarterly on a timely basis to the U.S. Department of Treasury. Condition and context: The annual report was submitted late, after the deadline. The quarterly report submission dates could not be substantiated. Cause: Due to high amounts of turnover, the Borough was not able to complete the reports within the time requirement. Effect: Late submission of grant progress reports may result in delaying the issuance of funds, or continuation of the award. Questioned Costs: None noted. Repeat finding: This is not a repeat finding and due to the turnover it is considered an isolated instance. Recommendation: We recommend that the client implements a stronger set of internal controls that would ensure proper and timely reporting. Management’s Response: Management concurs with the finding. See Corrective Action Plan.
Condition: During our audit procedures, we noted that the following financial reports were not submitted on time and/or with incorrect balances of cumulative expenses. Criteria: As stated in the award terms 2.CFR 200.328, financial reports are due on a quarterly basis. Cause: Staff members responsible for compiling and submitting financial reports may lack a comprehensive understanding of the specific reporting requirements stipulated by the Federal awarding agency. Without clear guidance or training on reporting deadlines, formatting, and content expectations, they may confront problems meeting compliance obligations in a timely and accurate manner. Effect: Late submissions of required financial reports can result in heightened scrutiny from Federal awarding agencies. The Corporation could face delays in receiving future funding until compliance issues are resolved, impacting its financial stability and mission delivery. Recommendation: Centro Margarita, Inc. should establish clear protocols and timelines for the preparation and submission of financial reports to ensure compliance with Federal awarding agency requirements. This include defining roles and responsibilities within the finance and accounting team and setting deadlines well in advance of the reporting due dates.
Internal Control over Compliance - Timing of Expenditures Reported in the Schedule of Expenditure of Federal Awards (SEFA) Requires Alignment with Federal Guidelines Federal Program Information: Federal Assistance Listing Number: 16.753 Federal Program Name: Byrne Discretionary Community Project Funding /Byrne Discretionary Grants Program Federal Agency: U.S. Department of Justice Pass-through Agency: State of California Bureau of Justice Assistance Federal Award Number: 15PBJA-22-GG-00264-BRND Federal Award Year: March 15, 2022 to September 30, 2023 Criteria: Per 2 CFR 200.510(b), Financial Statements: Schedule of Expenditures of Federal Awards (SEFA), the SEFA must include the total federal awards expended, as determined in accordance with 2 CFR 200.502, Basis for Determining Federal Awards Expended, and must align with the same reporting period as the auditee's financial statements. 2 CFR 200.502(a) specifies that the timing of when a federal award is expended is based on the occurrence of the activity related to the award. Additionally, 2 CFR 200.328, Financial Reporting, emphasizes the importance of submitting performance and financial reports that are complete, accurate, and consistent with the accounting records. Specifically: • Financial data must be derived from and consistent with the recipient's accounting records. • Reports must include all financial information in accordance with federal requirements. Condition: During our audit, we identified a discrepancy involving the federal expenditures for the Byrne Discretionary Community Project Funding/Byrne Discretionary Grants Program, totaling $1,000,000. These expenditures were incurred in FY 2023 but were reported in the SEFA for FY 2024. Additionally, we noted that the reports submitted to the federal agency lacked evident review controls to verify their completeness, accuracy, and consistency with accounting records. Cause and Effect: The City inadvertently excluded the federal expenditure for this grant from the FY2023 SEFA due to an unintentional oversight. This error was later identified and addressed by including the expenditure in the FY2024 SEFA. The oversight occurred because the equipment expenditure tied to this grant was recorded with an effective date of June 2023, while the corresponding grant funds were received and recorded in November 2023. This misalignment in timing created confusion regarding the proper fiscal year in which the expenditure should be reported. Additionally, this was a one-time funding and expenditure, and the City lacked prior experience in both receiving and reporting such grants. The absence of established procedures or review controls specific to this type of funding further contributed to the oversight. Collectively, these factors led to the omission of the expenditure from the FY 2023 SEFA, highlighting the need for improved processes to prevent similar issues in the future. Recommendation: We recommend that the City implement enhanced procedures for reviewing and reconciling grant-related expenditures and receipts to ensure accurate and timely reporting in the SEFA. Specifically, the City should: • Establish a process to track one-time or unique grants separately to ensure their proper inclusion in the correct fiscal year. • Conduct cross-departmental reviews to align the timing of expenditure recording with grant fund receipts. • Provide training to staff on federal reporting requirements, including the accurate preparation of the SEFA in compliance with 2 CFR 200.510(b) and 2 CFR 200.502(a). • Periodically audit SEFA preparation processes to identify and address any potential discrepancies promptly. • Implement thorough pre-submission reviews to ensure reports are accurate, complete, and consistent with accounting records, using checklists or tools if necessary. Views of Responsible Officials and Planned Corrective Action: The City internally identify improvement opportunities in managing grants. As a part of the City’s grant oversight improvement efforts, the City began implementing various processes and internal controls surrounding grant monitoring, which improves the SEFA drafting process and mitigates risks of future inaccuracies. These efforts began in early 2024 and include the following: • Creation of a grant policy that provides City staff with guidance, information, and expectations surrounding grants. • Creation of a master grants database that lists the general ledger fund, applicable project ledger references, status, grant type, start/end dates, granting agency, pass-through agency, grant name, assistance listing numbers, grant amounts, and the grant manager for each grant. This database is now used to verify the completeness and accuracy of the SEFA (beginning FY24). • Formal quarterly monitoring. Each quarter, the City will formally review the grants database with department contacts and grant managers to verify the completeness and accuracy of the database. The City is formalizing this process and plans to include department signoffs evidencing the review process. If any items are missing, the missing component will be identified and added to the database on a timely basis. The City will also utilize this quarterly process to review the grants policy to ensure grant managers are aware of the requirements related to their grants. • The City is in the process of formalizing the SEFA drafting process utilized during the FY24 SEFA preparation, which includes additional mitigating procedures such as reviewing all next FY federal receipts to ensure none of them relate to the SEFA year federal expenditures. Personnel Responsible for Implementation: Marvin Lopez Position of Responsible Personnel: Deputy Administrative Services Director (Fiscal Services) Expected Date of Implementation: June 30, 2025
2024-034 Oregon Housing and Community Services Quarterly Performance Report should include all expenditures incurred to date Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii Federal Award Numbers and Years: B-21-DZ-41-0001, 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Findings: N/A Questioned Costs: N/A Criteria: 2 CFR 200.328(c), DRGR User Manual, Chapter 19, p. 15 CDBG recipients are required to provide a quarterly performance report (QPR) including expenditures incurred period-to-date and in total for each activity. Activity expenditures should be equal to the amount of funds the grantee expended that quarter, regardless of the amount drawn. We found the June 30, 2024 report filed with HUD did not contain accurate information regarding funds expended for the CDBG-Disaster Recovery (CDBG-DR) program as a whole, or for individual activities within the program. OHCS hired a management consultant to provide consulting services, including assistance with preparation of the quarterly reports to HUD for the CDBG-DR grant. Although the department provided the consultant with a report detailing all expenditures for the program, the consultant's approach to QPR reporting did not take into account expenditures the department does not pre-draw for, such as direct and indirect payroll, and services and supplies costs. As a result, only costs for the Homeowner Assistance and Reconstruction Program (HARP) activity and admin costs were reported, although costs were incurred for other program activities. Overall costs were understated by $6.4 million to date and $5.3 million for the period. HARP costs were underreported by $4.3 million to date and $3.8 million for the quarter, and admin costs were underreported by $1 million to date and $0.6 million for the quarter. We recommend quarterly performance reports are prepared to include all expenditures incurred for the period and to date regardless of whether funds have been drawn.
