Finding Number: 2024-007 State/Educational Agency(s): Arkansas Department of Agriculture – Natural Resources Division Pass-Through Entity: Not Applicable ALN Number(s) and Program Title(s): 21.027 – COVID 19: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Federal Awarding Agency: U.S. Department of the Treasury Federal Award Number(s): SLFRP3627 Federal Award Year(s): 2021 Compliance Requirement(s) Affected: Allowable Costs/Cost Principles Type of Finding: Noncompliance and Material Weakness Repeat Finding: Not applicable Criteria: In accordance with 2 CFR § 200.403(g), costs must be adequately documented to be allowable under federal awards. In addition, 2 CFR § 200.400(d) states that the accounting practices of the recipient and subrecipient must be consistent with these cost principles and support the accumulation of costs as required by these cost principles, including maintaining adequate documentation to support costs charged to the federal award. Condition and Context: ALA staff reviewed 14 payments to water departments to determine if sufficient, appropriate documentation was maintained to support allowability of infrastructure improvement expenses. ALA review of one of those payments included costs of $26,979 that were not adequately documented. In addition, supporting documentation did not include a complete accumulation of costs that identified amounts charged to the federal award. Statistically Valid Sample: Not a statistically valid sample Questioned Costs: $26,979 Cause: The Agency did not have controls in place to ensure a review of documentation supporting reimbursement requests was properly performed prior to issuing payments. In addition, the Agency did not provide training on Uniform Guidance documentation requirements to staff responsible for reviewing and loading documents into its project management application. Effect: Reimbursements were approved for expenditures that may not have been allowable. The federal awarding agency may require recoupment. Recommendation: ALA staff recommend the Agency strengthen controls to ensure costs are adequately documented. Supporting documentation containing sufficient detail to determine the allowability and nature of the costs incurred by the subrecipient should be reviewed by the Agency prior to reimbursement to ensure compliance with federal regulations. Views of Responsible Officials and Planned Corrective Action: Moving forward the Department will require recipients to provide a list of invoices with the invoice date, period of performance, invoice amount and amount requested/disbursed from ARPA and/or other funding sources to be included with each disbursement request. Staff training will be modified to ensure staff understand allowable expenditures and period of performance restrictions. Anticipated Completion Date: June 30, 2025 Contact Person: Debby Dickson Water Development Division Manager Arkansas Department of Agriculture-Natural Resources Division 1 Natural Resources Drive Little Rock, AR 72205 (501) 225-1598 Debra.Dickson@agriculture.arkansas.gov
FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-PN01, 22611-043-ARP, 22619-043-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2022-2023 the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. INDIANA STATE BOARD OF ACCOUNTS 19 SCHOOL CITY OF HOBART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The nonpublic expenditures spent did not meet the earmarking requirements for grant award numbers 22611-043-PN01, 22611-043-ARP, and 22619-043-ARP. From the beginning of the grant awards until September 2022, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in September 2022, the Cooperative began tracking expenditures by member school for the nonpublic services. As such we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through September 2022, as required. The lack of internal controls and noncompliance was isolated to the 22611-043-PN01, 2611-043-ARP, and 22619-043-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 20 SCHOOL CITY OF HOBART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Through inquiry of Cooperative management, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member school starting in September 2022, most of the grant awards had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation was unable to ensure Cooperative compliance with earmarking requirements and the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school by the Cooperative. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the Earmarking compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-PN01, 22611-043-ARP, 22619-043-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2022-2023 the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. INDIANA STATE BOARD OF ACCOUNTS 19 SCHOOL CITY OF HOBART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The nonpublic expenditures spent did not meet the earmarking requirements for grant award numbers 22611-043-PN01, 22611-043-ARP, and 22619-043-ARP. From the beginning of the grant awards until September 2022, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in September 2022, the Cooperative began tracking expenditures by member school for the nonpublic services. As such we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through September 2022, as required. The lack of internal controls and noncompliance was isolated to the 22611-043-PN01, 2611-043-ARP, and 22619-043-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 20 SCHOOL CITY OF HOBART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Through inquiry of Cooperative management, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member school starting in September 2022, most of the grant awards had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation was unable to ensure Cooperative compliance with earmarking requirements and the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school by the Cooperative. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the Earmarking compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-PN01, 22611-043-ARP, 22619-043-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2022-2023 the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. INDIANA STATE BOARD OF ACCOUNTS 19 SCHOOL CITY OF HOBART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The nonpublic expenditures spent did not meet the earmarking requirements for grant award numbers 22611-043-PN01, 22611-043-ARP, and 22619-043-ARP. From the beginning of the grant awards until September 2022, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in September 2022, the Cooperative began tracking expenditures by member school for the nonpublic services. As such we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through September 2022, as required. The lack of internal controls and noncompliance was isolated to the 22611-043-PN01, 2611-043-ARP, and 22619-043-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 20 SCHOOL CITY OF HOBART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Through inquiry of Cooperative management, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member school starting in September 2022, most of the grant awards had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation was unable to ensure Cooperative compliance with earmarking requirements and the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school by the Cooperative. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the Earmarking compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-PN01, 22611-043-ARP, 22619-043-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2022-2023 the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. INDIANA STATE BOARD OF ACCOUNTS 19 SCHOOL CITY OF HOBART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The nonpublic expenditures spent did not meet the earmarking requirements for grant award numbers 22611-043-PN01, 22611-043-ARP, and 22619-043-ARP. From the beginning of the grant awards until September 2022, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in September 2022, the Cooperative began tracking expenditures by member school for the nonpublic services. As such we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through September 2022, as required. The lack of internal controls and noncompliance was isolated to the 22611-043-PN01, 2611-043-ARP, and 22619-043-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 20 SCHOOL CITY OF HOBART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Through inquiry of Cooperative management, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member school starting in September 2022, most of the grant awards had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation was unable to ensure Cooperative compliance with earmarking requirements and the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school by the Cooperative. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the Earmarking compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Programs: Special Education Grants to States, COVID-19 - Special Education Grants to States, COVID-19 - Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 22611-043-PN01, 22611-043-ARP, 22619-043-ARP Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Significant Deficiency, Other Matters Condition and Context The School Corporation is a member of the Northwest Indiana Special Education Cooperative (Cooperative). During fiscal year 2022-2023 the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. INDIANA STATE BOARD OF ACCOUNTS 19 SCHOOL CITY OF HOBART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The nonpublic expenditures spent did not meet the earmarking requirements for grant award numbers 22611-043-PN01, 22611-043-ARP, and 22619-043-ARP. From the beginning of the grant awards until September 2022, total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. Beginning in September 2022, the Cooperative began tracking expenditures by member school for the nonpublic services. As such we were unable to identify if the minimum amount per the grant award was expended and properly reported to the IDOE from the beginning of the grant awards through September 2022, as required. The lack of internal controls and noncompliance was isolated to the 22611-043-PN01, 2611-043-ARP, and 22619-043-ARP grant awards. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (g) Be adequately documented. . . ." 2 CFR 200.208(b) states in part: "The Federal awarding agency or pass-through entity may adjust specific Federal award conditions as needed . . ." 511 IAC 7-34-7(b) states: "The public agency, in providing special education and related services to students in nonpublic schools must expend at least an amount that is the same proportion of the public agency total subgrant under 20 U.S.C. 1411(f) as the number of nonpublic school students with disabilities, who are enrolled by their parents in nonpublic schools within its boundaries, is to the total number of students with disabilities of the same age range." INDIANA STATE BOARD OF ACCOUNTS 20 SCHOOL CITY OF HOBART SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause Through inquiry of Cooperative management, they were unaware of the requirements to track nonpublic proportionate share expenditures directly for each member school. While the Cooperative did implement new processes and procedures to ensure expenditures were tracked by member school starting in September 2022, most of the grant awards had been allocated to the member schools based on a percentage of the budget. Effect Without the proper implementation of an effectively designed system of internal controls, the School Corporation was unable to ensure Cooperative compliance with earmarking requirements and the Cooperative was unable to track expenditures for nonpublic services for each member school. Consequently, the amounts requested for reimbursement were not supported by actual expenditures, but rather a percentage based on the budget per member school. Because of this, expenditures were not accurately reported to the oversight agency. Questioned Costs There were no questioned costs identified. Recommendation Management of the School Corporation should develop written policies and procedures which would require tracking of actual nonpublic proportionate share expenditures by member school by the Cooperative. Documentation should be maintained to show how these expenditures are being tracked to ensure compliance with the Earmarking compliance requirements. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Reference Number: 2024-027 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Human Resources Agency of Human Services Federal Program: SNAP Cluster Temporary Assistance for Needy Families Child Support Services CCDF Cluster Medicaid Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.563, 93.575, 93.596, 93.775, 93.777, 93.778 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2401VTSCSS (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR section 200.403(c), to be allowable under Federal awards, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient. Compensation for exempt attorneys in the State of Vermont are determined by the State of Vermont’s Attorney Pay Plan which governs the hiring level, compensation and promotion of exempt attorneys. 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 hourly rate used to compensate an exempt attorney was higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Context: The Department of Human Resources (Department) manages and updates the VTHR Human Resource information system which is the system used for managing employee data and processing payroll for all State employees. The Agency of Human Services (Agency) allocates payroll costs to federal programs using methodologies approved in its Cost Allocation Plan. After allocation, compensation for positions may be charged by the Agency to multiple federal programs. During cost allocation testing, auditors determined one employee’s rate of pay exceeded the limit identified for the position in the State of Vermont’s Attorney Pay Plan. The maximum hourly rate for the General Counsel I position is $59.61 or up to the Department Head’s Salary, whichever is lower. The employee selected for testing was compensated at the hourly rate of $62.06 which exceeds the maximum for the position. Cause: The Department of Human Resources used the department head’s salary as the maximum for the General Counsel I position in VTHR. It did not implement a control to ensure that the employee’s salary also did not exceed the maximum hourly rate identified for the position. Effect An employee was compensated at a rate higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Internal controls did not detect or prevent the error. Questioned costs: Undetermined. Recommendation: We recommend that the Department review and enhance procedures and internal controls to ensure that VTHR uses rates of pay for attorneys that align with the maximum pay rates established by the Attorney Pay Plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-027 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Human Resources Agency of Human Services Federal Program: SNAP Cluster Temporary Assistance for Needy Families Child Support Services CCDF Cluster Medicaid Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.563, 93.575, 93.596, 93.775, 93.777, 93.778 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2401VTSCSS (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR section 200.403(c), to be allowable under Federal awards, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient. Compensation for exempt attorneys in the State of Vermont are determined by the State of Vermont’s Attorney Pay Plan which governs the hiring level, compensation and promotion of exempt attorneys. 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 hourly rate used to compensate an exempt attorney was higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Context: The Department of Human Resources (Department) manages and updates the VTHR Human Resource information system which is the system used for managing employee data and processing payroll for all State employees. The Agency of Human Services (Agency) allocates payroll costs to federal programs using methodologies approved in its Cost Allocation Plan. After allocation, compensation for positions may be charged by the Agency to multiple federal programs. During cost allocation testing, auditors determined one employee’s rate of pay exceeded the limit identified for the position in the State of Vermont’s Attorney Pay Plan. The maximum hourly rate for the General Counsel I position is $59.61 or up to the Department Head’s Salary, whichever is lower. The employee selected for testing was compensated at the hourly rate of $62.06 which exceeds the maximum for the position. Cause: The Department of Human Resources used the department head’s salary as the maximum for the General Counsel I position in VTHR. It did not implement a control to ensure that the employee’s salary also did not exceed the maximum hourly rate identified for the position. Effect An employee was compensated at a rate higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Internal controls did not detect or prevent the error. Questioned costs: Undetermined. Recommendation: We recommend that the Department review and enhance procedures and internal controls to ensure that VTHR uses rates of pay for attorneys that align with the maximum pay rates established by the Attorney Pay Plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-027 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Human Resources Agency of Human Services Federal Program: SNAP Cluster Temporary Assistance for Needy Families Child Support Services CCDF Cluster Medicaid Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.563, 93.575, 93.596, 93.775, 93.777, 93.778 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2401VTSCSS (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR section 200.403(c), to be allowable under Federal awards, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient. Compensation for exempt attorneys in the State of Vermont are determined by the State of Vermont’s Attorney Pay Plan which governs the hiring level, compensation and promotion of exempt attorneys. 