FINDING 2022-002 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-009-PN01, 21611-009-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation is a member of the Exceptional Children's Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. There was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. 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 non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The non-public proportionate share expenditures for the 20611-009-PN01 and 21611-009-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The non-public proportionate share expenditures were determined by applying a percentage to the non-public school budgeted expenditures. These were the amounts reported to the IDOE. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance was isolated to the 20611-009-PN01 and 21611-009-PN01 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." Cause The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreements and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-002 Subject: Special Education Cluster (IDEA) - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States Assistance Listings Number: 84.027 Federal Award Numbers and Years (or Other Identifying Numbers): 20611-009-PN01, 21611-009-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation is a member of the Exceptional Children's Cooperative (Cooperative). During fiscal year 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its member schools. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. There was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. 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 non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The non-public proportionate share expenditures for the 20611-009-PN01 and 21611-009-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The non-public proportionate share expenditures were determined by applying a percentage to the non-public school budgeted expenditures. These were the amounts reported to the IDOE. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance was isolated to the 20611-009-PN01 and 21611-009-PN01 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." Cause The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreements and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-004 Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-021-PN01, 20611-21-PN01, 20619-21-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2020-2021 and 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The Cooperative was a planning district whose purpose was to provide free appropriate public education to students identified as disabled in accordance with state statute who were legal residents and/or have been accepted through means of open enrollment, or other legal means of transfer to the participating member school corporations in Tippecanoe County. INDIANA STATE BOARD OF ACCOUNTS 21 TIPPECANOE SCHOOL CORPORATION 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 non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 19611-21-PN01, 20611-21-PN01, and 20619-21-PN01 grant awards could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools on a percentage basis. These allocations were the amounts reported to the IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance were isolated to the 19611-21-PN01, 20611-21-PN01, and 20619-21-PN01 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." Cause The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 22 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-004 Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-021-PN01, 20611-21-PN01, 20619-21-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2020-2021 and 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The Cooperative was a planning district whose purpose was to provide free appropriate public education to students identified as disabled in accordance with state statute who were legal residents and/or have been accepted through means of open enrollment, or other legal means of transfer to the participating member school corporations in Tippecanoe County. INDIANA STATE BOARD OF ACCOUNTS 21 TIPPECANOE SCHOOL CORPORATION 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 non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 19611-21-PN01, 20611-21-PN01, and 20619-21-PN01 grant awards could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools on a percentage basis. These allocations were the amounts reported to the IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance were isolated to the 19611-21-PN01, 20611-21-PN01, and 20619-21-PN01 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." Cause The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 22 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2022-004 Subject: Special Education Cluster - Earmarking Federal Agency: Department of Education Federal Program: Special Education Grants to States, Special Education Preschool Grants Assistance Listings Numbers: 84.027, 84.173 Federal Award Numbers and Years (or Other Identifying Numbers): 19611-021-PN01, 20611-21-PN01, 20619-21-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Matching, Level of Effort, Earmarking Audit Findings: Material Weakness, Modified Opinion Condition and Context The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2020-2021 and 2021-2022, the Cooperative operated the special education programs and spent the federal money on behalf of all its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The Cooperative was a planning district whose purpose was to provide free appropriate public education to students identified as disabled in accordance with state statute who were legal residents and/or have been accepted through means of open enrollment, or other legal means of transfer to the participating member school corporations in Tippecanoe County. INDIANA STATE BOARD OF ACCOUNTS 21 TIPPECANOE SCHOOL CORPORATION 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 non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 19611-21-PN01, 20611-21-PN01, and 20619-21-PN01 grant awards could not be verified for the individual member schools. The non-public school share funds for all member schools were comingled and the aggregate amount of expenditures was then allocated to the member schools on a percentage basis. These allocations were the amounts reported to the IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance were isolated to the 19611-21-PN01, 20611-21-PN01, and 20619-21-PN01 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." Cause The School Corporation's management had not developed an effective system of internal controls that would have ensured compliance with the grant agreement and the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. INDIANA STATE BOARD OF ACCOUNTS 22 TIPPECANOE SCHOOL CORPORATION SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The failure to establish an effective internal control system, as well as adequately document costs of federal awards, prevented the determination of the School Corporation's compliance with the earmarking requirements of the Matching, Level of Effort, Earmarking compliance requirement. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish an effective system of internal controls, as well as appropriately document and identify federal award expenditures to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Ill FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-01 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $104,640.00 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $7,151,713.18 were expended and reported on the Appling County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?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? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that payments were made to a janitorial company and a staffing services company utilized by the School District to provide ?retention? bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private companies. Per review of the contracts in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the companies and in the service of the School District for a stated period of time were not reflected within the associated contract. Therefore, expenditures totaling $104,640.00 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $104,640.00 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and approved by the local Board of Education; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding.