2024-034 Oregon Housing and Community Services Quarterly Performance Report should include all expenditures incurred to date Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.228 Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii Federal Award Numbers and Years: B-21-DZ-41-0001, 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Findings: N/A Questioned Costs: N/A Criteria: 2 CFR 200.328(c), DRGR User Manual, Chapter 19, p. 15 CDBG recipients are required to provide a quarterly performance report (QPR) including expenditures incurred period-to-date and in total for each activity. Activity expenditures should be equal to the amount of funds the grantee expended that quarter, regardless of the amount drawn. We found the June 30, 2024 report filed with HUD did not contain accurate information regarding funds expended for the CDBG-Disaster Recovery (CDBG-DR) program as a whole, or for individual activities within the program. OHCS hired a management consultant to provide consulting services, including assistance with preparation of the quarterly reports to HUD for the CDBG-DR grant. Although the department provided the consultant with a report detailing all expenditures for the program, the consultant's approach to QPR reporting did not take into account expenditures the department does not pre-draw for, such as direct and indirect payroll, and services and supplies costs. As a result, only costs for the Homeowner Assistance and Reconstruction Program (HARP) activity and admin costs were reported, although costs were incurred for other program activities. Overall costs were understated by $6.4 million to date and $5.3 million for the period. HARP costs were underreported by $4.3 million to date and $3.8 million for the quarter, and admin costs were underreported by $1 million to date and $0.6 million for the quarter. We recommend quarterly performance reports are prepared to include all expenditures incurred for the period and to date regardless of whether funds have been drawn.
Item 2024-002 - Reporting - Significant Deficiency Name of Federal Agency: United States Department of Health and Human Services Federal Program Name: Early Head Start (EHS) Assistance Listing Number 93.600 Federal Award Identification Number and Year: 04HP000377-04-2023 04CH011372-04-2023 04HE001247-001-2023 Criteria Program regulations and contracts require timely submission of SF-425 FFR reports to the regulatory agent as specified in 2 CFR section 200.328. Condition Durham’s Partnership for Children did not submit timely SF-425 FFR reports related to ongoing 2023 EHS grants. Cause Management does not have controls in place to ensure timely data compilation and reporting. Effect or Potential Effect Management is not in compliance with the program guidelines requiring timely reporting to the regulatory agent. Questioned Costs: N/A Context During testing of the reporting compliance requirement for EHS, it was noted that there were severe delays in submission of all required reports from the current year. The delay in timing of the report filings relates to the availability of accurate financial data (Finding No. 2024-001). Identification of Repeat Finding: Not a repeat finding. Recommendation Management should implement procedures to ensure timely submission of required reports to the regulatory agent. Reporting Views of Responsible Officials The finance director has been replaced by a qualified CPA. Support from an external content specialist was secured to train the current CFO on the proper preparation of the SF-425 reports. Reporting has been brought current. Alert emails from HSES are being reviewed by leadership and the HSES website is being monitored for submission deadlines. Priority is given to ensure timely deliverables.
Item 2024-002 - Reporting - Significant Deficiency Name of Federal Agency: United States Department of Health and Human Services Federal Program Name: Early Head Start (EHS) Assistance Listing Number 93.600 Federal Award Identification Number and Year: 04HP000377-04-2023 04CH011372-04-2023 04HE001247-001-2023 Criteria Program regulations and contracts require timely submission of SF-425 FFR reports to the regulatory agent as specified in 2 CFR section 200.328. Condition Durham’s Partnership for Children did not submit timely SF-425 FFR reports related to ongoing 2023 EHS grants. Cause Management does not have controls in place to ensure timely data compilation and reporting. Effect or Potential Effect Management is not in compliance with the program guidelines requiring timely reporting to the regulatory agent. Questioned Costs: N/A Context During testing of the reporting compliance requirement for EHS, it was noted that there were severe delays in submission of all required reports from the current year. The delay in timing of the report filings relates to the availability of accurate financial data (Finding No. 2024-001). Identification of Repeat Finding: Not a repeat finding. Recommendation Management should implement procedures to ensure timely submission of required reports to the regulatory agent. Reporting Views of Responsible Officials The finance director has been replaced by a qualified CPA. Support from an external content specialist was secured to train the current CFO on the proper preparation of the SF-425 reports. Reporting has been brought current. Alert emails from HSES are being reviewed by leadership and the HSES website is being monitored for submission deadlines. Priority is given to ensure timely deliverables.
Item 2024-002 - Reporting - Significant Deficiency Name of Federal Agency: United States Department of Health and Human Services Federal Program Name: Early Head Start (EHS) Assistance Listing Number 93.600 Federal Award Identification Number and Year: 04HP000377-04-2023 04CH011372-04-2023 04HE001247-001-2023 Criteria Program regulations and contracts require timely submission of SF-425 FFR reports to the regulatory agent as specified in 2 CFR section 200.328. Condition Durham’s Partnership for Children did not submit timely SF-425 FFR reports related to ongoing 2023 EHS grants. Cause Management does not have controls in place to ensure timely data compilation and reporting. Effect or Potential Effect Management is not in compliance with the program guidelines requiring timely reporting to the regulatory agent. Questioned Costs: N/A Context During testing of the reporting compliance requirement for EHS, it was noted that there were severe delays in submission of all required reports from the current year. The delay in timing of the report filings relates to the availability of accurate financial data (Finding No. 2024-001). Identification of Repeat Finding: Not a repeat finding. Recommendation Management should implement procedures to ensure timely submission of required reports to the regulatory agent. Reporting Views of Responsible Officials The finance director has been replaced by a qualified CPA. Support from an external content specialist was secured to train the current CFO on the proper preparation of the SF-425 reports. Reporting has been brought current. Alert emails from HSES are being reviewed by leadership and the HSES website is being monitored for submission deadlines. Priority is given to ensure timely deliverables.
Item 2024-002 - Reporting - Significant Deficiency Name of Federal Agency: United States Department of Health and Human Services Federal Program Name: Early Head Start (EHS) Assistance Listing Number 93.600 Federal Award Identification Number and Year: 04HP000377-04-2023 04CH011372-04-2023 04HE001247-001-2023 Criteria Program regulations and contracts require timely submission of SF-425 FFR reports to the regulatory agent as specified in 2 CFR section 200.328. Condition Durham’s Partnership for Children did not submit timely SF-425 FFR reports related to ongoing 2023 EHS grants. Cause Management does not have controls in place to ensure timely data compilation and reporting. Effect or Potential Effect Management is not in compliance with the program guidelines requiring timely reporting to the regulatory agent. Questioned Costs: N/A Context During testing of the reporting compliance requirement for EHS, it was noted that there were severe delays in submission of all required reports from the current year. The delay in timing of the report filings relates to the availability of accurate financial data (Finding No. 2024-001). Identification of Repeat Finding: Not a repeat finding. Recommendation Management should implement procedures to ensure timely submission of required reports to the regulatory agent. Reporting Views of Responsible Officials The finance director has been replaced by a qualified CPA. Support from an external content specialist was secured to train the current CFO on the proper preparation of the SF-425 reports. Reporting has been brought current. Alert emails from HSES are being reviewed by leadership and the HSES website is being monitored for submission deadlines. Priority is given to ensure timely deliverables.
Item 2024-002 - Reporting - Significant Deficiency Name of Federal Agency: United States Department of Health and Human Services Federal Program Name: Early Head Start (EHS) Assistance Listing Number 93.600 Federal Award Identification Number and Year: 04HP000377-04-2023 04CH011372-04-2023 04HE001247-001-2023 Criteria Program regulations and contracts require timely submission of SF-425 FFR reports to the regulatory agent as specified in 2 CFR section 200.328. Condition Durham’s Partnership for Children did not submit timely SF-425 FFR reports related to ongoing 2023 EHS grants. Cause Management does not have controls in place to ensure timely data compilation and reporting. Effect or Potential Effect Management is not in compliance with the program guidelines requiring timely reporting to the regulatory agent. Questioned Costs: N/A Context During testing of the reporting compliance requirement for EHS, it was noted that there were severe delays in submission of all required reports from the current year. The delay in timing of the report filings relates to the availability of accurate financial data (Finding No. 2024-001). Identification of Repeat Finding: Not a repeat finding. Recommendation Management should implement procedures to ensure timely submission of required reports to the regulatory agent. Reporting Views of Responsible Officials The finance director has been replaced by a qualified CPA. Support from an external content specialist was secured to train the current CFO on the proper preparation of the SF-425 reports. Reporting has been brought current. Alert emails from HSES are being reviewed by leadership and the HSES website is being monitored for submission deadlines. Priority is given to ensure timely deliverables.
