Finding Number: 2023-005 Program: Research and Development Cluster Federal Agency Name: Department of Agriculture, National Science Foundation, Environmental Protection Agency, Department of Homeland Security, Department of Commerce,Department of Defense and Department of Health and Human Services. Federal Award Year: July 1, 2022 – June 30, 2023 Federal Assistance Listing Numbers: 10.310, 47.041, 47.070, 66.469, 97.077, 11.609, 12.901, 93.913 Finding Type: Significant deficiency and non-compliance Compliance Requirement: Period of Performance Criteria 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 not 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 (2 CFR section 200.344(b)) In accordance with 2 CFR 200.303(a), non-federal entities 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. Condition During our testing of period of performance, we noted that 8 out of 20 transactions tested for grants closed out in FY23 had transactions posted to the grant more than 120 days after the close out of the award or the end of the period of performance. After reviewing the full population of grants that ended during FY23 we noted a total of 8 grants and 47 transactions that were posted to the grant more than 120 days after the close out of the award or the end of the period of performance. Specifically, we noted for 38 of the 47 transactions posted late were to move costs off the grants for a total of ($39,006) and 9 transactions were to add expenses to the grants for a total of $27,266. Cause In discussing this with the University, there was not adequately designed internal controls to ensure grants are closed out timely in accordance with the federal regulations, primarily in times of turnover in staff in the office of sponsored research. Effect Unsupported costs could be charged to a grant after the close out period. Questioned Costs ALN Amount 10.310 $ 1,092 47.041 3 47.070 628 66.469 543 97.077 25,000 Total $ 27,266 Statistical Sampling Our sample was not and was not intended to be statistically valid. Identification of Whether the Audit Finding was a Repeat Finding This was not a repeat finding Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to ensure that grants are closed out timely.
Finding Number: 2023-005 Program: Research and Development Cluster Federal Agency Name: Department of Agriculture, National Science Foundation, Environmental Protection Agency, Department of Homeland Security, Department of Commerce,Department of Defense and Department of Health and Human Services. Federal Award Year: July 1, 2022 – June 30, 2023 Federal Assistance Listing Numbers: 10.310, 47.041, 47.070, 66.469, 97.077, 11.609, 12.901, 93.913 Finding Type: Significant deficiency and non-compliance Compliance Requirement: Period of Performance Criteria 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 not 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 (2 CFR section 200.344(b)) In accordance with 2 CFR 200.303(a), non-federal entities 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. Condition During our testing of period of performance, we noted that 8 out of 20 transactions tested for grants closed out in FY23 had transactions posted to the grant more than 120 days after the close out of the award or the end of the period of performance. After reviewing the full population of grants that ended during FY23 we noted a total of 8 grants and 47 transactions that were posted to the grant more than 120 days after the close out of the award or the end of the period of performance. Specifically, we noted for 38 of the 47 transactions posted late were to move costs off the grants for a total of ($39,006) and 9 transactions were to add expenses to the grants for a total of $27,266. Cause In discussing this with the University, there was not adequately designed internal controls to ensure grants are closed out timely in accordance with the federal regulations, primarily in times of turnover in staff in the office of sponsored research. Effect Unsupported costs could be charged to a grant after the close out period. Questioned Costs ALN Amount 10.310 $ 1,092 47.041 3 47.070 628 66.469 543 97.077 25,000 Total $ 27,266 Statistical Sampling Our sample was not and was not intended to be statistically valid. Identification of Whether the Audit Finding was a Repeat Finding This was not a repeat finding Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to ensure that grants are closed out timely.
Finding Number: 2023-005 Program: Research and Development Cluster Federal Agency Name: Department of Agriculture, National Science Foundation, Environmental Protection Agency, Department of Homeland Security, Department of Commerce,Department of Defense and Department of Health and Human Services. Federal Award Year: July 1, 2022 – June 30, 2023 Federal Assistance Listing Numbers: 10.310, 47.041, 47.070, 66.469, 97.077, 11.609, 12.901, 93.913 Finding Type: Significant deficiency and non-compliance Compliance Requirement: Period of Performance Criteria 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 not 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 (2 CFR section 200.344(b)) In accordance with 2 CFR 200.303(a), non-federal entities 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. Condition During our testing of period of performance, we noted that 8 out of 20 transactions tested for grants closed out in FY23 had transactions posted to the grant more than 120 days after the close out of the award or the end of the period of performance. After reviewing the full population of grants that ended during FY23 we noted a total of 8 grants and 47 transactions that were posted to the grant more than 120 days after the close out of the award or the end of the period of performance. Specifically, we noted for 38 of the 47 transactions posted late were to move costs off the grants for a total of ($39,006) and 9 transactions were to add expenses to the grants for a total of $27,266. Cause In discussing this with the University, there was not adequately designed internal controls to ensure grants are closed out timely in accordance with the federal regulations, primarily in times of turnover in staff in the office of sponsored research. Effect Unsupported costs could be charged to a grant after the close out period. Questioned Costs ALN Amount 10.310 $ 1,092 47.041 3 47.070 628 66.469 543 97.077 25,000 Total $ 27,266 Statistical Sampling Our sample was not and was not intended to be statistically valid. Identification of Whether the Audit Finding was a Repeat Finding This was not a repeat finding Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to ensure that grants are closed out timely.
