CONDITION: During my review of the District’s compliance with the laws and regulations related to filing its federal grant program ‘Quarterly Cash On Hand Reconciliations’, and ‘Final Expenditure Reports (FER)’, I noted that 1) the School District did not file the required Quarterly Cash on Hand Reconciliation for its ESSER and ARP ESSER funding for the 3rd fiscal quarter ending March 31, 2023, and 2) the School District did not file the required Final Expenditure Report (FER) for the ESSER II grant program until December 14, 2023. The report was required to be filed with the Pennsylvania Department of Education (PDE) within 30 days of the close of the grant (September 30, 2023), or as soon as funds are obligated, whichever comes first. CRITERIA: The Department of Education requires the completion of the Quarterly Cash on Hand Reconciliation by the 10th working day after each quarter, and submission of a ‘Final Expenditure Report’ (FER) within 30 days of expending all grant funding. In addition, Section 2 CFR 200.344 of the Uniform Guidance requires the submission of financial reports no later than 90 calendar days after the end date of the grant period for performance (or an earlier date as agreed-upon by the pass-through entity and subrecipient, which in this case is 30 days as required by PDE). EFFECT: The District is not in compliance with the financial reporting requirements for submission and/or timely submission of its Quarterly Cash on Hand Reconciliations for the 3rd fiscal quarter ending March 31, 2023, and the ‘final expenditure report’ (FER) for its ESSER II grant program in accordance with PDE policy and Section 2 CFR 200.344 of the Uniform Guidance. QUESTIONED COST: None CAUSE: The District had a changeover in the business office during the fiscal year and was without a business manager for a period of months, including the 3rd fiscal quarter of the District’s fiscal year which resulted in the oversight of not filing the required Quarterly Cash on Hand Reconciliations. In addition, the process of onboarding the District’s contracted third-party accountants and the necessary time needed to ensure the accuracy of the federal reporting of ESSER II funding, caused a delay in the submission of the Final Expenditure Report (FER). RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Quarterly Cash on Hand Reconciliations’ and ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions such as suspension of grant payments by PDE as a result of not filing these reports in a timely manner. These procedures should include, at a minimum, cross-training of business office personnel with regard to the completion of these reports so that the absence of one individual would not result in these reports not being filed in a timely manner. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
CONDITION: During my review of the District’s compliance with the laws and regulations related to filing its federal grant program ‘Quarterly Cash On Hand Reconciliations’, and ‘Final Expenditure Reports (FER)’, I noted that 1) the School District did not file the required Quarterly Cash on Hand Reconciliation for its ESSER and ARP ESSER funding for the 3rd fiscal quarter ending March 31, 2023, and 2) the School District did not file the required Final Expenditure Report (FER) for the ESSER II grant program until December 14, 2023. The report was required to be filed with the Pennsylvania Department of Education (PDE) within 30 days of the close of the grant (September 30, 2023), or as soon as funds are obligated, whichever comes first. CRITERIA: The Department of Education requires the completion of the Quarterly Cash on Hand Reconciliation by the 10th working day after each quarter, and submission of a ‘Final Expenditure Report’ (FER) within 30 days of expending all grant funding. In addition, Section 2 CFR 200.344 of the Uniform Guidance requires the submission of financial reports no later than 90 calendar days after the end date of the grant period for performance (or an earlier date as agreed-upon by the pass-through entity and subrecipient, which in this case is 30 days as required by PDE). EFFECT: The District is not in compliance with the financial reporting requirements for submission and/or timely submission of its Quarterly Cash on Hand Reconciliations for the 3rd fiscal quarter ending March 31, 2023, and the ‘final expenditure report’ (FER) for its ESSER II grant program in accordance with PDE policy and Section 2 CFR 200.344 of the Uniform Guidance. QUESTIONED COST: None CAUSE: The District had a changeover in the business office during the fiscal year and was without a business manager for a period of months, including the 3rd fiscal quarter of the District’s fiscal year which resulted in the oversight of not filing the required Quarterly Cash on Hand Reconciliations. In addition, the process of onboarding the District’s contracted third-party accountants and the necessary time needed to ensure the accuracy of the federal reporting of ESSER II funding, caused a delay in the submission of the Final Expenditure Report (FER). RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Quarterly Cash on Hand Reconciliations’ and ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions such as suspension of grant payments by PDE as a result of not filing these reports in a timely manner. These procedures should include, at a minimum, cross-training of business office personnel with regard to the completion of these reports so that the absence of one individual would not result in these reports not being filed in a timely manner. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
Federal Agency: Department of Agriculture Federal Program Title: Research and Development Cluster Assistance Listing Number: 10.205, 10.215 Federal Award Identification Number: 2019-38640-29878, NI201445XXXXG009 Award Period: 7/1/22-6/30/23 Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters Condition: The University does not have adequate procedures in place to ensure federal awards are closed in a timely manner. Criteria or specific requirement: Per Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Per 2 CFR 200.344(b), unless the Federal awarding agency or pass-through entity authorizes an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Context: During our testing, we identified 9 transactions out of 40 that were incurred after the period of performance date. Additionally, during our testing, we identified 1 transaction out of 27, that was paid over 120 days after the period of performance had ended. Questioned costs: N/A Cause: The University does not have an effective control in place to ensure costs are properly incurred prior to the end of the federal awards period of performance. Effect: Failure to close federal awards and process necessary cost transfers in a timely manner may result in inaccurate periodic financial reports and unallowable costs. Repeat finding: No Recommendation: We recommend the University review its current close out procedures and implement additional procedures to monitor the timeliness of federal account close outs. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.