FINDING NO. 2024-001 Federal programs FINANCIAL STATEMENTS All federal financial assistance programs Category Internal control Condition found The Organization accounted for its activities based on the services provided, which are educational services. During our financial and compliance audit procedures for the fiscal year ending June 30, 2024, we noted the following conditions related to the accounting procedures and financial reporting practices of the Organization: a. Accounting and interim financial reports are not executed on a current (month-to-month) basis. Accounting journals, general ledger and interim financial reports, such as Balance Sheet, Statement of Activities and Bank Reconciliations, monthly analysis of certain accounts are executed after the end of the related accounting year. Criteria 2 CFR 200.302 (b) (2), (4), (5) and (7) establish that the financial management system of each non Federal entity must provide for the following: i. Cause 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. Contracted outsource for the general accounting of the institution have been unable to prepare the monthly accounting and the related interim financial reports on a current basis. Effect This weakness in the accounting of the institution requires extra efforts from the administration to compensate for the lack of current accountability with additional alternative measures and procedures. Noncompliance with the above-mentioned requirements could lead to administrative actions by the grantor. Questioned Costs NoneIdentification as a Repeated Finding Yes Recommendations The Organization should enforce its policies and procedures in order to accurately maintain its financial information, and on a timely basis, assuring that they reflect its assets and liabilities, and to maintain an appropriate control over its revenues and the amounts expended, which will allow a proper management and monitoring of operations. These policies and procedures should be enforced to consider the following: • Establish monthly and year end closing procedures. • Prepare monthly or quarterly financial reports for management evaluation and analysis. Views of Responsible Officials The Organization agrees with the finding. Executed actions have substantially improved their year-end closing procedures. They contracted a new accounting firm to improve their accounting and the interim financial reporting.
CHILD NUTRITION CLUSTER – 10.553, 10.555, 10.556, 10.559, 10.582 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: 202424N109944, 202423N109944, 202424N119944, 202423N119944, 202423L160344 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Reporting FEDERAL REPORTING – SF-425 FINANCIAL REPORTS RIDE did not submit complete and timely SF-425 Financial Reports in accordance with federal requirements. Background: RIDE has an individual who initiates the SF-425 report by compiling data from RIFANS. Once completed and entered on the fprs.fns.usda.gov reporting site, the initiator notifies a separate individual to submit and have the report certified. The submission of the SF-425 Federal Financial Report on the reporting website should be no later than 30 calendar days after the reporting period for the quarterly report and the final annual report is due no later than 90 calendar days after the reporting period. The SF-425 is a cumulative report until the final report is submitted. Criteria: According to 2 CFR §200.328(c), RIDE must submit the SF-425 quarterly report no later than 30 calendar days after the reporting period and no later than 90 days after the reporting period for the final annual report. Condition: RIDE did not submit 3 of the 4 (1 quarterly and 2 final annual reports) SF-425 reports within the required period for the Fresh Fruit and Vegetable Program and Supply Chain Assistance (Part of National School Lunch Program). Cause: The department did not have adequate controls to ensure timely and complete reporting of the SF-425 Federal Financial Report. Effect: RIDE did not comply with reporting requirements of SF-425 Federal Financial Reporting. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-033 Establish policies and procedures in conjunction with formalizing internal control that ensures complete and timely reporting of the SF-425 Federal Financial Report.
CHILD NUTRITION CLUSTER – 10.553, 10.555, 10.556, 10.559, 10.582 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: 202424N109944, 202423N109944, 202424N119944, 202423N119944, 202423L160344 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Reporting FEDERAL REPORTING – SF-425 FINANCIAL REPORTS RIDE did not submit complete and timely SF-425 Financial Reports in accordance with federal requirements. Background: RIDE has an individual who initiates the SF-425 report by compiling data from RIFANS. Once completed and entered on the fprs.fns.usda.gov reporting site, the initiator notifies a separate individual to submit and have the report certified. The submission of the SF-425 Federal Financial Report on the reporting website should be no later than 30 calendar days after the reporting period for the quarterly report and the final annual report is due no later than 90 calendar days after the reporting period. The SF-425 is a cumulative report until the final report is submitted. Criteria: According to 2 CFR §200.328(c), RIDE must submit the SF-425 quarterly report no later than 30 calendar days after the reporting period and no later than 90 days after the reporting period for the final annual report. Condition: RIDE did not submit 3 of the 4 (1 quarterly and 2 final annual reports) SF-425 reports within the required period for the Fresh Fruit and Vegetable Program and Supply Chain Assistance (Part of National School Lunch Program). Cause: The department did not have adequate controls to ensure timely and complete reporting of the SF-425 Federal Financial Report. Effect: RIDE did not comply with reporting requirements of SF-425 Federal Financial Reporting. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-033 Establish policies and procedures in conjunction with formalizing internal control that ensures complete and timely reporting of the SF-425 Federal Financial Report.
CHILD NUTRITION CLUSTER – 10.553, 10.555, 10.556, 10.559, 10.582 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: 202424N109944, 202423N109944, 202424N119944, 202423N119944, 202423L160344 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Reporting FEDERAL REPORTING – SF-425 FINANCIAL REPORTS RIDE did not submit complete and timely SF-425 Financial Reports in accordance with federal requirements. Background: RIDE has an individual who initiates the SF-425 report by compiling data from RIFANS. Once completed and entered on the fprs.fns.usda.gov reporting site, the initiator notifies a separate individual to submit and have the report certified. The submission of the SF-425 Federal Financial Report on the reporting website should be no later than 30 calendar days after the reporting period for the quarterly report and the final annual report is due no later than 90 calendar days after the reporting period. The SF-425 is a cumulative report until the final report is submitted. Criteria: According to 2 CFR §200.328(c), RIDE must submit the SF-425 quarterly report no later than 30 calendar days after the reporting period and no later than 90 days after the reporting period for the final annual report. Condition: RIDE did not submit 3 of the 4 (1 quarterly and 2 final annual reports) SF-425 reports within the required period for the Fresh Fruit and Vegetable Program and Supply Chain Assistance (Part of National School Lunch Program). Cause: The department did not have adequate controls to ensure timely and complete reporting of the SF-425 Federal Financial Report. Effect: RIDE did not comply with reporting requirements of SF-425 Federal Financial Reporting. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-033 Establish policies and procedures in conjunction with formalizing internal control that ensures complete and timely reporting of the SF-425 Federal Financial Report.
CHILD NUTRITION CLUSTER – 10.553, 10.555, 10.556, 10.559, 10.582 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: 202424N109944, 202423N109944, 202424N119944, 202423N119944, 202423L160344 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Reporting FEDERAL REPORTING – SF-425 FINANCIAL REPORTS RIDE did not submit complete and timely SF-425 Financial Reports in accordance with federal requirements. Background: RIDE has an individual who initiates the SF-425 report by compiling data from RIFANS. Once completed and entered on the fprs.fns.usda.gov reporting site, the initiator notifies a separate individual to submit and have the report certified. The submission of the SF-425 Federal Financial Report on the reporting website should be no later than 30 calendar days after the reporting period for the quarterly report and the final annual report is due no later than 90 calendar days after the reporting period. The SF-425 is a cumulative report until the final report is submitted. Criteria: According to 2 CFR §200.328(c), RIDE must submit the SF-425 quarterly report no later than 30 calendar days after the reporting period and no later than 90 days after the reporting period for the final annual report. Condition: RIDE did not submit 3 of the 4 (1 quarterly and 2 final annual reports) SF-425 reports within the required period for the Fresh Fruit and Vegetable Program and Supply Chain Assistance (Part of National School Lunch Program). Cause: The department did not have adequate controls to ensure timely and complete reporting of the SF-425 Federal Financial Report. Effect: RIDE did not comply with reporting requirements of SF-425 Federal Financial Reporting. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-033 Establish policies and procedures in conjunction with formalizing internal control that ensures complete and timely reporting of the SF-425 Federal Financial Report.