Finding Number: 2023-005 Program: Research and Development Cluster Federal Agency Name: Department of Agriculture, National Science Foundation, Environmental Protection Agency, Department of Homeland Security, Department of Commerce,Department of Defense and Department of Health and Human Services. Federal Award Year: July 1, 2022 – June 30, 2023 Federal Assistance Listing Numbers: 10.310, 47.041, 47.070, 66.469, 97.077, 11.609, 12.901, 93.913 Finding Type: Significant deficiency and non-compliance Compliance Requirement: Period of Performance Criteria 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 not 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 (2 CFR section 200.344(b)) In accordance with 2 CFR 200.303(a), non-federal entities 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. Condition During our testing of period of performance, we noted that 8 out of 20 transactions tested for grants closed out in FY23 had transactions posted to the grant more than 120 days after the close out of the award or the end of the period of performance. After reviewing the full population of grants that ended during FY23 we noted a total of 8 grants and 47 transactions that were posted to the grant more than 120 days after the close out of the award or the end of the period of performance. Specifically, we noted for 38 of the 47 transactions posted late were to move costs off the grants for a total of ($39,006) and 9 transactions were to add expenses to the grants for a total of $27,266. Cause In discussing this with the University, there was not adequately designed internal controls to ensure grants are closed out timely in accordance with the federal regulations, primarily in times of turnover in staff in the office of sponsored research. Effect Unsupported costs could be charged to a grant after the close out period. Questioned Costs ALN Amount 10.310 $ 1,092 47.041 3 47.070 628 66.469 543 97.077 25,000 Total $ 27,266 Statistical Sampling Our sample was not and was not intended to be statistically valid. Identification of Whether the Audit Finding was a Repeat Finding This was not a repeat finding Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to ensure that grants are closed out timely.
Finding Number: 2023-005 Program: Research and Development Cluster Federal Agency Name: Department of Agriculture, National Science Foundation, Environmental Protection Agency, Department of Homeland Security, Department of Commerce,Department of Defense and Department of Health and Human Services. Federal Award Year: July 1, 2022 – June 30, 2023 Federal Assistance Listing Numbers: 10.310, 47.041, 47.070, 66.469, 97.077, 11.609, 12.901, 93.913 Finding Type: Significant deficiency and non-compliance Compliance Requirement: Period of Performance Criteria 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 not 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 (2 CFR section 200.344(b)) In accordance with 2 CFR 200.303(a), non-federal entities 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. Condition During our testing of period of performance, we noted that 8 out of 20 transactions tested for grants closed out in FY23 had transactions posted to the grant more than 120 days after the close out of the award or the end of the period of performance. After reviewing the full population of grants that ended during FY23 we noted a total of 8 grants and 47 transactions that were posted to the grant more than 120 days after the close out of the award or the end of the period of performance. Specifically, we noted for 38 of the 47 transactions posted late were to move costs off the grants for a total of ($39,006) and 9 transactions were to add expenses to the grants for a total of $27,266. Cause In discussing this with the University, there was not adequately designed internal controls to ensure grants are closed out timely in accordance with the federal regulations, primarily in times of turnover in staff in the office of sponsored research. Effect Unsupported costs could be charged to a grant after the close out period. Questioned Costs ALN Amount 10.310 $ 1,092 47.041 3 47.070 628 66.469 543 97.077 25,000 Total $ 27,266 Statistical Sampling Our sample was not and was not intended to be statistically valid. Identification of Whether the Audit Finding was a Repeat Finding This was not a repeat finding Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to ensure that grants are closed out timely.
Finding Number: 2023-005 Program: Research and Development Cluster Federal Agency Name: Department of Agriculture, National Science Foundation, Environmental Protection Agency, Department of Homeland Security, Department of Commerce,Department of Defense and Department of Health and Human Services. Federal Award Year: July 1, 2022 – June 30, 2023 Federal Assistance Listing Numbers: 10.310, 47.041, 47.070, 66.469, 97.077, 11.609, 12.901, 93.913 Finding Type: Significant deficiency and non-compliance Compliance Requirement: Period of Performance Criteria 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 not 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 (2 CFR section 200.344(b)) In accordance with 2 CFR 200.303(a), non-federal entities 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. Condition During our testing of period of performance, we noted that 8 out of 20 transactions tested for grants closed out in FY23 had transactions posted to the grant more than 120 days after the close out of the award or the end of the period of performance. After reviewing the full population of grants that ended during FY23 we noted a total of 8 grants and 47 transactions that were posted to the grant more than 120 days after the close out of the award or the end of the period of performance. Specifically, we noted for 38 of the 47 transactions posted late were to move costs off the grants for a total of ($39,006) and 9 transactions were to add expenses to the grants for a total of $27,266. Cause In discussing this with the University, there was not adequately designed internal controls to ensure grants are closed out timely in accordance with the federal regulations, primarily in times of turnover in staff in the office of sponsored research. Effect Unsupported costs could be charged to a grant after the close out period. Questioned Costs ALN Amount 10.310 $ 1,092 47.041 3 47.070 628 66.469 543 97.077 25,000 Total $ 27,266 Statistical Sampling Our sample was not and was not intended to be statistically valid. Identification of Whether the Audit Finding was a Repeat Finding This was not a repeat finding Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to ensure that grants are closed out timely.