CONDITION: During my review of the District’s compliance with the laws and regulations related to filing its federal grant program Final Expenditure Reports (FER), I noted that the School District did not file the Final Expenditure Report for the ESSER I grant program. The report was required to be filed with the Pennsylvania Department of Education (PDE) no later than 90 days after the end date of the grant period (September 30, 2022), or within 30 days of expending all grant funding. CRITERIA: The Department of Education requires the completion and submission of a ‘Final Expenditure Report’ (FER) within 30 days of expending all grant funding. In addition, Section 2 CFR 200.344 of the Uniform Guidance requires the submission of financial reports no later than 90 calendar days after the end date of the grant period for performance. EFFECT: The District is not in compliance with the financial reporting requirements for timely submission of a ‘final expenditure report’ (FER) for its ESSER I grant program in accordance with PDE policy and Section 2 CFR 200.344 of the Uniform Guidance. QUESTIONED COST: None CAUSE: It was not readily determinable as to why the School District had not completed and filed the ‘Final Expenditure Report’ with PDE in a timely manner. RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions or withholding of grant monies from PDE as a result of not filing these reports in a timely manner. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).
2023-004 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster – ALN(s) 84.027 & 84.173 COVID-19 - Special Education Cluster – ALN(s) 84.027X & 84.173X Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2022-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2023-004 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster – ALN(s) 84.027 & 84.173 COVID-19 - Special Education Cluster – ALN(s) 84.027X & 84.173X Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2022-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2023-004 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster – ALN(s) 84.027 & 84.173 COVID-19 - Special Education Cluster – ALN(s) 84.027X & 84.173X Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2022-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2023-004 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster – ALN(s) 84.027 & 84.173 COVID-19 - Special Education Cluster – ALN(s) 84.027X & 84.173X Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2022-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2023-004 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster – ALN(s) 84.027 & 84.173 COVID-19 - Special Education Cluster – ALN(s) 84.027X & 84.173X Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2022-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2023-004 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster – ALN(s) 84.027 & 84.173 COVID-19 - Special Education Cluster – ALN(s) 84.027X & 84.173X Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2022-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2023-004 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster – ALN(s) 84.027 & 84.173 COVID-19 - Special Education Cluster – ALN(s) 84.027X & 84.173X Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2022-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2023-004 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education Special Education Cluster – ALN(s) 84.027 & 84.173 COVID-19 - Special Education Cluster – ALN(s) 84.027X & 84.173X Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial reports were not filed in a timely manner for a Special Education Cluster grant. Cause: A lack of a formal review process for grants in prior years. Effect: The School is not in compliance with federal grant reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Finding 2022-001. Recommendation: We recommend that final financial reports be completed and submitted to the pass-through agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2023-007 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN(s) 84.425D & 84.425U Significant Deficiency in Internal Controls over Compliance Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial report revenues and expenditures were overstated in the Town’s general ledger. Cause: Reconciliations are not properly performed to Town’s general ledger. Effect: The Town’s general ledger balances do not properly reflect federal grant balances. The reporting submitted to the pass-through agency was deemed to be accurate. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should reconcile the final financial reports to the Town’s general ledger prior to submission. Views of Responsible Official: Management agrees with the finding.
2023-007 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN(s) 84.425D & 84.425U Significant Deficiency in Internal Controls over Compliance Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial report revenues and expenditures were overstated in the Town’s general ledger. Cause: Reconciliations are not properly performed to Town’s general ledger. Effect: The Town’s general ledger balances do not properly reflect federal grant balances. The reporting submitted to the pass-through agency was deemed to be accurate. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should reconcile the final financial reports to the Town’s general ledger prior to submission. Views of Responsible Official: Management agrees with the finding.
2023-007 U.S. Department of Education Passed-through the Commonwealth of Massachusetts Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN(s) 84.425D & 84.425U Significant Deficiency in Internal Controls over Compliance Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Final financial report revenues and expenditures were overstated in the Town’s general ledger. Cause: Reconciliations are not properly performed to Town’s general ledger. Effect: The Town’s general ledger balances do not properly reflect federal grant balances. The reporting submitted to the pass-through agency was deemed to be accurate. Questioned Costs: None Repeat Finding from Prior Year: No Recommendation: The School should reconcile the final financial reports to the Town’s general ledger prior to submission. Views of Responsible Official: Management agrees with the finding.
