2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers Grantor: Department of Health and Human Services, National Institute of Health Cluster: Research and Development Cluster Award Names: Various Award Numbers: Various Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855 Award Year: 2023-2024 Passthrough Entity: Various Criteria: The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report. Condition: Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers: the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days. Cause: For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer. Effect: The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines. Questioned Costs: There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred. Recommendation: We recommend the University review and update its cost transfer policies and procedures to require maintaining a comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines. Management’s Views and Corrective Action Plan: Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for additional details.
FINDING 2024-002 Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Number or Year (or Other Identifying Number): S010A210014 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Condition and Context Direct charges to a federal award are to be for allowable activities and allowable costs made in conformance with the applicable cost principles. The School Corporation did not have a process or internal controls in place to ensure expenditures for the 2021 Title I grant award were for allowable activities and costs and in conformance with the cost principles. The School Corporation was unable to provide supporting documentation for $43,141 worth of expenditures transferred out of the 2021 grant award fund 4121 from July 1, 2022 to December 1, 2022. These expenditures were originally expended from the Title I 2021 grant award fund 4121, requested for reimbursement and then the expenditures were moved to other funds. Because these expenditures were reappropriated, they were not an allowable activity or cost of the 2021 Title I grant award. In addition, the School Corporation was unable to provide supporting documentation for $6,646 worth of certified salary expenditures requested for reimbursement for the same grant award from February 17, 2022 to June 30, 2022. It was determined that this amount was double requested for reimbursement and were not an actual expenditure. The total amount of $49,787 was considered questioned costs. Subsequent to the 2021 Title I grant award, the School Corporation established and implemented a process and internal controls to ensure expenditures for the 2022 and 2023 awards from July 1, 2022 through December 31, 2023, were for allowable activities and costs and in conformance with the cost principles. The vendor expenditures are initiated by the Title I Director and the Title I Administrative Assistant. Payroll is reviewed each pay period by the Title I Administrative Assistant. The Business Manager/Treasurer prepares the reimbursement request using a detailed expenditure report from their accounting system. The Title I Administrative Assistant verifies the information entered into the reimbursement request by also comparing it to the detailed expenditure reports. The Title I Administrative Assistant also reconciles the Title I award to the expenditures. If the Title I Administrative Assistant identifies that a correction of errors needs to be made to a Title I fund, they fill out a Corrections Form. The Title I Director then reviews and signs the form and provides it to the Business Manager/Treasurer to make the correction in the accounting system prior to completing a request for reimbursement. After the corrections have been made, the Title I Administrative Assistant verifies the changes were correctly made. After all corrections are made, the reimbursement request is approved by the Title I Director and then submitted by the Business Manager/Treasurer. INDIANA STATE BOARD OF ACCOUNTS 18 METROPOLITAN SCHOOL DISTRICT OF STEUBEN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) We tested 25 other nonjournal entry expenditures from all three Title I grant awards during the audit period and did not identify any additional noncompliance with these expenditures. The lack of internal controls and supporting documentation was isolated to the 2021 Title I grant award number S010A21001 from February 17, 2022 to December 31, 2022. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." 2 CFR 200.302(b) states in part: "The recipient's and subrecipient's financial management system must provide for the following: . . . (7) Written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the Federal award." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." INDIANA STATE BOARD OF ACCOUNTS 19 METROPOLITAN SCHOOL DISTRICT OF STEUBEN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause A proper system of internal controls was not designed by management of the School Corporation. The School Corporation segregated duties of knowledgeable staff that were involved in the process of purchasing, entering claim information, processing claim and payroll information and using reliable financial data from the accounting system. However, they had not established a process or internal controls, for the 2021 Title I award number S010A21001, to ensure that all accounting corrections were made prior to processing a request for reimbursement. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation could not ensure that only expenditures for allowable activities and costs were made and requested for reimbursement. Any program funds the School Corporation reallocated to other funds or double requested for reimbursement would be unallowable, and the awarding agency could potentially recover them. Questioned Costs Questioned costs in the amount of $49,787 were identified as noted in the Condition and Context. Recommendation We recommended that Management of the School Corporation establish a proper system of internal controls and develop written policies and procedures to ensure that expenditures for all Title I grant awards are for allowable activities and costs, in conformance with the cost principles and support for all expenditures and journal entries is maintained for the date ranges of costs documented on the requests for reimbursement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY 2023, FY 2024 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system, which would include segregation of duties, was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds: micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micropurchase threshold but below the simplified acquisition threshold. Nonfederal entities may establish a micro-purchase threshold higher than the federal threshold of $10,000 as established in the FAR in accordance with 2 CFR 200.320(a)(1)(iv) and (v). The School Corporation established a higher micropurchase threshold of $50,000. The School Corporation self-certified due to meeting the classification of a public institution and established a higher threshold consistent with state law (Indiana threshold of micropurchases is $50,000). Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. Adequate internal controls were not in place over procurements made under the small purchase threshold for one of the two vendors tested during the audit period. The School Corporation made purchases with a vendor in fiscal year 2022-2023 totaling $97,773 and 2023-2024 totaling $59,070 but did not provide audit evidence that price quotations had been requested. Additionally, the School Corporation was not able to provide evidence that internal controls over suspension and debarment procedures were in place. The lack of internal controls was a systemic issue throughout the audit period. The noncompliance was isolated to procurement requirements. INDIANA STATE BOARD OF ACCOUNTS 18 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (1) . . . (iv) Non-Federal entity increase to the micro-purchase threshold up to $50,000. Non-Federal entities may establish a threshold higher than the micro-purchase threshold identified in the FAR in accordance with the requirements of this section. The non-Federal entity may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the Federal awarding agency and auditors in accordance with § 200.334. The self-certification must include a justification, clear identification of the threshold, and supporting documentation of any of the following: (A) A qualification as a low-risk auditee, in accordance with the criteria in § 200.520 for the most recent audit; (B) An annual internal institutional risk assessment to identify, mitigate, and manage financial risks; or, INDIANA STATE BOARD OF ACCOUNTS 19 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (C) For public institutions, a higher threshold consistent with State law. . . ." 2 CFR 180.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person." Indiana Code 5-22-8-3 states in part: "(a) This section applies only if the purchasing agent expects the purchase to be: (1) at least fifty thousand dollars ($50,000); and (2) not more than one hundred fifty thousand dollars ($150,000). . . . (d) If the purchasing agent receives a satisfactory quote, the purchasing agent shall award a contract to the lowest responsible and responsive offeror for each line or class of supplies required. . . ." Cause The School Corporation was not able to provide documentation to demonstrate that quotes were obtained for purchases under the small purchase method. The School Corporation was unable to provide documentation to demonstrate it checked SAM.gov to verify the contractor was not suspended or debarred prior to entering into the contract. The School Corporation did not have proper policies and procedures in place due to being unaware of the grant requirements. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation cannot ensure the contractors paid with federal funds are eligible to participate in federal programs. Any funds the School Corporation used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. The School Corporation cannot ensure that contractors paid under the small purchase method were awarded the best price for their services. This could result in federal funding not providing as many services or projects as possible. Questioned Costs There were no questioned costs identified. INDIANA STATE BOARD OF ACCOUNTS 20 LIBERTY-PERRY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Recommendation We recommended that the School Corporation strengthen its system of internal controls to ensure the proper procurement method is followed and documentation is retained. We recommended the School Corporation document its internal control procedures performed to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. We also recommended strengthening its policies and procedures to ensure appropriate evidence is retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context Internal controls were in place over reporting where two individuals were involved in submitting and reviewing the reports prior to submission. However, the internal controls were not effective in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Reporting. INDIANA STATE BOARD OF ACCOUNTS 24 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation was required to submit an annual data report to the Indiana Department of Education. Data to be submitted includes, but is not limited to, current period expenditure, prior period expenditure, and expenditures per activity. During the audit period, the School Corporation submitted 2021-2022 expenditures for ESSER II - Year 3 and ESSER III - Year 3 instead of reporting 2022-2023 expenditures for ESSER II - Year 3 and ESSER III - Year 3. The lack of effective internal controls was systemic throughout the audit period. The noncompliance was isolated to the ESSER II - Year 3 and ESSER III - Year 3 reporting. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation had policies and procedures in place over proper reporting on its annual data report; however, officials indicated their understanding of the guidance provided as to which year's expenditures were to be reported was different than what was required. INDIANA STATE BOARD OF ACCOUNTS 25 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Expenditures reported on the annual data report for ESSER II and ESSER III year 3 were not accurate. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure expenditures on the annual data reporting for ESSER II and ESSER III are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context Internal controls were in place over reporting where two individuals were involved in submitting and reviewing the reports prior to submission. However, the internal controls were not effective in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Reporting. INDIANA STATE BOARD OF ACCOUNTS 24 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation was required to submit an annual data report to the Indiana Department of Education. Data to be submitted includes, but is not limited to, current period expenditure, prior period expenditure, and expenditures per activity. During the audit period, the School Corporation submitted 2021-2022 expenditures for ESSER II - Year 3 and ESSER III - Year 3 instead of reporting 2022-2023 expenditures for ESSER II - Year 3 and ESSER III - Year 3. The lack of effective internal controls was systemic throughout the audit period. The noncompliance was isolated to the ESSER II - Year 3 and ESSER III - Year 3 reporting. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation had policies and procedures in place over proper reporting on its annual data report; however, officials indicated their understanding of the guidance provided as to which year's expenditures were to be reported was different than what was required. INDIANA STATE BOARD OF ACCOUNTS 25 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Expenditures reported on the annual data report for ESSER II and ESSER III year 3 were not accurate. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure expenditures on the annual data reporting for ESSER II and ESSER III are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context Internal controls were in place over reporting where two individuals were involved in submitting and reviewing the reports prior to submission. However, the internal controls were not effective in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Reporting. INDIANA STATE BOARD OF ACCOUNTS 24 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation was required to submit an annual data report to the Indiana Department of Education. Data to be submitted includes, but is not limited to, current period expenditure, prior period expenditure, and expenditures per activity. During the audit period, the School Corporation submitted 2021-2022 expenditures for ESSER II - Year 3 and ESSER III - Year 3 instead of reporting 2022-2023 expenditures for ESSER II - Year 3 and ESSER III - Year 3. The lack of effective internal controls was systemic throughout the audit period. The noncompliance was isolated to the ESSER II - Year 3 and ESSER III - Year 3 reporting. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation had policies and procedures in place over proper reporting on its annual data report; however, officials indicated their understanding of the guidance provided as to which year's expenditures were to be reported was different than what was required. INDIANA STATE BOARD OF ACCOUNTS 25 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Expenditures reported on the annual data report for ESSER II and ESSER III year 3 were not accurate. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure expenditures on the annual data reporting for ESSER II and ESSER III are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context Internal controls were in place over reporting where two individuals were involved in submitting and reviewing the reports prior to submission. However, the internal controls were not effective in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Reporting. INDIANA STATE BOARD OF ACCOUNTS 24 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation was required to submit an annual data report to the Indiana Department of Education. Data to be submitted includes, but is not limited to, current period expenditure, prior period expenditure, and expenditures per activity. During the audit period, the School Corporation submitted 2021-2022 expenditures for ESSER II - Year 3 and ESSER III - Year 3 instead of reporting 2022-2023 expenditures for ESSER II - Year 3 and ESSER III - Year 3. The lack of effective internal controls was systemic throughout the audit period. The noncompliance was isolated to the ESSER II - Year 3 and ESSER III - Year 3 reporting. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation had policies and procedures in place over proper reporting on its annual data report; however, officials indicated their understanding of the guidance provided as to which year's expenditures were to be reported was different than what was required. INDIANA STATE BOARD OF ACCOUNTS 25 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Expenditures reported on the annual data report for ESSER II and ESSER III year 3 were not accurate. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure expenditures on the annual data reporting for ESSER II and ESSER III are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context Internal controls were in place over reporting where two individuals were involved in submitting and reviewing the reports prior to submission. However, the internal controls were not effective in order to ensure compliance with requirements related to the grant agreement and the following compliance requirement: Reporting. INDIANA STATE BOARD OF ACCOUNTS 24 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation was required to submit an annual data report to the Indiana Department of Education. Data to be submitted includes, but is not limited to, current period expenditure, prior period expenditure, and expenditures per activity. During the audit period, the School Corporation submitted 2021-2022 expenditures for ESSER II - Year 3 and ESSER III - Year 3 instead of reporting 2022-2023 expenditures for ESSER II - Year 3 and ESSER III - Year 3. The lack of effective internal controls was systemic throughout the audit period. The noncompliance was isolated to the ESSER II - Year 3 and ESSER III - Year 3 reporting. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause The School Corporation had policies and procedures in place over proper reporting on its annual data report; however, officials indicated their understanding of the guidance provided as to which year's expenditures were to be reported was different than what was required. INDIANA STATE BOARD OF ACCOUNTS 25 MT. VERNON COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Expenditures reported on the annual data report for ESSER II and ESSER III year 3 were not accurate. Questioned Costs There were no questioned costs identified. Recommendation We recommended the School Corporation's management establish a proper system of internal controls and develop policies and procedures to ensure expenditures on the annual data reporting for ESSER II and ESSER III are accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-006 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the Special Tests and Provisions - Annual Report Card compliance requirement. The School Corporation did not have effective internal controls in place to ensure that documentation regarding the reason for a student being removed from the high school graduation cohort for mobility reasons was prepared, reviewed, and retained. The Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement necessitated that for students removed from the high school graduation cohort for mobility reasons there be proper written documentation to support the identified mobility code. There were 15 students selected for testing. Of the 15 students tested, 1 student did not have the required supporting documentation to substantiate removal from the cohort for mobility reasons. The lack of internal controls, noncompliance, and failure to maintain adequate supporting documentation were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 27 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain documentation from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or is deceased." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." Cause Due to an ineffective internal control system, documentation was not maintained to provide evidence of proper removal of a student from a cohort. Effect Without the proper design or implementation of internal controls, material noncompliance cannot be capable of being prevented or detected and corrected. As a result, proper documentation to support students' mobility was not collected, retained, or provided for audit. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure mobility documentation is collected and retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-006 Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listings Number: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A210014, S010A220014, S010A230014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Annual Report Card, High School Graduation Rate Audit Findings: Material Weakness, Other Matters Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the Special Tests and Provisions - Annual Report Card compliance requirement. The School Corporation did not have effective internal controls in place to ensure that documentation regarding the reason for a student being removed from the high school graduation cohort for mobility reasons was prepared, reviewed, and retained. The Special Tests and Provisions - Annual Report Card, High School Graduation Rate compliance requirement necessitated that for students removed from the high school graduation cohort for mobility reasons there be proper written documentation to support the identified mobility code. There were 15 students selected for testing. Of the 15 students tested, 1 student did not have the required supporting documentation to substantiate removal from the cohort for mobility reasons. The lack of internal controls, noncompliance, and failure to maintain adequate supporting documentation were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 27 HUNTINGTON COUNTY COMMUNITY SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 20 USC 7801(23)(B) states: "To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain documentation from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or is deceased." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." Cause Due to an ineffective internal control system, documentation was not maintained to provide evidence of proper removal of a student from a cohort. Effect Without the proper design or implementation of internal controls, material noncompliance cannot be capable of being prevented or detected and corrected. As a result, proper documentation to support students' mobility was not collected, retained, or provided for audit. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure mobility documentation is collected and retained for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared and submitted by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Due to the lack of effective internal controls, one of the four reports submitted during the audit period was not supported by the School Corporation's records. The following error was noted: For the ESSER III, Year 3 Report, which covered the period July 1, 2022 to June 30, 2023, total expenses reported for Property: Addressing Physical Health and Safety - Mandatory Subgrant funds was $236,023. Total expenses reported for Personnel Services: Meeting Student's Academic, Social, Emotional, and Other Needs was $66,387, for a total of $302,410. This was an overstatement of $271,004. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to the ESSER III, Year 3 Report. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Two employees collaborated on the preparation of the reports, but there was no documented review of the completed reports by someone other than the preparers to detect errors prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 3 Report was not supported by the School Corporation's records. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are supported by the School Corporation's records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared and submitted by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Due to the lack of effective internal controls, one of the four reports submitted during the audit period was not supported by the School Corporation's records. The following error was noted: For the ESSER III, Year 3 Report, which covered the period July 1, 2022 to June 30, 2023, total expenses reported for Property: Addressing Physical Health and Safety - Mandatory Subgrant funds was $236,023. Total expenses reported for Personnel Services: Meeting Student's Academic, Social, Emotional, and Other Needs was $66,387, for a total of $302,410. This was an overstatement of $271,004. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to the ESSER III, Year 3 Report. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Two employees collaborated on the preparation of the reports, but there was no documented review of the completed reports by someone other than the preparers to detect errors prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 3 Report was not supported by the School Corporation's records. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are supported by the School Corporation's records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared and submitted by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Due to the lack of effective internal controls, one of the four reports submitted during the audit period was not supported by the School Corporation's records. The following error was noted: For the ESSER III, Year 3 Report, which covered the period July 1, 2022 to June 30, 2023, total expenses reported for Property: Addressing Physical Health and Safety - Mandatory Subgrant funds was $236,023. Total expenses reported for Personnel Services: Meeting Student's Academic, Social, Emotional, and Other Needs was $66,387, for a total of $302,410. This was an overstatement of $271,004. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to the ESSER III, Year 3 Report. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Two employees collaborated on the preparation of the reports, but there was no documented review of the completed reports by someone other than the preparers to detect errors prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 3 Report was not supported by the School Corporation's records. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are supported by the School Corporation's records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002 Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirement. The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared and submitted by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Due to the lack of effective internal controls, one of the four reports submitted during the audit period was not supported by the School Corporation's records. The following error was noted: For the ESSER III, Year 3 Report, which covered the period July 1, 2022 to June 30, 2023, total expenses reported for Property: Addressing Physical Health and Safety - Mandatory Subgrant funds was $236,023. Total expenses reported for Personnel Services: Meeting Student's Academic, Social, Emotional, and Other Needs was $66,387, for a total of $302,410. This was an overstatement of $271,004. The lack of internal controls was a systemic issue throughout the audit period. Noncompliance was isolated to the ESSER III, Year 3 Report. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for the Federal awards that are renewed quarterly or annual, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.302(b) states in part: "The financial management system of each non-Federal entity must provide for the following . . . (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . ." 34 CFR 76.722 states: "A State may require a subgrantee to submit reports in a manner and format that assists the State in complying with the requirements under 34 CFR 76.720 and in carrying out other responsibilities under the program." Cause A proper system of internal controls was not designed by management of the School Corporation. Two employees collaborated on the preparation of the reports, but there was no documented review of the completed reports by someone other than the preparers to detect errors prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the ESSER III, Year 3 Report was not supported by the School Corporation's records. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the School Corporation establish a proper system of internal controls and develop policies and procedures to ensure that all reports are supported by the School Corporation's records. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Assistance Listings number and name: 84.002 Adult Education—Basic Grants to States Award numbers and years: 24FABASC-412421-01A, July 1, 2023 through June 30, 2024; 24FIELCC-412421-01A, July 1, 2023 through June 30, 2024; 24FIETCO-412421-01A, July 1, 2023 through June 30, 2024; 24FPRLEC-412421-01A, July 1, 2023 through June 30, 2024; 24FIECTC-412421-01A, July 1, 2023 through June 30, 2024 Compliance requirements: Activities Allowed or Unallowed and Allowable Costs / Cost Principles Questioned costs: $52,754 Assistance Listings number and name: 84.031 Higher Education—Institutional Aid Award numbers and years: P031S160090, October 1, 2016 through September 30, 2023; P031S190167, October 1, 2019 through September 30, 2024; P031S200096, October 1, 2020 through September 30, 2025; P031S200281, October 1, 2020 through September 30, 2025; P031C210057, October 1, 2021 through September 30, 2026; P031C210077, October 1, 2021 through September 30, 2026; P031S220015, October 1, 2022 through September 30, 2027; P031S220179, October 1, 2022 through September 30, 2027; P031A230147, October 1, 2023 through September 30, 2028; P031S230158, October 1, 2023 through September 30, 2028 Compliance requirements: Activities allowed or unallowed Questioned costs: $20,411 Federal agency: U.S. Department of Education Total questioned costs: $73,165 Condition—Contrary to federal regulations, State law, and District policies, the District did not always retain