Finding Number: 2023-005 Program: Research and Development Cluster Federal Agency Name: Department of Agriculture, National Science Foundation, Environmental Protection Agency, Department of Homeland Security, Department of Commerce,Department of Defense and Department of Health and Human Services. Federal Award Year: July 1, 2022 – June 30, 2023 Federal Assistance Listing Numbers: 10.310, 47.041, 47.070, 66.469, 97.077, 11.609, 12.901, 93.913 Finding Type: Significant deficiency and non-compliance Compliance Requirement: Period of Performance Criteria 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 not 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 (2 CFR section 200.344(b)) In accordance with 2 CFR 200.303(a), non-federal entities 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. Condition During our testing of period of performance, we noted that 8 out of 20 transactions tested for grants closed out in FY23 had transactions posted to the grant more than 120 days after the close out of the award or the end of the period of performance. After reviewing the full population of grants that ended during FY23 we noted a total of 8 grants and 47 transactions that were posted to the grant more than 120 days after the close out of the award or the end of the period of performance. Specifically, we noted for 38 of the 47 transactions posted late were to move costs off the grants for a total of ($39,006) and 9 transactions were to add expenses to the grants for a total of $27,266. Cause In discussing this with the University, there was not adequately designed internal controls to ensure grants are closed out timely in accordance with the federal regulations, primarily in times of turnover in staff in the office of sponsored research. Effect Unsupported costs could be charged to a grant after the close out period. Questioned Costs ALN Amount 10.310 $ 1,092 47.041 3 47.070 628 66.469 543 97.077 25,000 Total $ 27,266 Statistical Sampling Our sample was not and was not intended to be statistically valid. Identification of Whether the Audit Finding was a Repeat Finding This was not a repeat finding Recommendation We recommend that the University implement a more thorough and detailed process and related internal controls to ensure that grants are closed out timely.
Lack of Internal Controls and Noncompliance with Reporting Requirements Over Federal Grant Coronavirus State and Local Fiscal Recovery Funds 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 subrecipients. The quarterly reports improperly classified payments totaling $1,600,000 to subrecipients as a ‘Revenue Replacement’ expense instead of using the ‘Infrastructure’ expense category. In addition, it was noted the 2nd Quarter Report was not timely submitted. 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 with 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: 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.
Condition: During the test of 100% of projects, thirty-five (35) projects, for the Coronavirus and Local Fiscal Recovery Funds, the following noncompliance with the Reporting compliance requirement was noted: • Eighteen (18) projects were coded as revenue loss and were a subrecipient relationship. • Seventeen (17) projects were coded as revenue loss and should have been coded to an Administrative code. • Four (4) projects were coded as a subrecipient and should not have been. After the review of the quarterly reports, the following exceptions were noted: • The second quarter report was over reported by $643,303, • 911 Trust Authority reported $195,398 in cumulative expenditures on the report; however, no disbursements were made in fiscal year 2022 or fiscal year 2023. • North West Rogers County Fire Protection District reported $171,219 in cumulative expenditures; however, no disbursements were made in fiscal year 2022 and fiscal year 2023. • Emergency Management reported $333,169 in cumulative expenditures; however, there were only expenditures totaling $18,313. • School Resource Officers reported $135,778 in cumulative expenditures; however, there were only expenditures totaled $41,447. • Expenditures for the jail security electronics upgrade was not reported; however, there were expenditures totaling $132,501. 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 resulted in noncompliance with federal grant guidelines. 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: Board of County Commissioners: The Board of County Commissioners is responsible for the overall fiscal concerns of the county. See OKLA. STAT. Title 19, § 345. The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. These policies and procedures will be designed to identify requirements for recipients and sub-recipients of grants, ensure accurate equipment and real property management, procurement, recipient and subrecipient monitoring and reporting. Further, policies will ensure a proper understanding of all grant requirements and compliance of the same. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration. 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 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 Control 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 outlines in Part 2 of this guidance. Expenditures may be reported on a cash of 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 internal 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: (c)(1) 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 gays 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 Number: 2023-001 Federal Program: COVID-19 ARP Elementary and Secondary School Emergency Relief Federal Award Identification Number and Year: N/A, 2023 Assistance Listing Number (ALN): 84.425U Federal Awarding Agency: U.S. Department of Education Compliance Requirement: Reporting – Final Expenditure Report Pass-through Entity: Ohio Department of Education Repeat Finding: No Significant Deficiency and Noncompliance – Reporting of Final Expenditure Report Criteria: 2 C.F.R. § 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R. § 200.302(b)(2) which states, in part, the financial management system of each non-Federal entity must provide for the accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in § 200.328. 2 C.F.R. § 200.328 states, in part, this information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. 2 C.F.R. § 200.344(a) states, in part, a subrecipient must submit to the pass-through entity, no later than 90 calendar days (or an earlier date as agreed upon by the pass-through entity and subrecipient) 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. Ohio Department of Education Grants Manual requires a final expenditure report (FER) to be submitted to show how grant funds were expended during the grant period for each project immediately after all financial obligations have been liquidated. FERs are to be submitted by September 30. Condition: The Academy did not start and submit the FER until October 3, 2022, three days after the deadline of September 30, 2022. Questioned Costs: None. Identification of How Questioned Costs Were Computed: N/A Context: Auditor reviewed the FER via CCIP and noted the Academy did not start and submit the FER until October 3, 2022, which was three days after the deadline of September 30, 2022. Cause and Effect: The Academy did not have procedures in place to review and submit the Final Expenditure Report timely. As a result, the Academy filed the Final Expenditure Report after the required due date. Recommendation: We recommend that the Academy implement a process to ensure that the Final Expenditure Report is filed by the required due date. Views of Responsible Officials and Corrective Action Plan: See Corrective Action Plan.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(b), the City must liquidate within 60 days after the State's fiscal year end any unpaid year-end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department. Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - Refer to context below. Context - Testing revealed 3 invoices out of 25 were liquidated after the required 60 days for the performance period ended September 30, 2022. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60-day period. As a result, no questioned costs are reported. Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs. Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or Uniform Guidance issued by 0MB (whichever is more restrictive). Views of Responsible Officials and Planned Corrective Actions - The OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved, and processed for payment prior to the 60-day liquidation requirement period.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(b), the City must liquidate within 60 days after the State's fiscal year end any unpaid year-end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department. Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - Refer to context below. Context - Testing revealed 3 invoices out of 25 were liquidated after the required 60 days for the performance period ended September 30, 2022. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60-day period. As a result, no questioned costs are reported. Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs. Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or Uniform Guidance issued by 0MB (whichever is more restrictive). Views of Responsible Officials and Planned Corrective Actions - The OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved, and processed for payment prior to the 60-day liquidation requirement period.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(b), the City must liquidate within 60 days after the State's fiscal year end any unpaid year-end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department. Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - Refer to context below. Context - Testing revealed 3 invoices out of 25 were liquidated after the required 60 days for the performance period ended September 30, 2022. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60-day period. As a result, no questioned costs are reported. Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs. Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or Uniform Guidance issued by 0MB (whichever is more restrictive). Views of Responsible Officials and Planned Corrective Actions - The OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved, and processed for payment prior to the 60-day liquidation requirement period.
Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.344(b), unless the federal awarding agency or pass-through entity authorizes an extension, a nonfederal entity must liquidate all financial obligations incurred under the federal award no later than 120 calendar days after the end of the period of performance, as specified in the terms and conditions of the federal award. However, as outlined within the grant award from the Michigan Department of Health and Human Services and more restrictive than 2 CFR 200.344(b), the City must liquidate within 60 days after the State's fiscal year end any unpaid year-end commitments and obligations. Any obligation remaining unliquidated after 60 days from the end of the period shall revert to the State for disposition in accordance with applicable state and/or federal requirements, except as specifically authorized in writing by the department. Condition - The City did not have adequate controls in place to ensure obligations were liquidated (paid) within the required 60 days. Questioned Costs - None Identification of How Questioned Costs Were Computed - Refer to context below. Context - Testing revealed 3 invoices out of 25 were liquidated after the required 60 days for the performance period ended September 30, 2022. Based on email communication received by the City from the Michigan Department of Health and Human Services, the department granted the City retroactive approval to allow for the expenses despite being liquidated after the 60-day period. As a result, no questioned costs are reported. Cause and Effect - Failure to comply with the terms and conditions of the grant agreement, including the liquidation provisions, may result in disallowed costs and the need to repay the funder for such costs. Recommendation - We recommend the City ensure controls are in place to comply with liquidation requirements outlined in the award agreements and/or Uniform Guidance issued by 0MB (whichever is more restrictive). Views of Responsible Officials and Planned Corrective Actions - The OCFO will work with the Health Department to implement additional controls to ensure all subrecipients and contractors submit invoices timely and that they are reviewed, approved, and processed for payment prior to the 60-day liquidation requirement period.
Finding 2023-002 – Significant Deficiency Assistance List Number: 97.039 – Hazzard Mitigation Grant Pass-through Agency: California Governor’s Office of Emergency Services, FEMA-4344-DR-CA. Compliance Requirement: Reporting. Condition: The District did not provide project closeout materials to the pass-through agency within 90 days of the end of the period of performance so the pass-through agency could prepare the closeout reporting within 120 days of the end of the period of performance. Criteria: The Notice of Funding Opportunity indicates: “In addition, pass-through entities are responsible for closing out their subawards as described in 2 C.F.R. § 200.344; subrecipients are still required to submit closeout materials within 90 calendar days of the period of performance end date. When a subrecipient completes all closeout requirements, pass-through entities must promptly complete all closeout actions for subawards in time for the recipient to submit all necessary documentation and information to FEMA during the closeout of the prime award.” Cause: The District’s staff were waiting for a requested extension for the period of performance from the pass-through agency and assumed the closeout reporting would not be necessary. Effect: The District is not in compliance with the terms and conditions of the federal award. Recommendation: We understand the District provided the information to the pass-through agency necessary to complete the closeout reporting on November 30, 2023. Views of Responsible Officials and Planned Corrective Actions: Management’s response and planned corrective action is included in the Corrective Action Plan included at the end of the report.
FINDING: 2023-004 – Internal Control and Compliance over Period of Performance Federal Agency: Department of Health and Human Services Pass-through Agency: Pennsylvania Department of Community and Economic Development Program: 93.569 Community Services Block Grant and 93.569 COVID-19: Community Services Block Grant Statement of Condition: The Partnership drew federal CSBG funds in December 2022 in the amount of $36,853 to be used for an equipment purchase. The funds were not yet obligated for the purchase, as no contract was in place and Board approval was not yet obtained. In accordance with compliance requirements for CSBG funds, funds granted by the state to subgrantees are available to the subgrantee for obligation during the federal fiscal year that the grant was made and in the following federal fiscal year. Funds were not obligated within the appropriate time period (as of December 31, 2023). Criteria: In accordance with Uniform Guidance period of performance requirements found in 2 CFR section 200.1, 200.308, 200.309, and 200.344, the Partnership is required to ensure that funds are obligated with the required time frame of the period of performance. Effect: The Partnership was not in compliance with the period of performance requirements of the Uniform Guidance. Cause: Procedures in place to ensure that funds were utilized in the proper period of performance were not adequate. Questioned Costs: Unknown Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Partnership establish procedures to ensure the funds are obligated and utilized in the proper period of performance. Views of responsible officials and planned corrective action: Management agrees with the finding. See attached corrective action plan.