CHILD NUTRITION CLUSTER – 10.553, 10.555, 10.556, 10.559, 10.582 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: 202424N109944, 202423N109944, 202424N119944, 202423N119944, 202423L160344 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Reporting FEDERAL REPORTING – SF-425 FINANCIAL REPORTS RIDE did not submit complete and timely SF-425 Financial Reports in accordance with federal requirements. Background: RIDE has an individual who initiates the SF-425 report by compiling data from RIFANS. Once completed and entered on the fprs.fns.usda.gov reporting site, the initiator notifies a separate individual to submit and have the report certified. The submission of the SF-425 Federal Financial Report on the reporting website should be no later than 30 calendar days after the reporting period for the quarterly report and the final annual report is due no later than 90 calendar days after the reporting period. The SF-425 is a cumulative report until the final report is submitted. Criteria: According to 2 CFR §200.328(c), RIDE must submit the SF-425 quarterly report no later than 30 calendar days after the reporting period and no later than 90 days after the reporting period for the final annual report. Condition: RIDE did not submit 3 of the 4 (1 quarterly and 2 final annual reports) SF-425 reports within the required period for the Fresh Fruit and Vegetable Program and Supply Chain Assistance (Part of National School Lunch Program). Cause: The department did not have adequate controls to ensure timely and complete reporting of the SF-425 Federal Financial Report. Effect: RIDE did not comply with reporting requirements of SF-425 Federal Financial Reporting. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-033 Establish policies and procedures in conjunction with formalizing internal control that ensures complete and timely reporting of the SF-425 Federal Financial Report.
SPECIAL EDUCATION CLUSTER (IDEA) – 84.027, 84.173 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: HO27A220054-22A, H173A220057 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Subrecipient Monitoring SUBRECIPIENT MONITORING The Department of Education (RIDE) has not implemented adequate subrecipient monitoring activities to ensure compliance with federal regulations. Background: The State relies on grantee agencies to perform subrecipient monitoring, when required, and ensure compliance with federal regulations. There is no statewide monitoring of subrecipient activities to ensure compliance with federal regulations. RIDE performs its subrecipient monitoring through the review of audit reports, desk reviews and performing site visits deemed high risk. High-risk subrecipients are determined through the review of audit reports, completion of a desk review checklist, and the completion of an annual survey completed by the subrecipients then scored by RIDE. Criteria: Federal regulations 2 CFR §200.329, require Pass Through Entities (PTE), such as the State, to monitor grant subrecipients to ensure that federal funds are spent appropriately. Federal Regulation 2 CFR §200.332 Subpart B requires that the PTE provide subrecipients with clear grant information, including grant terms, required financial reporting, and audit requirements. Per 2 CFR § 200.328, PTEs must collect financial data from subrecipients no less than annually. Condition: We identified some deficiencies in internal controls relating to subrecipient monitoring during our audit. Deficiencies included a lack of required monitoring documentation (e.g., annual surveys, Single Audit Reports) submitted by subrecipients and failure by RIDE to appropriately consider these deficiencies within their consideration of subrecipient risk. Of the 65 subrecipients receiving $55.3 million, we selected 25 subrecipients for testing and found 4 subrecipients with control deficiencies that prevented RIDE from complying with the subrecipient monitoring requirement as follows: • RIDE was unable to provide documentation supporting grant award information communicated to one subrecipient. Additionally, the required risk assessment for the Special Education Cluster was not performed for this subrecipient. • RIDE was unable to provide the completed Desk Review checklist for 3 subrecipients. These 3 subrecipients also did not complete RIDE’s required annual survey. We found that the lack of annual survey completion did not result in RIDE assessing higher risk for one subrecipient and thus no site visit was performed. The other 2 subrecipients were assessed at high risk, however, no site visit was performed for these subrecipients. • A subrecipient did not submit its fiscal year 2022 and 2023 Single Audit Reports and RIDE did not modify its risk assessment accordingly. RIDE was also unable to provide documentation supporting its follow-up (i.e., meeting discussing the submission of the Single Audit Report) with the subrecipients. Additionally, RIDE’s risk assessment was not adequate to identify this subrecipient as high risk. Internal controls over subrecipient monitoring would be improved by 1) updating subrecipients’ risk assessments when they fail to comply with documentation requirements, and 2) implementing monitoring procedures to identify instances where RIDE’s monitoring is not consistent with the risk assessed. Implementing site visits when subrecipients do not comply with documentation requirements would ensure that monitoring procedures align with the risk associated with the subrecipient. Cause: Lack of adequate dedicated agency resources and insufficient controls to ensure compliance with federal requirements. Effect: Noncompliance with federal compliance requirements by subrecipients could occur without being identified by the State in a timely manner. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-047 Improve internal controls over subrecipient monitoring by 1) updating subrecipients’ risk assessments when they fail to comply with documentation requirements, and 2) implementing monitoring procedures to identify instances where RIDE’s monitoring is not consistent with the risk assessed.
SPECIAL EDUCATION CLUSTER (IDEA) – 84.027, 84.173 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: HO27A220054-22A, H173A220057 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Subrecipient Monitoring SUBRECIPIENT MONITORING The Department of Education (RIDE) has not implemented adequate subrecipient monitoring activities to ensure compliance with federal regulations. Background: The State relies on grantee agencies to perform subrecipient monitoring, when required, and ensure compliance with federal regulations. There is no statewide monitoring of subrecipient activities to ensure compliance with federal regulations. RIDE performs its subrecipient monitoring through the review of audit reports, desk reviews and performing site visits deemed high risk. High-risk subrecipients are determined through the review of audit reports, completion of a desk review checklist, and the completion of an annual survey completed by the subrecipients then scored by RIDE. Criteria: Federal regulations 2 CFR §200.329, require Pass Through Entities (PTE), such as the State, to monitor grant subrecipients to ensure that federal funds are spent appropriately. Federal Regulation 2 CFR §200.332 Subpart B requires that the PTE provide subrecipients with clear grant information, including grant terms, required financial reporting, and audit requirements. Per 2 CFR § 200.328, PTEs must collect financial data from subrecipients no less than annually. Condition: We identified some deficiencies in internal controls relating to subrecipient monitoring during our audit. Deficiencies included a lack of required monitoring documentation (e.g., annual surveys, Single Audit Reports) submitted by subrecipients and failure by RIDE to appropriately consider these deficiencies within their consideration of subrecipient risk. Of the 65 subrecipients receiving $55.3 million, we selected 25 subrecipients for testing and found 4 subrecipients with control deficiencies that prevented RIDE from complying with the subrecipient monitoring requirement as follows: • RIDE was unable to provide documentation supporting grant award information communicated to one subrecipient. Additionally, the required risk assessment for the Special Education Cluster was not performed for this subrecipient. • RIDE was unable to provide the completed Desk Review checklist for 3 subrecipients. These 3 subrecipients also did not complete RIDE’s required annual survey. We found that the lack of annual survey completion did not result in RIDE assessing higher risk for one subrecipient and thus no site visit was performed. The other 2 subrecipients were assessed at high risk, however, no site visit was performed for these subrecipients. • A subrecipient did not submit its fiscal year 2022 and 2023 Single Audit Reports and RIDE did not modify its risk assessment accordingly. RIDE was also unable to provide documentation supporting its follow-up (i.e., meeting discussing the submission of the Single Audit Report) with the subrecipients. Additionally, RIDE’s risk assessment was not adequate to identify this subrecipient as high risk. Internal controls over subrecipient monitoring would be improved by 1) updating subrecipients’ risk assessments when they fail to comply with documentation requirements, and 2) implementing monitoring procedures to identify instances where RIDE’s monitoring is not consistent with the risk assessed. Implementing site visits when subrecipients do not comply with documentation requirements would ensure that monitoring procedures align with the risk associated with the subrecipient. Cause: Lack of adequate dedicated agency resources and insufficient controls to ensure compliance with federal requirements. Effect: Noncompliance with federal compliance requirements by subrecipients could occur without being identified by the State in a timely manner. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-047 Improve internal controls over subrecipient monitoring by 1) updating subrecipients’ risk assessments when they fail to comply with documentation requirements, and 2) implementing monitoring procedures to identify instances where RIDE’s monitoring is not consistent with the risk assessed.