documentation supporting the Adult Education—Basic Grants to States and Higher Education—Institutional Aid programs’ payroll costs or approve employee time sheets after the work was performed for these programs. Specifically, the District could not provide documentation to support employees’ pay rates and authorization to perform work for these programs, such as offer letters, contracts, and personnel action forms, or did not approve employee time sheets after the work was performed for 22 of 54 payroll transactions we tested totaling $73,165. See finding 2024-01 in our Report on Internal Controls and Compliance for a similar finding related to the District not reviewing or approving employee timesheets.1 Also, see Table 1 on the next page for further information. Table 1 Summary of the $73,165 of payroll costs the District did not properly support or approve Fiscal year 2024 84.002 Adult Education—Basic Grants to States 84.031 Higher Education—Institutional Aid Total for both programs Total employees tested 35 19 54 Total employees with unsupported pay rates and lack of authorization to perform work for the programs 7 1 8 Total unsupported payroll costs $52,366 $9,636 $62,002 Total employee time sheets lacking approval after the work was performed2 2 12 14 Total unapproved payroll costs $388 $10,775 $11,163 Total number of employees with unsupported or unapproved payroll costs 9 13 22 Total salaries not supported $52,754 $20,411 $73,165 Effect—The District’s failure to retain documentation supporting payroll costs and approve time sheets increased the risk that the $52,754 for the Adult Education—Basic Grants to States and $20,411 for the Higher Education—Institutional Aid programs may not have been spent in accordance with their award terms and conditions. Consequently, the District may be required to return these monies to the federal agency in accordance with federal requirements.3 Further, see Table 2 for information on the overall payroll costs per program during fiscal year 2024 that are at an increased risk of not being spent in accordance with the award terms and conditions. Finally, the District is at risk that this finding applies to other federal programs it administers. Table 2 Calculation of percent of payroll costs to total program expenditures Fiscal year 2024 84.002 Adult Education—Basic Grants to States 84.031 Higher Education—Institutional Aid Total number of employees 279 214 Total payroll costs $3,613,133 $1,984,462 Total program costs $5,026,228 $6,696,263 % of payroll costs to total program costs 72% 30% Cause—The District’s management reported that it did not retain documentation to support employees’ pay rates and authorization to perform work for the federal programs for employees hired prior to 2018 as they were archived and support was no longer available, and some offers for temporary employees were made verbally over the phone and never documented. The District’s policies and procedures lack requirements to document all employment offers, including temporary employment offers. Additionally, as discussed in finding 2024-01 in our Report on Internal Controls and Compliance, some supervisors did not follow District policies and procedures requiring employees’ time sheets to be reviewed and approved either before processing payroll or within 3 business days after receiving a payroll email notification that the employee’s time sheet needed approval.1 Finally, District management did not sufficiently monitor whether each college’s Human Resources Department was enforcing these policies and procedures or verifying that supervisors reviewed and approved employees’ time sheets, as required. Criteria—Federal regulation requires the District to maintain records for salaries and wages charged to federal awards that accurately reflect the work performed to ensure they are accurate, allowable, and properly allocated (2 CFR §200.430[g][1][i]). Also, federal regulation, similar to State law and the District’s record retention policies, requires the District to retain all public records, including those contained in personnel files, related to a federal program for a period of 3 years from the date the program’s final report was submitted to the federal awarding agency or pass-through grantor (2 CFR §200.334).4,5 Further, the District’s written procedures require each employee’s time sheet to be reviewed and approved by the employee’s supervisor either before processing payroll or within 3 business days from receiving a payroll email notification that the employee’s time sheet needs approval. Additionally, each college’s Human Resources Department is responsible for verifying that supervisors review and approve time sheets timely.6 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The District should: 1. Retain documentation for all payroll costs, such as employment agreements or acceptance letters, to demonstrate employees’ salaries and wages are authorized to be charged to federal programs and spent in accordance with the programs’ award terms and conditions. 2. Review the fiscal year 2024 payroll costs for the Adult Education—Basic Grants to States and Higher Education—Institutional Aid programs to ensure they were properly supported and spent in accordance with the award terms and conditions and coordinate with the U.S. Department of Education, as necessary, to adjust future federal reimbursement requests or repay any unallowable costs the District charged to the programs. 3. Enforce and train employees on District written procedures and requirements to: a. Retain all public records, including those contained in personnel files, related to a federal program for a period of 3 years from the date the program’s final report was submitted to the federal awarding agency or pass-through grantor. b. Ensure supervisors review and approve employees’ time sheets, either before payroll is processed or within 3 business days from receiving the payroll email notification that a time sheet needs approval, to verify employees accurately reported their time worked. This review should be performed after the employee performed the work to ensure the payroll costs charged to the programs accurately reflect the work performed and are accurate, allowable, and properly allocated. 4. Update District written procedures to require documentation of all employment offers, including offers for temporary employees. The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Auditor General. (2024). Report on Internal Control and Compliance, June 30, 2024. Phoenix, AZ. https://www.azauditor.gov/sites/default/files/2025-02/MaricopaCountyCommunityCollegeDistrictJune30_2024ReportOnInternalControlAndCompliance.pdf 2 The 14 employee time sheets lacking approval after the work was performed includes 5 time sheets totaling $6,917 for the Higher Education—Institutional Aid program that were never approved by a supervisor and 2 time sheets totaling $388 for the Adult Education—Basic Grants to States program and 7 time sheets totaling $3,858 for the Higher Education—Institutional Aid program that were approved by a supervisor between 1 and 7 days prior to the work being performed by the employee. 3 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the District, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 4 Maricopa County Community College District (MCCCD). (2023). Staff Policy Manual. 5 Arizona State Library, Archives and Public Records. (2023) General Retention Schedule Created for All Public Bodies. Retrieved 3/12/25 from https://apps.azlibrary.gov/files/docs/all_general_schedules_searchable.pdf 6 Maricopa County Community College District (MCCCD). Version 1.1 (2019). Monitoring Time Approvals: Monitoring Procedures.