FINDING: 2023-004 – Internal Control and Compliance over Period of Performance Federal Agency: Department of Health and Human Services Pass-through Agency: Pennsylvania Department of Community and Economic Development Program: 93.569 Community Services Block Grant and 93.569 COVID-19: Community Services Block Grant Statement of Condition: The Partnership drew federal CSBG funds in December 2022 in the amount of $36,853 to be used for an equipment purchase. The funds were not yet obligated for the purchase, as no contract was in place and Board approval was not yet obtained. In accordance with compliance requirements for CSBG funds, funds granted by the state to subgrantees are available to the subgrantee for obligation during the federal fiscal year that the grant was made and in the following federal fiscal year. Funds were not obligated within the appropriate time period (as of December 31, 2023). Criteria: In accordance with Uniform Guidance period of performance requirements found in 2 CFR section 200.1, 200.308, 200.309, and 200.344, the Partnership is required to ensure that funds are obligated with the required time frame of the period of performance. Effect: The Partnership was not in compliance with the period of performance requirements of the Uniform Guidance. Cause: Procedures in place to ensure that funds were utilized in the proper period of performance were not adequate. Questioned Costs: Unknown Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Partnership establish procedures to ensure the funds are obligated and utilized in the proper period of performance. Views of responsible officials and planned corrective action: Management agrees with the finding. See attached corrective action plan.
(2023-062) Title: Internal control over Special Education period of performance needs improvement Prior Year Findings: None State Department: Education Administrative and Financial Services State Bureau: Special Services & Inclusive Education General Government Service Center Federal Agency: U.S. Department of Education Assistance Listing Title: Special Education Cluster (IDEA) (COVID-19) Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Allowable costs/cost principles Period of performance Type of Finding: Material weakness Material noncompliance Questioned costs Known Questioned Costs: $2,446,391 Likely Questioned Costs: Undeterminable; the exceptions noted in our sample represent nonroutine transactions; therefore, the projection of questioned costs utilizing the error rate related to known exceptions and amounts tested would not produce a reasonable estimate of likely questioned costs. Criteria: 2 CFR 200.303; 2 CFR 200.344; 2 CFR 200.403; 34 CFR 76.703 and .709 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. Unless the Federal awarding agency authorizes an extension, the Department 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. To be allowable under Federal awards, costs must be necessary and reasonable for the performance of the Federal award and be adequately documented. The Department must obligate Federal award funds during the 27-month period of performance, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. Condition: The Department of Education’s (DOE) Office of Special Services & Inclusive Education, in conjunction with the Department of Administrative and Financial Services’ General Government Service Center (GGSC), administers Federal funding received through the Special Education Cluster (SEC) program. The SEC program provides grants to states, and through them to Local Education Agencies (LEAs), to assist in providing special education and related services to eligible children. DOE and GGSC review and approve requests for reimbursement from LEAs and invoices for other costs including payroll, administrative expenditures, and awards to subrecipients of State-level activities. This review includes a determination of whether the costs are obligated within the applicable Federal award’s period of performance through a comparison of billing dates and billing periods to grant award terms. Period of performance compliance requirements applicable to the SEC program in fiscal year 2023 relate to the Federal fiscal year 2021 grant award. The award’s obligation period ended September 30, 2022, and the liquidation period ended 120 calendar days following, on January 28, 2023. The Office of the State Auditor (OSA) tested 43 expenditure transactions that occurred during the Federal fiscal year 2021 grant award’s liquidation period to ensure that the expenditures were obligated and liquidated in accordance with Federal regulations, and identified the following: • Six transactions related to an obligation that occurred after the end of the period of performance. Upon further review, OSA determined that the full obligation included 20 transactions totaling $1.7 million. • Three obligations totaling $742,668 were liquidated after expiration of the liquidation period. The above-noted transactions did not meet the Federal fiscal year 2021 grant award’s period of performance requirements and are not allowable under the terms of the award. As a result, OSA identified questioned costs totaling $2.4 million. OSA selected a non-statistical random sample. Context: In fiscal year 2023, the Department expended $71.6 million in SEC program funds. Of this total, $5.1 million of Federal fiscal year 2021 grant funds was expended during the award’s liquidation period which occurred during fiscal year 2023. The identified questioned costs of $2.4 million represent approximately 47 percent of the award funds expended during the liquidation period. Cause: • Lack of adequate policies and procedures • Lack of supervisory oversight Effect: • Known questioned costs • Potential future questioned costs and disallowances • Noncompliance with Federal regulations Recommendation: We recommend that the Department enhance policies and procedures to ensure that obligation and liquidation of grant funds are made within period of performance requirements established in the terms and conditions of Federal grant awards. Corrective Action Plan: See F-27 Management’s Response: The Department agrees with this finding. The Department will review and implement stronger internal controls to ensure obligations and final payments are made within the period of performance requirements. Regarding the 20 transactions totaling $1.7 million, all expenditures reimbursed were within the period of performance, however there was a lengthy delay in determining the final payment mechanism. Due to this delay, the final obligation date in Advantage was outside of the grant's date of obligation. Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161 (State Number: 23-1201-02)