Finding 2023-014 – Noncompliance with Reporting Requirements Over Federal Grant – Coronavirus State and Local Fiscal Recovery Funds (Repeat Finding – 2022-014) PASS-THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Reporting QUESTIONED COSTS: $0 Condition: In the review of fifty-five (55) expenditures for federal programs, five (5) instances were noted where the expenditures were not correctly reported on the Coronavirus State and Local Fiscal Recovery Funds compliance reports. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are properly reported in accordance with federal compliance requirements. Effect of Condition: This condition could result in noncompliance to grant requirements. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Chairman of the Board of County Commissioners: The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants. Criteria: Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (10. Reporting.) reads as follows: 10. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, your organization needs to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. See Part 2 of this guidance for a full overview of recipient reporting responsibilities. Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also § 200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
Finding 2022-013 – Lack of Internal Controls and Noncompliance with Reporting Requirements Over Federal Grant Coronavirus State and Local Fiscal Recovery Funds (Repeat Finding – 2022-013) PASS-THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Reporting QUESTIONED COSTS: $-0- Condition: The County has not established internal controls to ensure the correct expenditure category is used for reporting payments to the grant administrative contractor. The quarterly reports improperly classified payments totaling $177,465 to a contractor as a ‘Revenue Replacement’ expense instead of using the ‘Administrative’ expense category. Also, the quarterly reports improperly classified payments totaling $386,056 for the Resurrection House as a ‘Revenue Replacement’ expense instead of using the ‘Negative Economic Impact’ expense category as stated in the agreement with the Board of County Commissioners. This entity was also not reflected as a Beneficiary in the quarterly reports. Further, subrecipient agreements for the following pass-through entities were signed and approved by the Board of County Commissioners; however, the entities were not reported as subrecipients in the quarterly reports: • Grady County Fairgrounds • Town of Rush Springs • Grady County Rural Water #2 • Grady County Rural Water #6 Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with federal compliance requirements. Effect of Condition: This condition resulted in noncompliance to grant requirements. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Chairman of the Board of County Commissioners: The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants. Criteria: Accountability and stewardship should be overall goals in management’s accounting of federal funds. Internal controls should be designed to monitor compliance with laws and regulations pertaining to grant contracts. Title 2 CFR § 200.303(a) Internal Controls reads (a) reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 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 Controls Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (10. Reporting.) reads as follows: All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. In addition, where appropriate, you organization needs to establish controls to ensure completion and timely submission of all mandatory performance and/or compliance reporting. Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance reports as required by the terms and conditions of the Federal award. See also § 200.344. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
2023-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the prior fiscal years were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The District is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-002. Recommendation: The District should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2023-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the prior fiscal years were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The District is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-002. Recommendation: The District should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2023-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the prior fiscal years were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The District is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-002. Recommendation: The District should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2023-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the prior fiscal years were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The District is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-002. Recommendation: The District should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
2023-003 U.S. Department of Education Passed-through the Commonwealth of Massachusetts’ Department of Elementary and Secondary Education COVID-19 – Education Stabilization Fund – ALN 84.425 Criteria: Per 2 CFR section 200.344(a), a subrecipient must submit to the pass-through agency, no later than 90 calendar days after the end date of the period of performance, all financial, performance and other reports as required by the terms and conditions of the Federal award. Condition: Two final financial reports due during the prior fiscal years were not submitted. Cause: A lack of formal reconciliation and review process for grants. Effect: The District is not in compliance with reporting requirements. Questioned Costs: None Repeat Finding from Prior Year: Yes; Finding 2022-002. Recommendation: The District should implement procedures to verify that reports are completed and submitted to the oversight agency within the prescribed deadlines. Views of Responsible Official: Management agrees with the finding.
Assistance Listing 14.267 Continuum of Care Program Condition: For two out of 51 tested transactions, the Office of Homeless Services (OHS) charged to the grant a total of $63,816 in expenditures that were incurred after the established period of performance. Also, an additional three expenditure transactions were not liquidated within 120 calendar days after the end date of the period of performance; however, we are not questioning costs related to these transactions, as they are otherwise in compliance with period of performance regulations. Funding for this program is received from the U.S. Department of Housing and Urban Development. Criteria: Per 2 CFR section 200.403(h), costs must be incurred during the approved budget period. Also, per 2 CFR section 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a non-federal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award. Effect: Failure to incur expenditures and liquidate financial obligations within the required time period can result in noncompliance for the program as well as questioned costs and repayment obligations. Total expenditures of $63,816 incurred after the period of performance are considered to be known questioned costs. Cause: For most of the transactions noted in the condition, period of performance issues were the result of the timing of vendor invoice submissions. Additionally, OHS expenditure review procedures did not detect the noncompliance. Recommendation:We recommend that OHS improve the efficiency of communications with their vendors to stress the importance of timely invoice submissions. OHS should also strengthen expenditure review procedures to detect future noncompliance. Views of the Responsible Officials and Corrective Action Plan: OHS agrees with the issues outlined, which stem from the delayed processing of invoices and untimely payments. These challenges are largely the result of longstanding issues with over-allocations and the need to catch up on processing a backlog of documents. We appreciate you bringing this to our attention, as it provides an opportunity to refine our procedures and put in place measures to prevent these issues from recurring in the future. This feedback will be valuable as we work to improve our processes and enhance our ability to manage workloads more effectively. Contact Person: Jerome R. Hill, Director of Compliance, Office of Homeless Services, 215-686-0371, 215-520-3556