Assistance Listings number and name: 84.002 Adult Education—Basic Grants to States Award numbers and years: 24FABASC-412421-01A, July 1, 2023 through June 30, 2024; 24FIELCC-412421-01A, July 1, 2023 through June 30, 2024; 24FIETCO-412421-01A, July 1, 2023 through June 30, 2024; 24FPRLEC-412421-01A, July 1, 2023 through June 30, 2024; 24FIECTC-412421-01A, July 1, 2023 through June 30, 2024 Compliance requirements: Activities Allowed or Unallowed and Allowable Costs / Cost Principles Questioned costs: $52,754 Assistance Listings number and name: 84.031 Higher Education—Institutional Aid Award numbers and years: P031S160090, October 1, 2016 through September 30, 2023; P031S190167, October 1, 2019 through September 30, 2024; P031S200096, October 1, 2020 through September 30, 2025; P031S200281, October 1, 2020 through September 30, 2025; P031C210057, October 1, 2021 through September 30, 2026; P031C210077, October 1, 2021 through September 30, 2026; P031S220015, October 1, 2022 through September 30, 2027; P031S220179, October 1, 2022 through September 30, 2027; P031A230147, October 1, 2023 through September 30, 2028; P031S230158, October 1, 2023 through September 30, 2028 Compliance requirements: Activities allowed or unallowed Questioned costs: $20,411 Federal agency: U.S. Department of Education Total questioned costs: $73,165 Condition—Contrary to federal regulations, State law, and District policies, the District did not always retain documentation supporting the Adult Education—Basic Grants to States and Higher Education—Institutional Aid programs’ payroll costs or approve employee time sheets after the work was performed for these programs. Specifically, the District could not provide documentation to support employees’ pay rates and authorization to perform work for these programs, such as offer letters, contracts, and personnel action forms, or did not approve employee time sheets after the work was performed for 22 of 54 payroll transactions we tested totaling $73,165. See finding 2024-01 in our Report on Internal Controls and Compliance for a similar finding related to the District not reviewing or approving employee timesheets.1 Also, see Table 1 on the next page for further information. Table 1 Summary of the $73,165 of payroll costs the District did not properly support or approve Fiscal year 2024 84.002 Adult Education—Basic Grants to States 84.031 Higher Education—Institutional Aid Total for both programs Total employees tested 35 19 54 Total employees with unsupported pay rates and lack of authorization to perform work for the programs 7 1 8 Total unsupported payroll costs $52,366 $9,636 $62,002 Total employee time sheets lacking approval after the work was performed2 2 12 14 Total unapproved payroll costs $388 $10,775 $11,163 Total number of employees with unsupported or unapproved payroll costs 9 13 22 Total salaries not supported $52,754 $20,411 $73,165 Effect—The District’s failure to retain documentation supporting payroll costs and approve time sheets increased the risk that the $52,754 for the Adult Education—Basic Grants to States and $20,411 for the Higher Education—Institutional Aid programs may not have been spent in accordance with their award terms and conditions. Consequently, the District may be required to return these monies to the federal agency in accordance with federal requirements.3 Further, see Table 2 for information on the overall payroll costs per program during fiscal year 2024 that are at an increased risk of not being spent in accordance with the award terms and conditions. Finally, the District is at risk that this finding applies to other federal programs it administers. Table 2 Calculation of percent of payroll costs to total program expenditures Fiscal year 2024 84.002 Adult Education—Basic Grants to States 84.031 Higher Education—Institutional Aid Total number of employees 279 214 Total payroll costs $3,613,133 $1,984,462 Total program costs $5,026,228 $6,696,263 % of payroll costs to total program costs 72% 30% Cause—The District’s management reported that it did not retain documentation to support employees’ pay rates and authorization to perform work for the federal programs for employees hired prior to 2018 as they were archived and support was no longer available, and some offers for temporary employees were made verbally over the phone and never documented. The District’s policies and procedures lack requirements to document all employment offers, including temporary employment offers. Additionally, as discussed in finding 2024-01 in our Report on Internal Controls and Compliance, some supervisors did not follow District policies and procedures requiring employees’ time sheets to be reviewed and approved either before processing payroll or within 3 business days after receiving a payroll email notification that the employee’s time sheet needed approval.1 Finally, District management did not sufficiently monitor whether each college’s Human Resources Department was enforcing these policies and procedures or verifying that supervisors reviewed and approved employees’ time sheets, as required. Criteria—Federal regulation requires the District to maintain records for salaries and wages charged to federal awards that accurately reflect the work performed to ensure they are accurate, allowable, and properly allocated (2 CFR §200.430[g][1][i]). Also, federal regulation, similar to State law and the District’s record retention policies, requires the District to retain all public records, including those contained in personnel files, related to a federal program for a period of 3 years from the date the program’s final report was submitted to the federal awarding agency or pass-through grantor (2 CFR §200.334).4,5 Further, the District’s written procedures require each employee’s time sheet to be reviewed and approved by the employee’s supervisor either before processing payroll or within 3 business days from receiving a payroll email notification that the employee’s time sheet needs approval. Additionally, each college’s Human Resources Department is responsible for verifying that supervisors review and approve time sheets timely.6 Finally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The District should: 1. Retain documentation for all payroll costs, such as employment agreements or acceptance letters, to demonstrate employees’ salaries and wages are authorized to be charged to federal programs and spent in accordance with the programs’ award terms and conditions. 2. Review the fiscal year 2024 payroll costs for the Adult Education—Basic Grants to States and Higher Education—Institutional Aid programs to ensure they were properly supported and spent in accordance with the award terms and conditions and coordinate with the U.S. Department of Education, as necessary, to adjust future federal reimbursement requests or repay any unallowable costs the District charged to the programs. 