(2023-062) Title: Internal control over Special Education period of performance needs improvement Prior Year Findings: None State Department: Education Administrative and Financial Services State Bureau: Special Services & Inclusive Education General Government Service Center Federal Agency: U.S. Department of Education Assistance Listing Title: Special Education Cluster (IDEA) (COVID-19) Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Allowable costs/cost principles Period of performance Type of Finding: Material weakness Material noncompliance Questioned costs Known Questioned Costs: $2,446,391 Likely Questioned Costs: Undeterminable; the exceptions noted in our sample represent nonroutine transactions; therefore, the projection of questioned costs utilizing the error rate related to known exceptions and amounts tested would not produce a reasonable estimate of likely questioned costs. Criteria: 2 CFR 200.303; 2 CFR 200.344; 2 CFR 200.403; 34 CFR 76.703 and .709 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. Unless the Federal awarding agency authorizes an extension, the Department 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. To be allowable under Federal awards, costs must be necessary and reasonable for the performance of the Federal award and be adequately documented. The Department must obligate Federal award funds during the 27-month period of performance, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. Condition: The Department of Education’s (DOE) Office of Special Services & Inclusive Education, in conjunction with the Department of Administrative and Financial Services’ General Government Service Center (GGSC), administers Federal funding received through the Special Education Cluster (SEC) program. The SEC program provides grants to states, and through them to Local Education Agencies (LEAs), to assist in providing special education and related services to eligible children. DOE and GGSC review and approve requests for reimbursement from LEAs and invoices for other costs including payroll, administrative expenditures, and awards to subrecipients of State-level activities. This review includes a determination of whether the costs are obligated within the applicable Federal award’s period of performance through a comparison of billing dates and billing periods to grant award terms. Period of performance compliance requirements applicable to the SEC program in fiscal year 2023 relate to the Federal fiscal year 2021 grant award. The award’s obligation period ended September 30, 2022, and the liquidation period ended 120 calendar days following, on January 28, 2023. The Office of the State Auditor (OSA) tested 43 expenditure transactions that occurred during the Federal fiscal year 2021 grant award’s liquidation period to ensure that the expenditures were obligated and liquidated in accordance with Federal regulations, and identified the following: • Six transactions related to an obligation that occurred after the end of the period of performance. Upon further review, OSA determined that the full obligation included 20 transactions totaling $1.7 million. • Three obligations totaling $742,668 were liquidated after expiration of the liquidation period. The above-noted transactions did not meet the Federal fiscal year 2021 grant award’s period of performance requirements and are not allowable under the terms of the award. As a result, OSA identified questioned costs totaling $2.4 million. OSA selected a non-statistical random sample. Context: In fiscal year 2023, the Department expended $71.6 million in SEC program funds. Of this total, $5.1 million of Federal fiscal year 2021 grant funds was expended during the award’s liquidation period which occurred during fiscal year 2023. The identified questioned costs of $2.4 million represent approximately 47 percent of the award funds expended during the liquidation period. Cause: • Lack of adequate policies and procedures • Lack of supervisory oversight Effect: • Known questioned costs • Potential future questioned costs and disallowances • Noncompliance with Federal regulations Recommendation: We recommend that the Department enhance policies and procedures to ensure that obligation and liquidation of grant funds are made within period of performance requirements established in the terms and conditions of Federal grant awards. Corrective Action Plan: See F-27 Management’s Response: The Department agrees with this finding. The Department will review and implement stronger internal controls to ensure obligations and final payments are made within the period of performance requirements. Regarding the 20 transactions totaling $1.7 million, all expenditures reimbursed were within the period of performance, however there was a lengthy delay in determining the final payment mechanism. Due to this delay, the final obligation date in Advantage was outside of the grant's date of obligation. Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161 (State Number: 23-1201-02)
(2023-062) Title: Internal control over Special Education period of performance needs improvement Prior Year Findings: None State Department: Education Administrative and Financial Services State Bureau: Special Services & Inclusive Education General Government Service Center Federal Agency: U.S. Department of Education Assistance Listing Title: Special Education Cluster (IDEA) (COVID-19) Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Allowable costs/cost principles Period of performance Type of Finding: Material weakness Material noncompliance Questioned costs Known Questioned Costs: $2,446,391 Likely Questioned Costs: Undeterminable; the exceptions noted in our sample represent nonroutine transactions; therefore, the projection of questioned costs utilizing the error rate related to known exceptions and amounts tested would not produce a reasonable estimate of likely questioned costs. Criteria: 2 CFR 200.303; 2 CFR 200.344; 2 CFR 200.403; 34 CFR 76.703 and .709 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. Unless the Federal awarding agency authorizes an extension, the Department 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. To be allowable under Federal awards, costs must be necessary and reasonable for the performance of the Federal award and be adequately documented. The Department must obligate Federal award funds during the 27-month period of performance, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. Condition: The Department of Education’s (DOE) Office of Special Services & Inclusive Education, in conjunction with the Department of Administrative and Financial Services’ General Government Service Center (GGSC), administers Federal funding received through the Special Education Cluster (SEC) program. The SEC program provides grants to states, and through them to Local Education Agencies (LEAs), to assist in providing special education and related services to eligible children. DOE and GGSC review and approve requests for reimbursement from LEAs and invoices for other costs including payroll, administrative expenditures, and awards to subrecipients of State-level activities. This review includes a determination of whether the costs are obligated within the applicable Federal award’s period of performance through a comparison of billing dates and billing periods to grant award terms. Period of performance compliance requirements applicable to the SEC program in fiscal year 2023 relate to the Federal fiscal year 2021 grant award. The award’s obligation period ended September 30, 2022, and the liquidation period ended 120 calendar days following, on January 28, 2023. The Office of the State Auditor (OSA) tested 43 expenditure transactions that occurred during the Federal fiscal year 2021 grant award’s liquidation period to ensure that the expenditures were obligated and liquidated in accordance with Federal regulations, and identified the following: • Six transactions related to an obligation that occurred after the end of the period of performance. Upon further review, OSA determined that the full obligation included 20 transactions totaling $1.7 million. • Three obligations totaling $742,668 