SPECIAL EDUCATION CLUSTER (IDEA) – 84.027, 84.173 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: HO27A220054-22A, H173A220057 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Subrecipient Monitoring SUBRECIPIENT MONITORING The Department of Education (RIDE) has not implemented adequate subrecipient monitoring activities to ensure compliance with federal regulations. Background: The State relies on grantee agencies to perform subrecipient monitoring, when required, and ensure compliance with federal regulations. There is no statewide monitoring of subrecipient activities to ensure compliance with federal regulations. RIDE performs its subrecipient monitoring through the review of audit reports, desk reviews and performing site visits deemed high risk. High-risk subrecipients are determined through the review of audit reports, completion of a desk review checklist, and the completion of an annual survey completed by the subrecipients then scored by RIDE. Criteria: Federal regulations 2 CFR §200.329, require Pass Through Entities (PTE), such as the State, to monitor grant subrecipients to ensure that federal funds are spent appropriately. Federal Regulation 2 CFR §200.332 Subpart B requires that the PTE provide subrecipients with clear grant information, including grant terms, required financial reporting, and audit requirements. Per 2 CFR § 200.328, PTEs must collect financial data from subrecipients no less than annually. Condition: We identified some deficiencies in internal controls relating to subrecipient monitoring during our audit. Deficiencies included a lack of required monitoring documentation (e.g., annual surveys, Single Audit Reports) submitted by subrecipients and failure by RIDE to appropriately consider these deficiencies within their consideration of subrecipient risk. Of the 65 subrecipients receiving $55.3 million, we selected 25 subrecipients for testing and found 4 subrecipients with control deficiencies that prevented RIDE from complying with the subrecipient monitoring requirement as follows: • RIDE was unable to provide documentation supporting grant award information communicated to one subrecipient. Additionally, the required risk assessment for the Special Education Cluster was not performed for this subrecipient. • RIDE was unable to provide the completed Desk Review checklist for 3 subrecipients. These 3 subrecipients also did not complete RIDE’s required annual survey. We found that the lack of annual survey completion did not result in RIDE assessing higher risk for one subrecipient and thus no site visit was performed. The other 2 subrecipients were assessed at high risk, however, no site visit was performed for these subrecipients. • A subrecipient did not submit its fiscal year 2022 and 2023 Single Audit Reports and RIDE did not modify its risk assessment accordingly. RIDE was also unable to provide documentation supporting its follow-up (i.e., meeting discussing the submission of the Single Audit Report) with the subrecipients. Additionally, RIDE’s risk assessment was not adequate to identify this subrecipient as high risk. Internal controls over subrecipient monitoring would be improved by 1) updating subrecipients’ risk assessments when they fail to comply with documentation requirements, and 2) implementing monitoring procedures to identify instances where RIDE’s monitoring is not consistent with the risk assessed. Implementing site visits when subrecipients do not comply with documentation requirements would ensure that monitoring procedures align with the risk associated with the subrecipient. Cause: Lack of adequate dedicated agency resources and insufficient controls to ensure compliance with federal requirements. Effect: Noncompliance with federal compliance requirements by subrecipients could occur without being identified by the State in a timely manner. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-047 Improve internal controls over subrecipient monitoring by 1) updating subrecipients’ risk assessments when they fail to comply with documentation requirements, and 2) implementing monitoring procedures to identify instances where RIDE’s monitoring is not consistent with the risk assessed.
SPECIAL EDUCATION CLUSTER (IDEA) – 84.027, 84.173 Federal Awarding Agency: U.S. Department of Agriculture (USDA) Federal Award Fiscal Year: 2024 Federal Award Numbers: HO27A220054-22A, H173A220057 Administered by: Rhode Island Department of Elementary and Secondary Education (RIDE) Compliance Requirement: Subrecipient Monitoring SUBRECIPIENT MONITORING The Department of Education (RIDE) has not implemented adequate subrecipient monitoring activities to ensure compliance with federal regulations. Background: The State relies on grantee agencies to perform subrecipient monitoring, when required, and ensure compliance with federal regulations. There is no statewide monitoring of subrecipient activities to ensure compliance with federal regulations. RIDE performs its subrecipient monitoring through the review of audit reports, desk reviews and performing site visits deemed high risk. High-risk subrecipients are determined through the review of audit reports, completion of a desk review checklist, and the completion of an annual survey completed by the subrecipients then scored by RIDE. Criteria: Federal regulations 2 CFR §200.329, require Pass Through Entities (PTE), such as the State, to monitor grant subrecipients to ensure that federal funds are spent appropriately. Federal Regulation 2 CFR §200.332 Subpart B requires that the PTE provide subrecipients with clear grant information, including grant terms, required financial reporting, and audit requirements. Per 2 CFR § 200.328, PTEs must collect financial data from subrecipients no less than annually. Condition: We identified some deficiencies in internal controls relating to subrecipient monitoring during our audit. Deficiencies included a lack of required monitoring documentation (e.g., annual surveys, Single Audit Reports) submitted by subrecipients and failure by RIDE to appropriately consider these deficiencies within their consideration of subrecipient risk. Of the 65 subrecipients receiving $55.3 million, we selected 25 subrecipients for testing and found 4 subrecipients with control deficiencies that prevented RIDE from complying with the subrecipient monitoring requirement as follows: • RIDE was unable to provide documentation supporting grant award information communicated to one subrecipient. Additionally, the required risk assessment for the Special Education Cluster was not performed for this subrecipient. • RIDE was unable to provide the completed Desk Review checklist for 3 subrecipients. These 3 subrecipients also did not complete RIDE’s required annual survey. We found that the lack of annual survey completion did not result in RIDE assessing higher risk for one subrecipient and thus no site visit was performed. The other 2 subrecipients were assessed at high risk, however, no site visit was performed for these subrecipients. • A subrecipient did not submit its fiscal year 2022 and 2023 Single Audit Reports and RIDE did not modify its risk assessment accordingly. RIDE was also unable to provide documentation supporting its follow-up (i.e., meeting discussing the submission of the Single Audit Report) with the subrecipients. Additionally, RIDE’s risk assessment was not adequate to identify this subrecipient as high risk. Internal controls over subrecipient monitoring would be improved by 1) updating subrecipients’ risk assessments when they fail to comply with documentation requirements, and 2) implementing monitoring procedures to identify instances where RIDE’s monitoring is not consistent with the risk assessed. Implementing site visits when subrecipients do not comply with documentation requirements would ensure that monitoring procedures align with the risk associated with the subrecipient. Cause: Lack of adequate dedicated agency resources and insufficient controls to ensure compliance with federal requirements. Effect: Noncompliance with federal compliance requirements by subrecipients could occur without being identified by the State in a timely manner. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATION 2024-047 Improve internal controls over subrecipient monitoring by 1) updating subrecipients’ risk assessments when they fail to comply with documentation requirements, and 2) implementing monitoring procedures to identify instances where RIDE’s monitoring is not consistent with the risk assessed.