3. Enforce and train employees on District written procedures and requirements to: a. Retain all public records, including those contained in personnel files, related to a federal program for a period of 3 years from the date the program’s final report was submitted to the federal awarding agency or pass-through grantor. b. Ensure supervisors review and approve employees’ time sheets, either before payroll is processed or within 3 business days from receiving the payroll email notification that a time sheet needs approval, to verify employees accurately reported their time worked. This review should be performed after the employee performed the work to ensure the payroll costs charged to the programs accurately reflect the work performed and are accurate, allowable, and properly allocated. 4. Update District written procedures to require documentation of all employment offers, including offers for temporary employees. The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 Arizona Auditor General. (2024). Report on Internal Control and Compliance, June 30, 2024. Phoenix, AZ. https://www.azauditor.gov/sites/default/files/2025-02/MaricopaCountyCommunityCollegeDistrictJune30_2024ReportOnInternalControlAndCompliance.pdf 2 The 14 employee time sheets lacking approval after the work was performed includes 5 time sheets totaling $6,917 for the Higher Education—Institutional Aid program that were never approved by a supervisor and 2 time sheets totaling $388 for the Adult Education—Basic Grants to States program and 7 time sheets totaling $3,858 for the Higher Education—Institutional Aid program that were approved by a supervisor between 1 and 7 days prior to the work being performed by the employee. 3 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the District, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 4 Maricopa County Community College District (MCCCD). (2023). Staff Policy Manual. 5 Arizona State Library, Archives and Public Records. (2023) General Retention Schedule Created for All Public Bodies. Retrieved 3/12/25 from https://apps.azlibrary.gov/files/docs/all_general_schedules_searchable.pdf 6 Maricopa County Community College District (MCCCD). Version 1.1 (2019). Monitoring Time Approvals: Monitoring Procedures.
Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education CONDITION: Management did not ensure that all documentation to support the Special Education Cluster was available for audit. CONTEXT: Specifically, we identified the following: The Program Director was unable to provide a grant award or an approved budget for the Special Education Cluster. In addition, the Program Director was unable to provide the maintenance of effort documentation. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that a budget was prepared to obtain a grant award and that documentation was maintained for the Special Education Cluster. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200. EFFECT: Funds were expended for the Special Education Cluster but the auditors were unable to fully determine the allowability due to not having a budget or grant award. In addition, the auditors were unable to determine that maintenance of effort was maintained due to this information not being available. This issue contributed to the disclaimer of opinion on compliance for the Special Education Cluster. REPEAT FINDING: No RECOMMENDATION: Management of the Upshur County Board of Education should follow the guidance set forth in Title 2 U.S. Code of Federal Regulations (CFR) Part 200.
Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education CONDITION: Management did not ensure that all documentation to support the Special Education Cluster was available for audit. CONTEXT: Specifically, we identified the following: The Program Director was unable to provide a grant award or an approved budget for the Special Education Cluster. In addition, the Program Director was unable to provide the maintenance of effort documentation. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that a budget was prepared to obtain a grant award and that documentation was maintained for the Special Education Cluster. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200. EFFECT: Funds were expended for the Special Education Cluster but the auditors were unable to fully determine the allowability due to not having a budget or grant award. In addition, the auditors were unable to determine that maintenance of effort was maintained due to this information not being available. This issue contributed to the disclaimer of opinion on compliance for the Special Education Cluster. REPEAT FINDING: No RECOMMENDATION: Management of the Upshur County Board of Education should follow the guidance set forth in Title 2 U.S. Code of Federal Regulations (CFR) Part 200.
Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education CONDITION: Management did not ensure that all documentation to support the Special Education Cluster was available for audit. CONTEXT: Specifically, we identified the following: The Program Director was unable to provide a grant award or an approved budget for the Special Education Cluster. In addition, the Program Director was unable to provide the maintenance of effort documentation. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that a budget was prepared to obtain a grant award and that documentation was maintained for the Special Education Cluster. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200. EFFECT: Funds were expended for the Special Education Cluster but the auditors were unable to fully determine the allowability due to not having a budget or grant award. In addition, the auditors were unable to determine that maintenance of effort was maintained due to this information not being available. This issue contributed to the disclaimer of opinion on compliance for the Special Education Cluster. REPEAT FINDING: No RECOMMENDATION: Management of the Upshur County Board of Education should follow the guidance set forth in Title 2 U.S. Code of Federal Regulations (CFR) Part 200.
Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education CONDITION: Management did not ensure that all documentation to support the Special Education Cluster was available for audit. CONTEXT: Specifically, we identified the following: The Program Director was unable to provide a grant award or an approved budget for the Special Education Cluster. In addition, the Program Director was unable to provide the maintenance of effort documentation. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that a budget was prepared to obtain a grant award and that documentation was maintained for the Special Education Cluster. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200. EFFECT: Funds were expended for the Special Education Cluster but the auditors were unable to fully determine the allowability due to not having a budget or grant award. In addition, the auditors were unable to determine that maintenance of effort was maintained due to this information not being available. This issue contributed to the disclaimer of opinion on compliance for the Special Education Cluster. REPEAT FINDING: No RECOMMENDATION: Management of the Upshur County Board of Education should follow the guidance set forth in Title 2 U.S. Code of Federal Regulations (CFR) Part 200.
Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.
Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.
Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.
Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.
Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.
Grant Title: Title I Grants to Local Educational Agencies (Title I) Federal Award Number and Year: 2024 Assistance Listing #: 84.010A Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Special Education Cluster: Special Education - Grants to States, Special Education -Preschool Grants, COVID-19 Special Educatin Preschool Grants Federal Award Number and Year: 2024 Assistance Listing #: 84.027A, 84.173, 84.173A and 84.173X Federal Agency: US Department of Education Pass-through Entity number: 43 Pass-through Agency: WV Department of Education Grant Title: Child Nutrition Cluster: School Breakfast Program and National School Lunch Program Federal Award Number and Year: 2024 Assistance Listing #: 10.553 and 10.555 Federal Agency: US Department of Agriculture Pass-through Entity number: 88 Pass-through Agency: WV Department of Education Grant Title: COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Education Stabilization Fund (ESSER) Federal Award Number and Year: 2024 Assistance Listing #: 84.425U, 84.425W Federal Agency: US Department of Education Pass-through Entity number: 52 Pass-through Agency: WV Department of Education CONDITION: Several expenditures were not properly approved by the Federal Program Directors. In addition, signed purchase orders or other supporting documentation were not available for all expenditures. Management did not ensure that expenditures were allowable for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER programs. CONTEXT: Specifically, we identified the following: Sixty non-payroll expenditure transactions were sampled for Title I Grants to Local Education Agencies, of which Two expenditures, or 3% of the sample size, totaling $4,518, did not have Program Director approval prior to payment. Seven expenditures, or 12% of the sample size, totaling $162,988, to one vendor in which the contract was not available for review for contracted services. Three expenditures, or 5% of the sample size, totaling $5,040, which were not supported with adequate documentation. Two expenditures, or 3% of the sample size, totaling $4,525, in which the purchase order was dated after the invoice. Ten non-payroll expenditure transactions were sampled for the COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief (ESSER) Fund - Education Stabilization Fund, of which Five expenditures, or 50% of the sample size, totaling $913,518, did not have Program Director approval prior to payment. Two expenditures, or 20% of the sample size, totaling $28,036, in which the purchase order was dated after the invoice. In addition, we tested 5 employee personnel files with 50 related payroll expenditures for the above federal programs and noted the following items: Three employees did not have a WV IT-104 withholding form. One employee did not have a valid employment contract in their file. Five employees did not have a years of experience ledger in the file in order to recalculate pay. One employee did not have an IRS W-4 withholding form. Sixty non-payroll expenditure transactions were sampled for the Child Nutrition Cluster, of which Two expenditures, or 3% of the sample size, totaling $388,297, did not have Program Director approval prior to payment. Six expenditures, or 10% of the sample size, totaling $57,115, in which the expenditures did not reconcile with the supporting documentation. Forty-one non-payroll expenditure transactions were sampled for the Special Education Cluster, of which Five expenditures, or 12% of the sample size totaling $4,392 in which expenditures were made without a contract or the amounts paid were not provided for in the contract. Six expenditures, or 15% of the sample size, totaling $10,850, in which the purchase order was dated after the invoice. Forty-one expenditures, or 100% could not be traced to a project application. In addition, we tested 7 employee personnel files with 19 related payroll expenditures for the above federal programs and noted the following items: Three employees were paid a total of $219,529 from the Special Education Cluster that should not have been paid with federal funds. Five employees did not have a valid employment contract in their file.Six employees were paid supplements and did not have support in their file. Two employees did not have a valid extra-duty employment contract in their file. Three employees did not have an IRS W-4 withholding form. Four employees did not have a WV IT-104 withholding form. Seven employees did not have a years of experience ledger in the file in order to recalculate pay. CRITERIA: Proper internal controls include maintaining an adequate filing system in order to safeguard records and documents and procedures that ensure all purchases are approved by reconciling a purchase order to the invoice from the vendor prior to payment. Additionally, Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.334 states, in part, that: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient." Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.403 states, in part, that: "Except where otherwise authorized by statue, costs must meet the following general criteria in order to be allowable under Federal Awards: ...(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period... (g) Be adequately documented." QUESTIONED COSTS: Unknown. CAUSE: Procedures were not in place to ensure that invoices and supporting documentation were maintained for all expenditures and that each expenditure was properly approved. Management of the Board does not have controls in place to comply with the Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and Title 34 U.S. Code of Federal Regulations (CFR) Part 75. EFFECT: Certain funds were not expended in accordance with requirements of their respective programs, and auditors were unable to determine the allowability of expenditures due to inadequate documentation. This issue contributed to the disclaimer of opinion on compliance for the Title I, Special Education Cluster, Child Nutrition Cluster, and ESSER Programs. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2023-022 RECOMMENDATION: Board officials should establish and follow procedures to require: All purchase orders be issued prior to the purchase and receipt of the invoice, Contracts for contracted services be available for review, and All personnel files be complete and have adequate support for payroll expenditures.The officials of the Upshur County Board of Education should review the existing procedures and controls over federal award expenditures to determine that these controls are implemented, and working effectively to ensure that expenditures are properly authorized prior to payment. Board officials should ensure that all expenditures are properly authorized by the respective program directors. The Board officials should consider additional training, internal reviews, cross-training of employees, and other measures as deemed appropriate to ensure existing controls are implemented.