were liquidated after expiration of the liquidation period. The above-noted transactions did not meet the Federal fiscal year 2021 grant award’s period of performance requirements and are not allowable under the terms of the award. As a result, OSA identified questioned costs totaling $2.4 million. OSA selected a non-statistical random sample. Context: In fiscal year 2023, the Department expended $71.6 million in SEC program funds. Of this total, $5.1 million of Federal fiscal year 2021 grant funds was expended during the award’s liquidation period which occurred during fiscal year 2023. The identified questioned costs of $2.4 million represent approximately 47 percent of the award funds expended during the liquidation period. Cause: • Lack of adequate policies and procedures • Lack of supervisory oversight Effect: • Known questioned costs • Potential future questioned costs and disallowances • Noncompliance with Federal regulations Recommendation: We recommend that the Department enhance policies and procedures to ensure that obligation and liquidation of grant funds are made within period of performance requirements established in the terms and conditions of Federal grant awards. Corrective Action Plan: See F-27 Management’s Response: The Department agrees with this finding. The Department will review and implement stronger internal controls to ensure obligations and final payments are made within the period of performance requirements. Regarding the 20 transactions totaling $1.7 million, all expenditures reimbursed were within the period of performance, however there was a lengthy delay in determining the final payment mechanism. Due to this delay, the final obligation date in Advantage was outside of the grant's date of obligation. Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161 (State Number: 23-1201-02)
(2023-062) Title: Internal control over Special Education period of performance needs improvement Prior Year Findings: None State Department: Education Administrative and Financial Services State Bureau: Special Services & Inclusive Education General Government Service Center Federal Agency: U.S. Department of Education Assistance Listing Title: Special Education Cluster (IDEA) (COVID-19) Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Allowable costs/cost principles Period of performance Type of Finding: Material weakness Material noncompliance Questioned costs Known Questioned Costs: $2,446,391 Likely Questioned Costs: Undeterminable; the exceptions noted in our sample represent nonroutine transactions; therefore, the projection of questioned costs utilizing the error rate related to known exceptions and amounts tested would not produce a reasonable estimate of likely questioned costs. Criteria: 2 CFR 200.303; 2 CFR 200.344; 2 CFR 200.403; 34 CFR 76.703 and .709 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. Unless the Federal awarding agency authorizes an extension, the Department 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. To be allowable under Federal awards, costs must be necessary and reasonable for the performance of the Federal award and be adequately documented. The Department must obligate Federal award funds during the 27-month period of performance, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. Condition: The Department of Education’s (DOE) Office of Special Services & Inclusive Education, in conjunction with the Department of Administrative and Financial Services’ General Government Service Center (GGSC), administers Federal funding received through the Special Education Cluster (SEC) program. The SEC program provides grants to states, and through them to Local Education Agencies (LEAs), to assist in providing special education and related services to eligible children. DOE and GGSC review and approve requests for reimbursement from LEAs and invoices for other costs including payroll, administrative expenditures, and awards to subrecipients of State-level activities. This review includes a determination of whether the costs are obligated within the applicable Federal award’s period of performance through a comparison of billing dates and billing periods to grant award terms. Period of performance compliance requirements applicable to the SEC program in fiscal year 2023 relate to the Federal fiscal year 2021 grant award. The award’s obligation period ended September 30, 2022, and the liquidation period ended 120 calendar days following, on January 28, 2023. The Office of the State Auditor (OSA) tested 43 expenditure transactions that occurred during the Federal fiscal year 2021 grant award’s liquidation period to ensure that the expenditures were obligated and liquidated in accordance with Federal regulations, and identified the following: • Six transactions related to an obligation that occurred after the end of the period of performance. Upon further review, OSA determined that the full obligation included 20 transactions totaling $1.7 million. • Three obligations totaling $742,668 were liquidated after expiration of the liquidation period. The above-noted transactions did not meet the Federal fiscal year 2021 grant award’s period of performance requirements and are not allowable under the terms of the award. As a result, OSA identified questioned costs totaling $2.4 million. OSA selected a non-statistical random sample. Context: In fiscal year 2023, the Department expended $71.6 million in SEC program funds. Of this total, $5.1 million of Federal fiscal year 2021 grant funds was expended during the award’s liquidation period which occurred during fiscal year 2023. The identified questioned costs of $2.4 million represent approximately 47 percent of the award funds expended during the liquidation period. Cause: • Lack of adequate policies and procedures • Lack of supervisory oversight Effect: • Known questioned costs • Potential future questioned costs and disallowances • Noncompliance with Federal regulations Recommendation: We recommend that the Department enhance policies and procedures to ensure that obligation and liquidation of grant funds are made within period of performance requirements established in the terms and conditions of Federal grant awards. Corrective Action Plan: See F-27 Management’s Response: The Department agrees with this finding. The Department will review and implement stronger internal controls to ensure obligations and final payments are made within the period of performance requirements. Regarding the 20 transactions totaling $1.7 million, all expenditures reimbursed were within the period of performance, however there was a lengthy delay in determining the final payment mechanism. Due to this delay, the final obligation date in Advantage was outside of the grant's date of obligation. Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161 (State Number: 23-1201-02)