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 hourly rate used to compensate an exempt attorney was higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Context: The Department of Human Resources (Department) manages and updates the VTHR Human Resource information system which is the system used for managing employee data and processing payroll for all State employees. The Agency of Human Services (Agency) allocates payroll costs to federal programs using methodologies approved in its Cost Allocation Plan. After allocation, compensation for positions may be charged by the Agency to multiple federal programs. During cost allocation testing, auditors determined one employee’s rate of pay exceeded the limit identified for the position in the State of Vermont’s Attorney Pay Plan. The maximum hourly rate for the General Counsel I position is $59.61 or up to the Department Head’s Salary, whichever is lower. The employee selected for testing was compensated at the hourly rate of $62.06 which exceeds the maximum for the position. Cause: The Department of Human Resources used the department head’s salary as the maximum for the General Counsel I position in VTHR. It did not implement a control to ensure that the employee’s salary also did not exceed the maximum hourly rate identified for the position. Effect An employee was compensated at a rate higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Internal controls did not detect or prevent the error. Questioned costs: Undetermined. Recommendation: We recommend that the Department review and enhance procedures and internal controls to ensure that VTHR uses rates of pay for attorneys that align with the maximum pay rates established by the Attorney Pay Plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-027 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Human Resources Agency of Human Services Federal Program: SNAP Cluster Temporary Assistance for Needy Families Child Support Services CCDF Cluster Medicaid Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.563, 93.575, 93.596, 93.775, 93.777, 93.778 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2401VTSCSS (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR section 200.403(c), to be allowable under Federal awards, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient. Compensation for exempt attorneys in the State of Vermont are determined by the State of Vermont’s Attorney Pay Plan which governs the hiring level, compensation and promotion of exempt attorneys. 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 hourly rate used to compensate an exempt attorney was higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Context: The Department of Human Resources (Department) manages and updates the VTHR Human Resource information system which is the system used for managing employee data and processing payroll for all State employees. The Agency of Human Services (Agency) allocates payroll costs to federal programs using methodologies approved in its Cost Allocation Plan. After allocation, compensation for positions may be charged by the Agency to multiple federal programs. During cost allocation testing, auditors determined one employee’s rate of pay exceeded the limit identified for the position in the State of Vermont’s Attorney Pay Plan. The maximum hourly rate for the General Counsel I position is $59.61 or up to the Department Head’s Salary, whichever is lower. The employee selected for testing was compensated at the hourly rate of $62.06 which exceeds the maximum for the position. Cause: The Department of Human Resources used the department head’s salary as the maximum for the General Counsel I position in VTHR. It did not implement a control to ensure that the employee’s salary also did not exceed the maximum hourly rate identified for the position. Effect An employee was compensated at a rate higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Internal controls did not detect or prevent the error. Questioned costs: Undetermined. Recommendation: We recommend that the Department review and enhance procedures and internal controls to ensure that VTHR uses rates of pay for attorneys that align with the maximum pay rates established by the Attorney Pay Plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-007 Prior Year Finding: No Federal Agency: U.S. Department of Defense State Agency: Vermont State Military Department Federal Program: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing Number: 12.401 Award Number and Year: W912LN2421001 (10/1/2023 – 9/20/2024) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. 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 Vermont State Military Department (Department) charged costs to the federal grant prior to the allowable start of the period of performance. Context: One of five transactions selected for testing was incurred prior to the award’s period of performance. The expense was for a transaction incurred in the month of September 2023 but the award’s period of performance began on 10/1/2023. Cause: The Department’s procedures were not operating sufficiently to ensure that expenditures charged to the program were incurred within the award’s period of performance. Internal controls did not prevent or detect the error. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Questioned costs: Below the reportable limit. Recommendation: The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-009 Prior Year Finding: 2023-007 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: DUA 23A60UD000013 (7/14/2023 - 7/14/2026) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR section 200.403 states, in part, except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. (g) Be adequately documented. 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 Labor (Department) charged costs to the program that were issued without supporting documentation and documentation of supervisory review and approval. Context: Sixty transactions were selected for testing and the following exceptions were noted: • For six of sixty transactions selected for testing, the Department was unable to provide documentation to support the transactions totaling $510. • For six of sixty transactions selected for testing, the Department was unable to provide documentation of supervisory review and approval prior to issuance of payment. Cause: The Department’s procedures were not sufficient to ensure that payments were supported, reviewed, and approved prior to issuance of payment. Internal controls did not prevent or detect the errors. Effect: Unallowable costs could be charged to the program if disbursements are not supported and reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs. Questioned costs: $510 which represents the total unsupported expenditures. Recommendation: We recommend the Department reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are supported and reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-010 Prior Year Finding: 2023-008 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: Admin 24A55UI000063 (10/1/2023-12/31/2026), DUA 23A60UD000013 (7/14/2023 - 7/14/2026) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. 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 Labor (Department) charged costs to the federal grant prior to the allowable start of the period of performance. Context: Sixty transactions were selected for testing and the following exceptions were noted: • Five of sixty transactions were charged to the award before the allowable period of performance. The grant award start date was October 1, 2023, but costs were incurred in July, August, and September 2023. Cause: The Department’s procedures and internal controls were not operating sufficiently to ensure that expenditures charged to the program were incurred within the award’s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Questioned costs: $2,980, which represents the total incurred before the allowable period of performance. Recommendation: We recommend the Department review and enhance its procedures and controls to ensure that prior to charging costs to the program, they are incurred within an award’s allowable period of performance. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-009 Prior Year Finding: 2023-007 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: DUA 23A60UD000013 (7/14/2023 - 7/14/2026) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR section 200.403 states, in part, except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. (g) Be adequately documented. 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 Labor (Department) charged costs to the program that were issued without supporting documentation and documentation of supervisory review and approval. Context: Sixty transactions were selected for testing and the following exceptions were noted: • For six of sixty transactions selected for testing, the Department was unable to provide documentation to support the transactions totaling $510. • For six of sixty transactions selected for testing, the Department was unable to provide documentation of supervisory review and approval prior to issuance of payment. Cause: The Department’s procedures were not sufficient to ensure that payments were supported, reviewed, and approved prior to issuance of payment. Internal controls did not prevent or detect the errors. Effect: Unallowable costs could be charged to the program if disbursements are not supported and reviewed by a supervisor who is knowledgeable of program regulations regarding allowable costs. Questioned costs: $510 which represents the total unsupported expenditures. Recommendation: We recommend the Department reviews and enhances its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are supported and reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-010 Prior Year Finding: 2023-008 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: Admin 24A55UI000063 (10/1/2023-12/31/2026), DUA 23A60UD000013 (7/14/2023 - 7/14/2026) Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. 