Federal Program Name: COVID-19 - Education Stabilization Fund Federal Agency: Department of Education Federal Assistance Listing Title and Number: COVID-19 - Education Stabilization Fund, 84.425U Criteria or Specific Requirement: Reporting - CFR Part 200.302(b) states, “The financial management system of each non-Federal entity must provide for accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329." This is a repeat finding from the prior year (2023-002). Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with federal requirements related to the reporting compliance requirements. (Other Instance of Noncompliance and Deficiency) Questioned Costs: None noted Context: The School Corporation submitted one ESSER III report where the expenses per the report did not tie to the ledger or the Schedule of Expenditures of Federal Awards by approximately $300,000. Effect: The ESSER III report was not supported by the School Corporation’s financial records. Cause: The School Corporation’s internal controls were not applied to the reporting process that required retention of documentation originally used to prepare the financial portion of the ESSER III report.. Recommendation: Management should establish a proper system of internal controls and strengthen its policies and procedures to ensure all reports submitted on behalf of the Education Stabilization Fund program funds are accurate and are reconciled to the School Corporation’s financial records. Views of Responsible Officials and Planned Corrective Action: The District notes the finding as presented. See Corrective Action Plan prepared by management Persons responsible for implementing: Matthew Miles, CFO Anticipated completion date: July 15, 2025.
Condition: During our audit of the Abandoned Mine Land and Reclamation Program, we noted that the submission of the quarterly SF-425 Federal Financial Reports was not completed within 30 days after the reporting period end date. Context: The SF-425 Federal Financial Reports for the four quarters of fiscal year 2024 were not submitted by their respective deadlines of 30 days after the reporting period end date. All fiscal year 2024 reports were filed in April 2025. Criteria: 2 C.F.R. § 1000.10 gives regulatory effect to the Department of Treasury for 2 C.F.R. § 200.328, which establishes requirements over federal reporting, and states: 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. 2 C.F.R. § 1000.10 gives regulatory effect to the Department of Treasury for 2 C.F.R. § 200.329(b), which establishes requirements over federal reporting, and states: Reporting program performance. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. As appropriate and in accordance with above mentioned information collections, the Federal awarding agency must require the recipient to relate financial data and accomplishments to performance goals and objectives of the Federal award. Also, in accordance with above mentioned common information collections, and when required by the terms and conditions of the Federal award, recipients must provide cost information to demonstrate cost effective practices (e.g., through unit cost data). In some instances (e.g., discretionary research awards), this will be limited to the requirement to submit technical performance reports (to be evaluated in accordance with Federal awarding agency policy). Reporting requirements must be clearly articulated such that, where appropriate, performance during the execution of the Federal award has a standard against which non-Federal entity performance can be measured. It is management's responsibility to implement internal control procedures to reasonably ensure the federal reports they submit are accurate, complete, and in compliance with program requirements. It is imperative that management be able to provide the underlying data and related program documentation required to prepare and support these reports. The Town’s management is responsible for the preparation of the quarterly SF-425 Federal Financial Report, as required by 2 C.F.R. § 200.328. Questioned Costs: $0 Cause: The Town did not have adequate controls in place to ensure the quarterly SF-425 Federal Financial Reports, were submitted within 30 days after the reporting period end date. Effect: The SF-425 Federal Financial Reports were not submitted by their respective deadlines of 30 days after the reporting period end date. Recommendation: We recommend the Town review these regulations and comply with the provisions set forth therein. A policy should be established to ensure that each SF-425 Federal Financial Report is submitted by its due date of 30 days after the reporting period end date. Management should periodically review these procedures to ensure they are operating as intended. Response: Management stated they have established a policy to ensure each quarterly report is submitted by its due date.
CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. This is a repeat finding from (2023-003) from the previous fiscal year. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 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 sections 200.328 and 200.329 of the Uniform Guidance. EFFECT: The District was not in compliance with the financial reporting requirements in the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CAUSE: The District experienced turnover in key business office personnel during the last three fiscal years, which resulted in errors in posting federal expenditures to the appropriate general ledger account codes. This further lead to inaccurate reporting as outlined above. QUESTIONED COST: None RECOMMENDATION: I recommend that the District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance and PDE regulations. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. This is a repeat finding from (2023-003) from the previous fiscal year. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 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 sections 200.328 and 200.329 of the Uniform Guidance. EFFECT: The District was not in compliance with the financial reporting requirements in the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CAUSE: The District experienced turnover in key business office personnel during the last three fiscal years, which resulted in errors in posting federal expenditures to the appropriate general ledger account codes. This further lead to inaccurate reporting as outlined above. QUESTIONED COST: None RECOMMENDATION: I recommend that the District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance and PDE regulations. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. This is a repeat finding from (2023-003) from the previous fiscal year. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 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 sections 200.328 and 200.329 of the Uniform Guidance. EFFECT: The District was not in compliance with the financial reporting requirements in the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CAUSE: The District experienced turnover in key business office personnel during the last three fiscal years, which resulted in errors in posting federal expenditures to the appropriate general ledger account codes. This further lead to inaccurate reporting as outlined above. QUESTIONED COST: None RECOMMENDATION: I recommend that the District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance and PDE regulations. VIEW OF RESPONSIBLE OFFICIALS: See Correction Action Plan
Finding 2024-003 – Reporting Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No.: No. 21.027 Federal Award Number: ASST_NON_SLFRP0137_2001 Grant Award Period: 9/1/2022 – 8/31/2024 Pass Through Entity: Los Angeles County - Department of Public Health Repeat Finding: No Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample Criteria As set forth in 2 CFR 200.328 and in 31 CFR Section 35.4(c), entities receiving Coronavirus State and Local Fiscal Recovery Funds are required to submit quarterly and annually project and expenditure reports to meet compliance and reporting responsibilities under the program. As the Foundation is a subrecipient to the County of Los Angeles (the County), section 6.2 and section 7.0 of Exhibit A of the Agreement between the County and the Foundation for American Rescue Plan Act Trauma Prevention Partnerships provides the reporting requirements by the Foundation to the County including, among other things, the expenditures reported to date by the Foundation. 2 CFR 200.303 requires the recipient of federal funds establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition/Context During fiscal the fiscal year ending June 30, 2024, the Foundation overstated expenditures incurred by its two vendors by $203,629 and a corresponding overstatement of $20,363 in indirect costs in the schedule of expenditures of federal awards (SEFA). Additionally, in the June 30, 2024 Quarterly Performance Report to the County, the Foundation overstated the advances to its vendors by $120,000 and understated expenditures incurred by its two vendors by $519,259. Finally, in the June 30, 2024 Quarterly Invoice to the County, the Foundation overstated the amounts advances to its vendors by $120,000 (however the remaining $807,000 of advances were correctly reported.) Management also failed to separately report the actual expenditures incurred by the vendors in the "Contracts" section of the invoice. However, in the total invoiced amount summarized in the invoice for fiscal 2024 approximated the total expenditures on the June 30, 2024 schedule of expenditures of federal awards. Based on our discussion with management, we understand that the Foundation and the County mutually understood that the June 30, 2024 quarterly invoice was preliminary, as it was submitted by CCF prior to the fiscal year-end. Consequently, the Foundation reflected the final expenditures and payments in the September 30, 2024 invoice. In this invoice, the Foundation removed the previously overstated amount of $120,000 of advances to a vendor. Cause The Foundation had reported all of the amounts advanced to its two vendors in the SEFA and in its quarterly reporting to the County with the understanding that those amounts were the actual expenditures incurred by the vendors during the year. Additionally, there were not sufficient controls in place to ensure that the amounts reported in the SEFA and June 30, 2024 quarterly performance report submitted to the County reconciled to the actual expenditures incurred by the Foundation’s vendors for the year ending June 30, 2024. Effect or Potential Effect The expenditures reported in the schedule of expenditures of federal awards for the year ended June 30, 2024 and in quarterly reporting to the County were incorrect. Questioned Costs None noted. Auditors’ Recommendation We recommend that the Foundation strengthen its reconciliation controls between the amounts reported in the SEFA and County invoices to ensure the amounts are accurate and consistently reported. Views of Responsible Officials CCF acknowledges the finding and is implementing corrective measures to strengthen the accuracy and integrity of its financial and programmatic reporting. CCF has enhanced its internal review process and implemented a reconciliation protocol to ensure consistency between internal records and external reports. Finance staff have received additional training, and final reports are now subject to dual validation by both the Compliance and Finance teams prior to submission.