Questioned Costs $- Finding No. 2023‐003: Cash Management (Control Deficiency) Period of Performance (Control Deficiency) Federal Agency: U.S. National Endowment for the Humanities Assistance Listing Number and Title: 45.310 – Grants to State Condition During our audit, we noted the following instances of noncompliance: Cash Management We selected 8 federal cash receipts and identified 9 instances totaling approximately $1,594,000 in which the time elapsing between the receipt of federal funds and the disbursement of amounts within the aggregate cash receipt to an individual vendor was greater than 30 days. Period of Performance We selected 40 disbursements for testing and identified 2 instances totaling approximately $40,000 in which expenditures were made outside of the award period. Criteria Cash Management U.S. Department of the Treasury Regulations 31 Code of Federal Regulations (“CFR”) Section 205.33 requires the Department to minimize the time between the receipt of federal funds from the federal government and the Department’s disbursement of the funds for federal program purposes. Therefore, the timing and amount of funds being requested and received must be as close as administratively feasible to the Department’s actual cash outlay for direct program costs and the proportionate share of any allowable indirect costs. Period of Performance Title 2 Section 200.344 of the CFR requires final accounting and settlement within 90 days after the end of the federal fiscal year, or upon termination or closeout of an award, whichever is earlier. Cause We were informed by program personnel that due to supply chain issues, invoices were not received in a timely manner which led to the untimely disbursement and expenditure of federal funds. Effect Cash Management The delay in disbursing advances of federal funds prevents the use of those funds for more urgent purposes by the federal government and represents an instance of noncompliance with the requirements of Title 2 U.S. CFR Part 200. Period of Performance The delay in expenditures prevents the granting agency from timely assessing the status and activities of the program and represents an instance of noncompliance with the requirements of Title 2 U.S. CFR Part 200. Context Cash Management A sample of 8 federal cash receipts totaling approximately $2,410,000 were selected for audit from a population of 20 federal cash receipts totaling approximately $3,647,000. Our test found 9 instances in which the Department’s disbursement of the funds within the aggregate cash receipt to an individual vendor was not completed in a timely manner. Our sample was a statistically valid sample. Period of Performance A sample of 40 disbursements totaling approximately $3,547,000 were selected for audit from a population of approximately $3,664,000. Our test found two instances in which expenditures were made outside of the award period. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the Department perform the following to ensure compliance: Cash Management Upon receipt of federal funds, ensure that the subsequent disbursement of such funds occurs in a timely manner. Period of Performance Ensure expenditures of federal funds are made within the grant award period. Cause and View of Responsible Officials During fiscal year 2023, multiple vendors experienced supply chain issues that resulted in untimely deliverables. As a result of these delays, the Department could not disburse funds in a timely manner.
Questioned Costs $- Finding No. 2023‐003: Cash Management (Control Deficiency) Period of Performance (Control Deficiency) Federal Agency: U.S. National Endowment for the Humanities Assistance Listing Number and Title: 45.310 – Grants to State Condition During our audit, we noted the following instances of noncompliance: Cash Management We selected 8 federal cash receipts and identified 9 instances totaling approximately $1,594,000 in which the time elapsing between the receipt of federal funds and the disbursement of amounts within the aggregate cash receipt to an individual vendor was greater than 30 days. Period of Performance We selected 40 disbursements for testing and identified 2 instances totaling approximately $40,000 in which expenditures were made outside of the award period. Criteria Cash Management U.S. Department of the Treasury Regulations 31 Code of Federal Regulations (“CFR”) Section 205.33 requires the Department to minimize the time between the receipt of federal funds from the federal government and the Department’s disbursement of the funds for federal program purposes. Therefore, the timing and amount of funds being requested and received must be as close as administratively feasible to the Department’s actual cash outlay for direct program costs and the proportionate share of any allowable indirect costs. Period of Performance Title 2 Section 200.344 of the CFR requires final accounting and settlement within 90 days after the end of the federal fiscal year, or upon termination or closeout of an award, whichever is earlier. Cause We were informed by program personnel that due to supply chain issues, invoices were not received in a timely manner which led to the untimely disbursement and expenditure of federal funds. Effect Cash Management The delay in disbursing advances of federal funds prevents the use of those funds for more urgent purposes by the federal government and represents an instance of noncompliance with the requirements of Title 2 U.S. CFR Part 200. Period of Performance The delay in expenditures prevents the granting agency from timely assessing the status and activities of the program and represents an instance of noncompliance with the requirements of Title 2 U.S. CFR Part 200. Context Cash Management A sample of 8 federal cash receipts totaling approximately $2,410,000 were selected for audit from a population of 20 federal cash receipts totaling approximately $3,647,000. Our test found 9 instances in which the Department’s disbursement of the funds within the aggregate cash receipt to an individual vendor was not completed in a timely manner. Our sample was a statistically valid sample. Period of Performance A sample of 40 disbursements totaling approximately $3,547,000 were selected for audit from a population of approximately $3,664,000. Our test found two instances in which expenditures were made outside of the award period. Our sample was a statistically valid sample. Repeat Finding This is not a repeat finding. Recommendation We recommend that the Department perform the following to ensure compliance: Cash Management Upon receipt of federal funds, ensure that the subsequent disbursement of such funds occurs in a timely manner. Period of Performance Ensure expenditures of federal funds are made within the grant award period. Cause and View of Responsible Officials During fiscal year 2023, multiple vendors experienced supply chain issues that resulted in untimely deliverables. As a result of these delays, the Department could not disburse funds in a timely manner.
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 II grant program until February 9, 2024. 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, 2023), 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 II 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: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027/84.173 Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22); Award Period: July 1, 2020 through September 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency. Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award. Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance. Questioned costs: The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518. Context: Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022. Cause: Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action. Effect: The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs. Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance. Views of responsible officials: There is no disagreement with the audit finding.