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 Labor (Department) charged costs to the federal grant prior to the allowable start of the period of performance. Context: Sixty transactions were selected for testing and the following exceptions were noted: • Five of sixty transactions were charged to the award before the allowable period of performance. The grant award start date was October 1, 2023, but costs were incurred in July, August, and September 2023. Cause: The Department’s procedures and internal controls were not operating sufficiently to ensure that expenditures charged to the program were incurred within the award’s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Questioned costs: $2,980, which represents the total incurred before the allowable period of performance. Recommendation: We recommend the Department review and enhance its procedures and controls to ensure that prior to charging costs to the program, they are incurred within an award’s allowable period of performance. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-027 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Human Resources Agency of Human Services Federal Program: SNAP Cluster Temporary Assistance for Needy Families Child Support Services CCDF Cluster Medicaid Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.563, 93.575, 93.596, 93.775, 93.777, 93.778 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2401VTSCSS (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR section 200.403(c), to be allowable under Federal awards, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient. Compensation for exempt attorneys in the State of Vermont are determined by the State of Vermont’s Attorney Pay Plan which governs the hiring level, compensation and promotion of exempt attorneys. 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 hourly rate used to compensate an exempt attorney was higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Context: The Department of Human Resources (Department) manages and updates the VTHR Human Resource information system which is the system used for managing employee data and processing payroll for all State employees. The Agency of Human Services (Agency) allocates payroll costs to federal programs using methodologies approved in its Cost Allocation Plan. After allocation, compensation for positions may be charged by the Agency to multiple federal programs. During cost allocation testing, auditors determined one employee’s rate of pay exceeded the limit identified for the position in the State of Vermont’s Attorney Pay Plan. The maximum hourly rate for the General Counsel I position is $59.61 or up to the Department Head’s Salary, whichever is lower. The employee selected for testing was compensated at the hourly rate of $62.06 which exceeds the maximum for the position. Cause: The Department of Human Resources used the department head’s salary as the maximum for the General Counsel I position in VTHR. It did not implement a control to ensure that the employee’s salary also did not exceed the maximum hourly rate identified for the position. Effect An employee was compensated at a rate higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Internal controls did not detect or prevent the error. Questioned costs: Undetermined. Recommendation: We recommend that the Department review and enhance procedures and internal controls to ensure that VTHR uses rates of pay for attorneys that align with the maximum pay rates established by the Attorney Pay Plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-027 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Human Resources Agency of Human Services Federal Program: SNAP Cluster Temporary Assistance for Needy Families Child Support Services CCDF Cluster Medicaid Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.563, 93.575, 93.596, 93.775, 93.777, 93.778 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2401VTSCSS (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR section 200.403(c), to be allowable under Federal awards, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient. Compensation for exempt attorneys in the State of Vermont are determined by the State of Vermont’s Attorney Pay Plan which governs the hiring level, compensation and promotion of exempt attorneys. 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 hourly rate used to compensate an exempt attorney was higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Context: The Department of Human Resources (Department) manages and updates the VTHR Human Resource information system which is the system used for managing employee data and processing payroll for all State employees. The Agency of Human Services (Agency) allocates payroll costs to federal programs using methodologies approved in its Cost Allocation Plan. After allocation, compensation for positions may be charged by the Agency to multiple federal programs. During cost allocation testing, auditors determined one employee’s rate of pay exceeded the limit identified for the position in the State of Vermont’s Attorney Pay Plan. The maximum hourly rate for the General Counsel I position is $59.61 or up to the Department Head’s Salary, whichever is lower. The employee selected for testing was compensated at the hourly rate of $62.06 which exceeds the maximum for the position. Cause: The Department of Human Resources used the department head’s salary as the maximum for the General Counsel I position in VTHR. It did not implement a control to ensure that the employee’s salary also did not exceed the maximum hourly rate identified for the position. Effect An employee was compensated at a rate higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Internal controls did not detect or prevent the error. Questioned costs: Undetermined. Recommendation: We recommend that the Department review and enhance procedures and internal controls to ensure that VTHR uses rates of pay for attorneys that align with the maximum pay rates established by the Attorney Pay Plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-027 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Human Resources Agency of Human Services Federal Program: SNAP Cluster Temporary Assistance for Needy Families Child Support Services CCDF Cluster Medicaid Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.563, 93.575, 93.596, 93.775, 93.777, 93.778 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2401VTSCSS (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR section 200.403(c), to be allowable under Federal awards, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient. Compensation for exempt attorneys in the State of Vermont are determined by the State of Vermont’s Attorney Pay Plan which governs the hiring level, compensation and promotion of exempt attorneys. 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 hourly rate used to compensate an exempt attorney was higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Context: The Department of Human Resources (Department) manages and updates the VTHR Human Resource information system which is the system used for managing employee data and processing payroll for all State employees. The Agency of Human Services (Agency) allocates payroll costs to federal programs using methodologies approved in its Cost Allocation Plan. After allocation, compensation for positions may be charged by the Agency to multiple federal programs. During cost allocation testing, auditors determined one employee’s rate of pay exceeded the limit identified for the position in the State of Vermont’s Attorney Pay Plan. The maximum hourly rate for the General Counsel I position is $59.61 or up to the Department Head’s Salary, whichever is lower. The employee selected for testing was compensated at the hourly rate of $62.06 which exceeds the maximum for the position. Cause: The Department of Human Resources used the department head’s salary as the maximum for the General Counsel I position in VTHR. It did not implement a control to ensure that the employee’s salary also did not exceed the maximum hourly rate identified for the position. Effect An employee was compensated at a rate higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Internal controls did not detect or prevent the error. Questioned costs: Undetermined. Recommendation: We recommend that the Department review and enhance procedures and internal controls to ensure that VTHR uses rates of pay for attorneys that align with the maximum pay rates established by the Attorney Pay Plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-027 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Human Resources Agency of Human Services Federal Program: SNAP Cluster Temporary Assistance for Needy Families Child Support Services CCDF Cluster Medicaid Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.563, 93.575, 93.596, 93.775, 93.777, 93.778 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2401VTSCSS (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR section 200.403(c), to be allowable under Federal awards, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient. Compensation for exempt attorneys in the State of Vermont are determined by the State of Vermont’s Attorney Pay Plan which governs the hiring level, compensation and promotion of exempt attorneys. 