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION - TITLE i GRANTS TO LOCAL EDUCATION AGENCIES FUNDS (FEDERAL ALN 84.010) 2024-005 Internal Control Over Compliance With Federal Reimbursement Submission Deadline Requirements Criteria – 2 CFR § 200.328 requires the Academy to establish and maintain effective internal control over compliance with requirements applicable to federal program reporting, including reimbursement submission requirements applicable to Title I grants. Condition – During our audit, we noted the Academy did not have sufficient controls in place within its Title I federal program to ensure compliance with federal reporting requirements. Questioned Costs – Not applicable. Context – During our testing, we noted for one request for reimbursement, the Academy did not submit the requrest to the MDE by the required deadline. This was not a statistically valid sample. Repeat Finding – This is a current year finding. Cause – This was an oversight by academy personnel. Effect – Noncompliance with reimbursement submission deadline requirements may lead to the Academy not receiving reimbursement in a timely manner or at all. Recommendation – We recommend that the Academy review its internal control procedures relating to reimbursement submission for the Title I program. Internal controls over compliance for this area should include documentation of submission policies and the Uniform Guidance requirements related to submission deadlines. These controls should also include steps to ensure any expenditure with which the Academy expects reimbursement to be submitted in a timely manner. View of Responsible Official and Planned Corrective Actions – The Academy agrees with the finding. The Academy will review and update its policies and procedures relating to reimbursement submission for its federal programs to ensure compliance with the Uniform Guidance in the future. The Academy has separately issued a Corrective Action Plan related to this finding.
AL number: 16.540 AL title: Juvenile Justice and Delinquency Prevention Federal award identification number and year: BSCC 892-22 7/1/2023 - 6/30/2024 Name of federal agency: U.S. Department of Justice Name of pass-through entity: Office of Youth and Community Restoration Repeat finding: No Criteria: According to the OMB Compliance Supplement and 2 CFR § 200.328, nonfederal entities must submit performance and financial reports as required by the terms and conditions of the federal award. These reports must be accurate, complete, and submitted timely, typically on a quarterly or annual basis as specified by the awarding agency. Condition: During our testing, we noted that the Organization submitted a quarterly report beyond the due date established in the award agreement. In addition, the Organization was unable to provide evidence that one quarterly report was submitted. Cause: The Organization lacks a formal internal control to track federal reporting deadlines and ensure timely submission. Effect or potential effect: Late submission of required federal reports may result in noncompliance with award conditions and could impact the Organization’s eligibility for future funding or trigger increased monitoring by the awarding agency. Recommendation: We recommend that the Organization implement a centralized compliance calendar to track all federal reporting deadlines and assign responsibility for preparation and timely submission. Management should also implement a review process to ensure that all reports are accurate and submitted in accordance with federal requirements.
. Reporting Finding Number: 2024-002 Assistance Listing Number and Title COVID-19 Coronavirus State and Local Fiscal Recovery Funds – AL #21.027 Federal Award Identification Number / Year: 2024 Federal Agency: U.S. Department of Treasury Compliance Requirement: Reporting Pass-Through Entity: Ohio Facilities Construction Commission Repeat Finding from Prior Audit? No Noncompliance and Material Weakness 2 CFR 1000.10 gives regulatory effect to the U.S. Department of Treasury for 2 CFR § 200.328 through 200.330 which describe specific procedures non-Federal entities must follow for performance and financial monitoring and reporting of Federal funds. 2 CFR § 200.328 states 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. The Federal awarding agency must use OMB approved common information collections, as applicable, when providing financial and performance reporting information. The District's grant agreement states that the grantee agrees to comply with any reporting obligations established by Treasury, as it relates to this award. Grantee also agrees to comply with any reporting requirements established by the Grantor, the Office of Budget and Management, or the State of Ohio, as it relates to this award. The Grantor has established a reporting workbook that is to be completed for each quarter the District reports. The reporting workbook includes four tabs, two of which are required to be completed for each reporting submission. During testing, the following errors in the completion of the reporting workbook were identified due to a deficient internal control structure: • Two of the District's quarterly reports were improperly certified. • Two of the District's quarterly reports inaccurately presented program expenditures. Failure to properly submit quarterly reports could result in Ohio Facilities Construction Commission taking action against the District for failure to comply with programmatic requirements. The District should implement policies and procedures to review the reports prior to submission to help ensure the reports are complete and accurate.
2024-006 —Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2023-007, 2022-005, 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, 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 three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly financial 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. Management’s Response: The College will submit annual performance reports in a timely manner.
2024-006 —Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2023-007, 2022-005, 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, 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 three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly financial 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. Management’s Response: The College will submit annual performance reports in a timely manner.
2024-006 —Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2023-007, 2022-005, 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, 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 three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly financial 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. Management’s Response: The College will submit annual performance reports in a timely manner.
2024-006 —Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2023-007, 2022-005, 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, 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 three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly financial 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. Management’s Response: The College will submit annual performance reports in a timely manner.
2024-006 —Reporting – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2023-007, 2022-005, 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, 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 three programs. The annual report for ALN 84.031 was inaccurate. In addition, two quarterly financial 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. Management’s Response: The College will submit annual performance reports in a timely manner.
2024-007 —Financial Reporting– Significant Deficiency in Internal Control Over Compliance and Noncompliance Federal program information: Funding agencies: U.S. Department of Education Titles: SFA Cluster-Federal Pell Grant Program ALN Number: 84.063 Award years: 2024 Criteria: According to 2 CFR Section 200.328, nonfederal entities may be required to submit financial reports at least annually as required by the terms of the federal award. In addition, the grant requires origination and disbursement records be submitted to the Common Origination and Disbursement (COD) system. Condition: The College did not submit disbursement records for students as required. Cause: The College was affected by a ransomware attack that restricted access from their system in order to submit the disbursement records to the COD system. Effect: The College is not in compliance with reporting requirements. Questioned Costs: None Context: Disbursement records were not reported for fall 2023 to the COD system. Recommendation: Work with Department of Education to report the disbursement records for the time period not reported to the COD system. Management’s Response: The College will submit disbursement records to the COD system as required.
2 CFR 200.328 states, in part, (c) the recipient or subrecipient must submit financial reports as required by the Federal award. Reports submitted annually by the recipient or subrecipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. (d) The final financial report submitted by the recipient must be due no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must submit a final financial report to a pass-through entity no later than 90 calendar days after the conclusion of the period of performance. See also § 200.344. The Federal agency or pass-through entity may extend the due date for any financial report with justification from the recipient or subrecipient. Further, 2 CFR 200.502(a) states that the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. We noted that the District filed its FY23 final expenditure report by the required deadline. However, the District claimed $476,752 more in expenditures on the final expenditure report than they had identified in eligible expenditures for the program. The District reclassified $476,752 in ESSER expenditures from the general fund into the ESSER fund after the reporting deadline. We noted that this determination was made after the obligation period had ended and without an extension request being made to the pass-through agency, Ohio Department of Education and Workforce (ODEW) to extend the due date. Further, the ESSER expenditures adjusted from the general fund did not align with the object codes budgeted with ODEW through the Comprehensive Continuous Improvement Plan and reported on the final expenditure report. Additionally, system reports originally filed with ODEW along with the final expenditure report did not accurately reflect the expenditures ultimately claimed for the program. We recommend that the District adopt proper procedures to ensure that reported expenditures on the final expenditure report are accurate and obligated by the appropriate deadline. Requests to extend the due date of the reporting requirement should be made when necessary. Further, expenditures should only be made for objects budgeted and approved by ODEW. In instances where reclassifications are made to program expenditures, the District should ensure that revisions to previously submitted reports are made, when necessary.