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 hourly rate used to compensate an exempt attorney was higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Context: The Department of Human Resources (Department) manages and updates the VTHR Human Resource information system which is the system used for managing employee data and processing payroll for all State employees. The Agency of Human Services (Agency) allocates payroll costs to federal programs using methodologies approved in its Cost Allocation Plan. After allocation, compensation for positions may be charged by the Agency to multiple federal programs. During cost allocation testing, auditors determined one employee’s rate of pay exceeded the limit identified for the position in the State of Vermont’s Attorney Pay Plan. The maximum hourly rate for the General Counsel I position is $59.61 or up to the Department Head’s Salary, whichever is lower. The employee selected for testing was compensated at the hourly rate of $62.06 which exceeds the maximum for the position. Cause: The Department of Human Resources used the department head’s salary as the maximum for the General Counsel I position in VTHR. It did not implement a control to ensure that the employee’s salary also did not exceed the maximum hourly rate identified for the position. Effect An employee was compensated at a rate higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Internal controls did not detect or prevent the error. Questioned costs: Undetermined. Recommendation: We recommend that the Department review and enhance procedures and internal controls to ensure that VTHR uses rates of pay for attorneys that align with the maximum pay rates established by the Attorney Pay Plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-027 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Human Resources Agency of Human Services Federal Program: SNAP Cluster Temporary Assistance for Needy Families Child Support Services CCDF Cluster Medicaid Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.563, 93.575, 93.596, 93.775, 93.777, 93.778 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2401VTSCSS (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR section 200.403(c), to be allowable under Federal awards, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient. Compensation for exempt attorneys in the State of Vermont are determined by the State of Vermont’s Attorney Pay Plan which governs the hiring level, compensation and promotion of exempt attorneys. 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 hourly rate used to compensate an exempt attorney was higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Context: The Department of Human Resources (Department) manages and updates the VTHR Human Resource information system which is the system used for managing employee data and processing payroll for all State employees. The Agency of Human Services (Agency) allocates payroll costs to federal programs using methodologies approved in its Cost Allocation Plan. After allocation, compensation for positions may be charged by the Agency to multiple federal programs. During cost allocation testing, auditors determined one employee’s rate of pay exceeded the limit identified for the position in the State of Vermont’s Attorney Pay Plan. The maximum hourly rate for the General Counsel I position is $59.61 or up to the Department Head’s Salary, whichever is lower. The employee selected for testing was compensated at the hourly rate of $62.06 which exceeds the maximum for the position. Cause: The Department of Human Resources used the department head’s salary as the maximum for the General Counsel I position in VTHR. It did not implement a control to ensure that the employee’s salary also did not exceed the maximum hourly rate identified for the position. Effect An employee was compensated at a rate higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Internal controls did not detect or prevent the error. Questioned costs: Undetermined. Recommendation: We recommend that the Department review and enhance procedures and internal controls to ensure that VTHR uses rates of pay for attorneys that align with the maximum pay rates established by the Attorney Pay Plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-027 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Human Resources Agency of Human Services Federal Program: SNAP Cluster Temporary Assistance for Needy Families Child Support Services CCDF Cluster Medicaid Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.563, 93.575, 93.596, 93.775, 93.777, 93.778 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2401VTSCSS (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR section 200.403(c), to be allowable under Federal awards, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient. Compensation for exempt attorneys in the State of Vermont are determined by the State of Vermont’s Attorney Pay Plan which governs the hiring level, compensation and promotion of exempt attorneys. 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 hourly rate used to compensate an exempt attorney was higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Context: The Department of Human Resources (Department) manages and updates the VTHR Human Resource information system which is the system used for managing employee data and processing payroll for all State employees. The Agency of Human Services (Agency) allocates payroll costs to federal programs using methodologies approved in its Cost Allocation Plan. After allocation, compensation for positions may be charged by the Agency to multiple federal programs. During cost allocation testing, auditors determined one employee’s rate of pay exceeded the limit identified for the position in the State of Vermont’s Attorney Pay Plan. The maximum hourly rate for the General Counsel I position is $59.61 or up to the Department Head’s Salary, whichever is lower. The employee selected for testing was compensated at the hourly rate of $62.06 which exceeds the maximum for the position. Cause: The Department of Human Resources used the department head’s salary as the maximum for the General Counsel I position in VTHR. It did not implement a control to ensure that the employee’s salary also did not exceed the maximum hourly rate identified for the position. Effect An employee was compensated at a rate higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Internal controls did not detect or prevent the error. Questioned costs: Undetermined. Recommendation: We recommend that the Department review and enhance procedures and internal controls to ensure that VTHR uses rates of pay for attorneys that align with the maximum pay rates established by the Attorney Pay Plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-027 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Human Resources Agency of Human Services Federal Program: SNAP Cluster Temporary Assistance for Needy Families Child Support Services CCDF Cluster Medicaid Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.563, 93.575, 93.596, 93.775, 93.777, 93.778 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2401VTSCSS (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR section 200.403(c), to be allowable under Federal awards, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient. Compensation for exempt attorneys in the State of Vermont are determined by the State of Vermont’s Attorney Pay Plan which governs the hiring level, compensation and promotion of exempt attorneys. 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 hourly rate used to compensate an exempt attorney was higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Context: The Department of Human Resources (Department) manages and updates the VTHR Human Resource information system which is the system used for managing employee data and processing payroll for all State employees. The Agency of Human Services (Agency) allocates payroll costs to federal programs using methodologies approved in its Cost Allocation Plan. After allocation, compensation for positions may be charged by the Agency to multiple federal programs. During cost allocation testing, auditors determined one employee’s rate of pay exceeded the limit identified for the position in the State of Vermont’s Attorney Pay Plan. The maximum hourly rate for the General Counsel I position is $59.61 or up to the Department Head’s Salary, whichever is lower. The employee selected for testing was compensated at the hourly rate of $62.06 which exceeds the maximum for the position. Cause: The Department of Human Resources used the department head’s salary as the maximum for the General Counsel I position in VTHR. It did not implement a control to ensure that the employee’s salary also did not exceed the maximum hourly rate identified for the position. Effect An employee was compensated at a rate higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Internal controls did not detect or prevent the error. Questioned costs: Undetermined. Recommendation: We recommend that the Department review and enhance procedures and internal controls to ensure that VTHR uses rates of pay for attorneys that align with the maximum pay rates established by the Attorney Pay Plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-027 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Human Resources Agency of Human Services Federal Program: SNAP Cluster Temporary Assistance for Needy Families Child Support Services CCDF Cluster Medicaid Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.563, 93.575, 93.596, 93.775, 93.777, 93.778 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2401VTSCSS (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR section 200.403(c), to be allowable under Federal awards, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient. Compensation for exempt attorneys in the State of Vermont are determined by the State of Vermont’s Attorney Pay Plan which governs the hiring level, compensation and promotion of exempt attorneys. 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 hourly rate used to compensate an exempt attorney was higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Context: The Department of Human Resources (Department) manages and updates the VTHR Human Resource information system which is the system used for managing employee data and processing payroll for all State employees. The Agency of Human Services (Agency) allocates payroll costs to federal programs using methodologies approved in its Cost Allocation Plan. After allocation, compensation for positions may be charged by the Agency to multiple federal programs. During cost allocation testing, auditors determined one employee’s rate of pay exceeded the limit identified for the position in the State of Vermont’s Attorney Pay Plan. The maximum hourly rate for the General Counsel I position is $59.61 or up to the Department Head’s Salary, whichever is lower. The employee selected for testing was compensated at the hourly rate of $62.06 which exceeds the maximum for the position. Cause: The Department of Human Resources used the department head’s salary as the maximum for the General Counsel I position in VTHR. It did not implement a control to ensure that the employee’s salary also did not exceed the maximum hourly rate identified for the position. Effect An employee was compensated at a rate higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Internal controls did not detect or prevent the error. Questioned costs: Undetermined. Recommendation: We recommend that the Department review and enhance procedures and internal controls to ensure that VTHR uses rates of pay for attorneys that align with the maximum pay rates established by the Attorney Pay Plan. Views of responsible officials: Management agrees with the finding.
Reference Number: 2024-027 Prior Year Finding: No Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services State Agency: Department of Human Resources Agency of Human Services Federal Program: SNAP Cluster Temporary Assistance for Needy Families Child Support Services CCDF Cluster Medicaid Cluster Assistance Listing Number: 10.551, 10.561, 93.558, 93.563, 93.575, 93.596, 93.775, 93.777, 93.778 Award Number and Year: 4VT400406 (10/1/2022 – 9/30/2023) 4VT402513 (10/1/2023 – 9/30/2024) 2301VTTANF (10/1/2022 – 9/30/2023) 2401VTTANF (10/1/2023 – 9/30/2024) 2401VTSCSS (10/1/2023 – 9/30/2024) 2301VTCCDD (10/1/2022 – 9/30/2025) 2401VTCCDD (10/1/2023 – 9/30/2026) 2305VT5MAP (10/1/2022 – 9/30/2023) Compliance Requirement: Allowable Costs/Cost Principles – Time and Effort Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: Per 2 CFR section 200.403(c), to be allowable under Federal awards, except where otherwise authorized by statute, costs must be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the recipient or subrecipient. Compensation for exempt attorneys in the State of Vermont are determined by the State of Vermont’s Attorney Pay Plan which governs the hiring level, compensation and promotion of exempt attorneys. 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 hourly rate used to compensate an exempt attorney was higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Context: The Department of Human Resources (Department) manages and updates the VTHR Human Resource information system which is the system used for managing employee data and processing payroll for all State employees. The Agency of Human Services (Agency) allocates payroll costs to federal programs using methodologies approved in its Cost Allocation Plan. After allocation, compensation for positions may be charged by the Agency to multiple federal programs. During cost allocation testing, auditors determined one employee’s rate of pay exceeded the limit identified for the position in the State of Vermont’s Attorney Pay Plan. The maximum hourly rate for the General Counsel I position is $59.61 or up to the Department Head’s Salary, whichever is lower. The employee selected for testing was compensated at the hourly rate of $62.06 which exceeds the maximum for the position. Cause: The Department of Human Resources used the department head’s salary as the maximum for the General Counsel I position in VTHR. It did not implement a control to ensure that the employee’s salary also did not exceed the maximum hourly rate identified for the position. Effect An employee was compensated at a rate higher than the maximum limit identified for the position in the State of Vermont’s Attorney Pay Plan. Internal controls did not detect or prevent the error. Questioned costs: Undetermined. Recommendation: We recommend that the Department review and enhance procedures and internal controls to ensure that VTHR uses rates of pay for attorneys that align with the maximum pay rates established by the Attorney Pay Plan. Views of responsible officials: Management agrees with the finding.
FINDING 2024-003 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Number and Year (or Other Identifying Number): FY23 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement; however, it was not effective. The School Corporation was approved for an indirect cost rate for fiscal year 2021-2022 in order to allocate indirect costs to the School Corporation's Cafeteria fund. However, the School Corporation did not charge these indirect costs within the appropriate time frame. Indirect costs for 2021-2022 in the amount of $26,793 was not charged to the Cafeteria fund until September 2022. Per USDA guidance, it is unallowable to bill the National School Food Service Account (NSFSA) for indirect costs that were paid from the general fund in prior years unless an agreement exists to show that the district had been "loaning" the NSFSA funds to cover the indirect costs in one or more prior years. The School Corporation did not have an interfund loan agreement in place. Therefore, the amounts were considered questioned costs. The lack of effective internal controls and noncompliance were isolated to the indirect costs noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." USDA Indirect Costs, Guidance for State Agencies & School Food Authorities states in part: ". . . It is unallowable to bill the NSFSA for indirect costs that were paid from the general fund in prior years unless an agreement exists to sow that the district had been 'loaning' the NSFSA funds to cover the indirect costs in one or more prior years. . . . There is no Federal requirement that prohibits an SFA from charging its internal fiscal policy regarding the recovery of indirect costs by those organizational units within the SFA that actually incur costs. Absent a documented 'inter-fund loan' as outlined above, however, an SFA may only change its policy to charge the NSFSA for indirect costs prospectively (that is going forward for the next school year.) It is unallowable to bill the NSFSA for indirect costs that were previously paid from the general fund unless an agreement exists to show that the district had been 'loaning' the NSFSA funds to cover the indirect costs in one or more prior years. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Cause Management was not aware of the requirements before the transfer was made in September 2022. Effect The failure to establish an effective system of internal controls enabled noncompliance to go undetected and resulted in the School Corporation charging indirect costs that were not allowable. Questioned Costs Known questioned costs of $26,793 were identified as noted in the Condition and Context. Recommendation Management of the School Corporation should develop written policies and procedures to ensure that indirect costs are properly determined and paid in the appropriate fiscal year. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Number and Year (or Other Identifying Number): FY23 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement; however, it was not effective. The School Corporation was approved for an indirect cost rate for fiscal year 2021-2022 in order to allocate indirect costs to the School Corporation's Cafeteria fund. However, the School Corporation did not charge these indirect costs within the appropriate time frame. Indirect costs for 2021-2022 in the amount of $26,793 was not charged to the Cafeteria fund until September 2022. Per USDA guidance, it is unallowable to bill the National School Food Service Account (NSFSA) for indirect costs that were paid from the general fund in prior years unless an agreement exists to show that the district had been "loaning" the NSFSA funds to cover the indirect costs in one or more prior years. The School Corporation did not have an interfund loan agreement in place. Therefore, the amounts were considered questioned costs. The lack of effective internal controls and noncompliance were isolated to the indirect costs noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." USDA Indirect Costs, Guidance for State Agencies & School Food Authorities states in part: ". . . It is unallowable to bill the NSFSA for indirect costs that were paid from the general fund in prior years unless an agreement exists to sow that the district had been 'loaning' the NSFSA funds to cover the indirect costs in one or more prior years. . . . There is no Federal requirement that prohibits an SFA from charging its internal fiscal policy regarding the recovery of indirect costs by those organizational units within the SFA that actually incur costs. Absent a documented 'inter-fund loan' as outlined above, however, an SFA may only change its policy to charge the NSFSA for indirect costs prospectively (that is going forward for the next school year.) It is unallowable to bill the NSFSA for indirect costs that were previously paid from the general fund unless an agreement exists to show that the district had been 'loaning' the NSFSA funds to cover the indirect costs in one or more prior years. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Cause Management was not aware of the requirements before the transfer was made in September 2022. Effect The failure to establish an effective system of internal controls enabled noncompliance to go undetected and resulted in the School Corporation charging indirect costs that were not allowable. Questioned Costs Known questioned costs of $26,793 were identified as noted in the Condition and Context. Recommendation Management of the School Corporation should develop written policies and procedures to ensure that indirect costs are properly determined and paid in the appropriate fiscal year. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-003 Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listings Numbers: 10.553, 10.555, 10.559 Federal Award Number and Year (or Other Identifying Number): FY23 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement; however, it was not effective. The School Corporation was approved for an indirect cost rate for fiscal year 2021-2022 in order to allocate indirect costs to the School Corporation's Cafeteria fund. However, the School Corporation did not charge these indirect costs within the appropriate time frame. Indirect costs for 2021-2022 in the amount of $26,793 was not charged to the Cafeteria fund until September 2022. Per USDA guidance, it is unallowable to bill the National School Food Service Account (NSFSA) for indirect costs that were paid from the general fund in prior years unless an agreement exists to show that the district had been "loaning" the NSFSA funds to cover the indirect costs in one or more prior years. The School Corporation did not have an interfund loan agreement in place. Therefore, the amounts were considered questioned costs. The lack of effective internal controls and noncompliance were isolated to the indirect costs noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." USDA Indirect Costs, Guidance for State Agencies & School Food Authorities states in part: ". . . It is unallowable to bill the NSFSA for indirect costs that were paid from the general fund in prior years unless an agreement exists to sow that the district had been 'loaning' the NSFSA funds to cover the indirect costs in one or more prior years. . . . There is no Federal requirement that prohibits an SFA from charging its internal fiscal policy regarding the recovery of indirect costs by those organizational units within the SFA that actually incur costs. Absent a documented 'inter-fund loan' as outlined above, however, an SFA may only change its policy to charge the NSFSA for indirect costs prospectively (that is going forward for the next school year.) It is unallowable to bill the NSFSA for indirect costs that were previously paid from the general fund unless an agreement exists to show that the district had been 'loaning' the NSFSA funds to cover the indirect costs in one or more prior years. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Cause Management was not aware of the requirements before the transfer was made in September 2022. Effect The failure to establish an effective system of internal controls enabled noncompliance to go undetected and resulted in the School Corporation charging indirect costs that were not allowable. Questioned Costs Known questioned costs of $26,793 were identified as noted in the Condition and Context. Recommendation Management of the School Corporation should develop written policies and procedures to ensure that indirect costs are properly determined and paid in the appropriate fiscal year. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Activities Allowed or Unallowed Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles, Activities Allowed or Unallowed Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Fund (ESF), established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act and further funded by the Coronavirus Response and Relief Supplemental Appropriations Act (CRSSA) and the American Rescue Plan (ARP) Act, was for the purpose of preventing, preparing for, or responding to the novel coronavirus. A sample of 40 vendor and payroll disbursements that were charged to the ESF grant for which reimbursement was received during the audit period was selected for testing to verify the expenditures were in conformance with the applicable allowable cost principles. Of the 40 disbursements tested, 4 payroll disbursements for accelerated learning were approved, but the School Corporation could not provide documentation to show where the governing board approved their rate of pay. In addition, there was a transfer from the ESSER II - Cares grant fund to the Education fund for $117,177 to reimburse that fund for expenses on June 20, 2024. The School Corporation was unable to provide documentation for the expenses that were reimbursed to ensure they were for allowable activities and allowable costs. The ineffective internal controls were a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the Allowable Costs/Cost Principles and the Activities Allowed or Unallowed compliance requirements. Management was not aware that they should have only been reimbursed for expenditures made out of the ESF funds or should have moved the expenditures and retained proper documentation to support what expenditures tied to what was reimbursed. It was noted that the accelerated learning rate of pay was discussed at a School Board meeting, but the approved wage rates were not documented in the School Board minutes or on any sort of salary schedule approved by the School Board members. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Cost/Cost Principles and the Activities Allowed or Unallowed compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs There was a total of $173,841 of questioned costs as referenced under the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure only allowable activities and allowable costs are charged to grants funds and to ensure grant money is only requested for reimbursement for monies directly related to the grant program. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Activities Allowed or Unallowed Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles, Activities Allowed or Unallowed Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Fund (ESF), established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act and further funded by the Coronavirus Response and Relief Supplemental Appropriations Act (CRSSA) and the American Rescue Plan (ARP) Act, was for the purpose of preventing, preparing for, or responding to the novel coronavirus. A sample of 40 vendor and payroll disbursements that were charged to the ESF grant for which reimbursement was received during the audit period was selected for testing to verify the expenditures were in conformance with the applicable allowable cost principles. Of the 40 disbursements tested, 4 payroll disbursements for accelerated learning were approved, but the School Corporation could not provide documentation to show where the governing board approved their rate of pay. In addition, there was a transfer from the ESSER II - Cares grant fund to the Education fund for $117,177 to reimburse that fund for expenses on June 20, 2024. The School Corporation was unable to provide documentation for the expenses that were reimbursed to ensure they were for allowable activities and allowable costs. The ineffective internal controls were a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the Allowable Costs/Cost Principles and the Activities Allowed or Unallowed compliance requirements. Management was not aware that they should have only been reimbursed for expenditures made out of the ESF funds or should have moved the expenditures and retained proper documentation to support what expenditures tied to what was reimbursed. It was noted that the accelerated learning rate of pay was discussed at a School Board meeting, but the approved wage rates were not documented in the School Board minutes or on any sort of salary schedule approved by the School Board members. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Cost/Cost Principles and the Activities Allowed or Unallowed compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs There was a total of $173,841 of questioned costs as referenced under the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure only allowable activities and allowable costs are charged to grants funds and to ensure grant money is only requested for reimbursement for monies directly related to the grant program. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Activities Allowed or Unallowed Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles, Activities Allowed or Unallowed Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Fund (ESF), established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act and further funded by the Coronavirus Response and Relief Supplemental Appropriations Act (CRSSA) and the American Rescue Plan (ARP) Act, was for the purpose of preventing, preparing for, or responding to the novel coronavirus. A sample of 40 vendor and payroll disbursements that were charged to the ESF grant for which reimbursement was received during the audit period was selected for testing to verify the expenditures were in conformance with the applicable allowable cost principles. Of the 40 disbursements tested, 4 payroll disbursements for accelerated learning were approved, but the School Corporation could not provide documentation to show where the governing board approved their rate of pay. In addition, there was a transfer from the ESSER II - Cares grant fund to the Education fund for $117,177 to reimburse that fund for expenses on June 20, 2024. The School Corporation was unable to provide documentation for the expenses that were reimbursed to ensure they were for allowable activities and allowable costs. The ineffective internal controls were a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the Allowable Costs/Cost Principles and the Activities Allowed or Unallowed compliance requirements. Management was not aware that they should have only been reimbursed for expenditures made out of the ESF funds or should have moved the expenditures and retained proper documentation to support what expenditures tied to what was reimbursed. It was noted that the accelerated learning rate of pay was discussed at a School Board meeting, but the approved wage rates were not documented in the School Board minutes or on any sort of salary schedule approved by the School Board members. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Cost/Cost Principles and the Activities Allowed or Unallowed compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs There was a total of $173,841 of questioned costs as referenced under the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure only allowable activities and allowable costs are charged to grants funds and to ensure grant money is only requested for reimbursement for monies directly related to the grant program. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-005 Subject: COVID-19 - Education Stabilization Fund - Allowable Costs/Cost Principles and Activities Allowed or Unallowed Federal Agency: Indiana Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirements: Allowable Costs/Cost Principles, Activities Allowed or Unallowed Audit Findings: Material Weakness, Modified Opinion Condition and Context The COVID-19 - Education Stabilization Fund (ESF), established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act and further funded by the Coronavirus Response and Relief Supplemental Appropriations Act (CRSSA) and the American Rescue Plan (ARP) Act, was for the purpose of preventing, preparing for, or responding to the novel coronavirus. A sample of 40 vendor and payroll disbursements that were charged to the ESF grant for which reimbursement was received during the audit period was selected for testing to verify the expenditures were in conformance with the applicable allowable cost principles. Of the 40 disbursements tested, 4 payroll disbursements for accelerated learning were approved, but the School Corporation could not provide documentation to show where the governing board approved their rate of pay. In addition, there was a transfer from the ESSER II - Cares grant fund to the Education fund for $117,177 to reimburse that fund for expenses on June 20, 2024. The School Corporation was unable to provide documentation for the expenses that were reimbursed to ensure they were for allowable activities and allowable costs. The ineffective internal controls were a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.334 states in part: "Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. . . . (g) Be adequately documented. . . ." Cause Management had not developed a system of internal controls that would have ensured compliance with the Allowable Costs/Cost Principles and the Activities Allowed or Unallowed compliance requirements. Management was not aware that they should have only been reimbursed for expenditures made out of the ESF funds or should have moved the expenditures and retained proper documentation to support what expenditures tied to what was reimbursed. It was noted that the accelerated learning rate of pay was discussed at a School Board meeting, but the approved wage rates were not documented in the School Board minutes or on any sort of salary schedule approved by the School Board members. Effect The failure to design and implement an effective internal control system enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Cost/Cost Principles and the Activities Allowed or Unallowed compliance requirements could result in the loss of future federal funds to the School Corporation. Questioned Costs There was a total of $173,841 of questioned costs as referenced under the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure only allowable activities and allowable costs are charged to grants funds and to ensure grant money is only requested for reimbursement for monies directly related to the grant program. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.
Assistance Listing, Federal Agency, and Program Name - Research and Development Cluster (R&D) Federal Award Identification Number and Year - R&D - All ALN's Pass through Entity - R&D - Various Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass through entity made the federal award that were authorized by the federal awarding agency or pass through entity (2 CFR sections 200.308, 200.309, and 200.403(h)). Condition - Of the 40 samples included in our sample selected for testing in the Research and Development Cluster, the University included two invoices for a total of $2,618 that were incurred prior to the beginning of the grant period. Questioned Costs - $2,618 Identification of How Questioned Costs Were Computed - Question costs were computed using the total costs identified in our sample that were incurred prior to the grant period. Context - The University completed a transfer of costs between two grant awards that were supporting the same overall program. The samples identified were part of one cost transfer, but the invoice date and related expense was incurred one day prior to the beginning of the grant period. Cause and Effect - The University did not have proper procedures over tracking of expenditures in separate grant cost centers for a R&D program. This required a transfer between the grant programs and resulted in the University adjusting costs from a prior period and charging costs to a grant that was outside the period of performance. Recommendation - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an Award Calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented have been removed from the existing grant and replaced by other allowable costs that were included in the proper award period. Views of Responsible Officials and Planned Corrective Actions - The University has implemented a new grant financial and billing software that provides improved controls over operational transactions, including an award calendar control that recognizes the award end date in the invoice posting process. The costs described in this finding, which occurred before the new system was implemented, have been removed from the existing grant and replaced by other allowable costs that were incurred within the proper award period.