2024-004 – Reporting Required by the Uniform Grant Guidance Finding Type. Significant Deficiency in Internal Control over Compliance and Immaterial Noncompliance (Reporting) Program. COVID-19 State and Local Fiscal Recovery Funds Cluster (CFDA# 21.027); U.S. Department of Treasury; Passed through State of Oregon Department of Administrative Services. Criteria. Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR sections 200.328 through 200.329. Condition. The District did not submit quarterly reports in compliance with 2 CFR sections 200.328 through 200.329. Cause. The District did not submit quarterly reports in compliance with grant requirements as no internal controls were in place to ensure compliance was maintained. Effect. As a result of this condition, the District did not fully comply with 2 CFR Part 200. Questioned Costs. No costs have been questioned as a result of this finding. Recommendation. We recommend that the District establish internal controls associated with grant reporting requirements to ensure compliance is maintained. View of Responsible Officials. We agree with the recommendation and will develop procedures to comply with the Uniform Guidance applicable to grants
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
Finding 2024-003 Improper Revenue Recognition (Material Weakness) Assistance Listing Number and Title: 84.010 Title I Name of Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 10.553 and 10.555 National School Lunch Breakfast and Lunch Name of Federal Agency: U.S. Department of Agriculture Criteria: Management is responsible for establishing and maintaining effective internal control over financial report-ing. Internal controls should allow management or employees in the normal course of performing their assigned func-tions to prevent or detect material misstatements in the financial reporting of all district funds. 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: During our audit, it was noted that revenue from certain grant-funded programs was not accurately recog-nized between state and federal sources. Specifically: • Some payments of federal revenue was recorded as state revenue, and some payments of state revenue was rec-orded as federal revenue. • In some cases, revenue was not recognized in the correct reporting period. This caused under recognition of current year federal revenue, and grant reimbursement to be therefore to be claimed in duplicate. Cause: Lack of clear procedures for distinguishing and recording revenue streams for blended funding sources. Internal controls to prevent, detect and correct accounting entries for grant revenues were weak or nonexistent allowing errors in reporting of revenues, overclaiming of federal revenues, and distinguishing revenue between state and federal sources. The lack of timely recognition of revenues caused the overclaiming of Title I. The accounting records were retroactively revised during the audit, for federal award and other reporting purposes. Dis-trict management did not have sufficient training or monitoring policies to recognize and correct the deficiency during the fiscal year. Effect or Potential Effect: Not accurately recording transactions timely into the general ledger, may result in transac-tions not being properly reported in the district’s financial statements and the ability to rely on the general ledger for correct and timely information. This may cause misstatement of financial statements, and inappropriate reporting of federal awards. Questioned Cost: No Context: Due to improper recording of financial activity, Title I grant revenues were overclaimed, and general ledger required adjustment for proper state and federal presentation of grant revenues for National School Lunch Program. Repeat of a Prior-Year Finding: No. Recommendation: We recommend that Willamina School District implement accounting staff training programs, and implement a standardized revenue recognition policy that clearly distinguishes between state and federal funding sources. Additionally, we recommend that a reconciliation process be established to ensure all federal, state and matching funds are recorded timely and accurately. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will provide training for staff in order to devise and implement appropriate poli-cies and procedures for accurately recording all financial transactions, including federal award revenues and expendi-tures. Additional internal control policies will be adopted and procedures implemented as on-going improvement efforts are made. Planned Implementation Date: August 1, 2025 Responsible Person: District Business Manager
2024-003 U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - ALN 21.027 Significant Deficiency in Internal Controls Over Compliance 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. An obligation is an order placed for property and services and entering into contracts, subawards, and similar transactions that require payment. Condition: As of the March 31, 2024, reporting date, the Town reported project amounts voted by the Select Board as obligated rather than purchases, contracts and agreements that met the Federal criteria of an obligation. Cause: The Town did not interpret the reporting requirements of the award properly. Effect: The Town’s reporting for obligations were overstated by approximately $520,000. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to reconcile the financial information in the Project and Expenditure reports to the Town’s contract and purchasing files before submission. Views of Responsible Official: Management agrees with the finding.
2024-003 U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - ALN 21.027 Significant Deficiency in Internal Controls Over Compliance 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. An obligation is an order placed for property and services and entering into contracts, subawards, and similar transactions that require payment. Condition: As of the March 31, 2024, reporting date, the Town reported project amounts voted by the Select Board as obligated rather than purchases, contracts and agreements that met the Federal criteria of an obligation. Cause: The Town did not interpret the reporting requirements of the award properly. Effect: The Town’s reporting for obligations were overstated by approximately $520,000. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The Town should implement procedures to reconcile the financial information in the Project and Expenditure reports to the Town’s contract and purchasing files before submission. Views of Responsible Official: Management agrees with the finding.
2024-006 Report Submission Delay Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: In accordance with 2 CFR 200.328, non-Federal entities must submit financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal entity may extend the due date for any financial report. Condition: Two monthly financial reports were submitted after the stated due date. Cause: Monthly reports were generated prior to the due date, but were not reviewed and approved by the deadline for submission. Effect: Reports were not submitted to the grantor in a timely manner and requests for extension of the due date were not made. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: In both instances, the reports were submitted within 5 days of the stated due date. Repeat Finding: No. Recommendation: Reports should be generated sooner to allow time for sufficient review and approval before the due date. When timely submission may not be possible, UAS should request an extension from the grantor by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, UAS should submit reports by the initial stated due date. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-006 Report Submission Delay Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: In accordance with 2 CFR 200.328, non-Federal entities must submit financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal entity may extend the due date for any financial report. Condition: Two monthly financial reports were submitted after the stated due date. Cause: Monthly reports were generated prior to the due date, but were not reviewed and approved by the deadline for submission. Effect: Reports were not submitted to the grantor in a timely manner and requests for extension of the due date were not made. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: In both instances, the reports were submitted within 5 days of the stated due date. Repeat Finding: No. Recommendation: Reports should be generated sooner to allow time for sufficient review and approval before the due date. When timely submission may not be possible, UAS should request an extension from the grantor by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, UAS should submit reports by the initial stated due date. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-006 Report Submission Delay Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: In accordance with 2 CFR 200.328, non-Federal entities must submit financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal entity may extend the due date for any financial report. Condition: Two monthly financial reports were submitted after the stated due date. Cause: Monthly reports were generated prior to the due date, but were not reviewed and approved by the deadline for submission. Effect: Reports were not submitted to the grantor in a timely manner and requests for extension of the due date were not made. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: In both instances, the reports were submitted within 5 days of the stated due date. Repeat Finding: No. Recommendation: Reports should be generated sooner to allow time for sufficient review and approval before the due date. When timely submission may not be possible, UAS should request an extension from the grantor by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, UAS should submit reports by the initial stated due date. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-006 Report Submission Delay Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: In accordance with 2 CFR 200.328, non-Federal entities must submit financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal entity may extend the due date for any financial report. Condition: Two monthly financial reports were submitted after the stated due date. Cause: Monthly reports were generated prior to the due date, but were not reviewed and approved by the deadline for submission. Effect: Reports were not submitted to the grantor in a timely manner and requests for extension of the due date were not made. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: In both instances, the reports were submitted within 5 days of the stated due date. Repeat Finding: No. Recommendation: Reports should be generated sooner to allow time for sufficient review and approval before the due date. When timely submission may not be possible, UAS should request an extension from the grantor by providing a notice of the delay and rationale for the late report, and, if approved, submit the report by the extended deadline. When extensions are not granted, UAS should submit reports by the initial stated due date. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.