Ill FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-01 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $104,640.00 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $7,151,713.18 were expended and reported on the Appling County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?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? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that payments were made to a janitorial company and a staffing services company utilized by the School District to provide ?retention? bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private companies. Per review of the contracts in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the companies and in the service of the School District for a stated period of time were not reflected within the associated contract. Therefore, expenditures totaling $104,640.00 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $104,640.00 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and approved by the local Board of Education; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding.
Ill FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-01 Improve Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $104,640.00 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $7,151,713.18 were expended and reported on the Appling County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the Institution is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?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? (g) Be adequately documented?? In addition, provisions included in the Uniform Guidance, Section 202.403 ? Reasonable Costs state that ?a cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award? (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost.? Furthermore, provisions included in the Uniform Guidance, Section 200.318 ? General Procurement Standards state that ?the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations? for the acquisition of property or services required under a Federal award or subaward?? Condition: Auditors performed a review of expenditure activity associated with the ESSER program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that payments were made to a janitorial company and a staffing services company utilized by the School District to provide ?retention? bonuses to contractors who were not employees of the School District. These individuals were assigned to work within the School District by the private companies. Per review of the contracts in place during the fiscal year under review, it was noted that these bonuses represented amounts in excess of the agreed upon price. Furthermore, the School District does not have the authority or ability to retain these individuals as they were not employees of the School District and contract provisions requiring the individuals to remain employed by the companies and in the service of the School District for a stated period of time were not reflected within the associated contract. Therefore, expenditures totaling $104,640.00 were not considered to be reasonable and necessary for the performance of the ESSER program and deemed unallowable. Questioned Costs: Known questioned costs of $104,640.00 were identified for expenditures that were not incurred for a necessary and reasonable purpose and did not follow the School District?s policies and procedures. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: Per discussion with management, the School District believed that the expenditures were allowable as the expenditures were approved by GaDOE through the Consolidated Application process and approved by the local Board of Education; however, they were not aware that contract amendments should be initiated prior to the expenditure of funds in this manner. Effect: The School District is not in compliance with the Uniform Guidance, ED, or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate policies and procedures are followed when expending federal funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are in line with provisions reflected within the associated contract and/or contract amendments. In addition, the School District should implement a monitoring process to ensure that all expenditures are compliant with the School District?s purchasing policies and procedures. Views of Responsible Officials: We concur with this finding.
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 Numbers and Years (or Other Identifying Numbers): SY 2020-2021, SY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective system of internal controls 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. INDIANA STATE BOARD OF ACCOUNTS 19 SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) During the audit period, four employees tested were assigned both Child Nutrition Cluster grant activities and other nonfederal duties. The four employees did not maintain documentation of time spent on federal program and nonfederal program activities. The total paid to the four employees from the School Lunch Fund 800 without proper documentation was $34,827 which was considered questioned costs. The lack of internal controls and noncompliance were isolated to the payments 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). . . ." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 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. INDIANA STATE BOARD OF ACCOUNTS 20 SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $34,827 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
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 Numbers and Years (or Other Identifying Numbers): SY 2020-2021, SY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective system of internal controls 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. INDIANA STATE BOARD OF ACCOUNTS 19 SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) During the audit period, four employees tested were assigned both Child Nutrition Cluster grant activities and other nonfederal duties. The four employees did not maintain documentation of time spent on federal program and nonfederal program activities. The total paid to the four employees from the School Lunch Fund 800 without proper documentation was $34,827 which was considered questioned costs. The lack of internal controls and noncompliance were isolated to the payments 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). . . ." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 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. INDIANA STATE BOARD OF ACCOUNTS 20 SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $34,827 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
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 Numbers and Years (or Other Identifying Numbers): SY 2020-2021, SY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective system of internal controls 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. INDIANA STATE BOARD OF ACCOUNTS 19 SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) During the audit period, four employees tested were assigned both Child Nutrition Cluster grant activities and other nonfederal duties. The four employees did not maintain documentation of time spent on federal program and nonfederal program activities. The total paid to the four employees from the School Lunch Fund 800 without proper documentation was $34,827 which was considered questioned costs. The lack of internal controls and noncompliance were isolated to the payments 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). . . ." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 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. INDIANA STATE BOARD OF ACCOUNTS 20 SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $34,827 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
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 Numbers and Years (or Other Identifying Numbers): SY 2020-2021, SY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective system of internal controls 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. INDIANA STATE BOARD OF ACCOUNTS 19 SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) During the audit period, four employees tested were assigned both Child Nutrition Cluster grant activities and other nonfederal duties. The four employees did not maintain documentation of time spent on federal program and nonfederal program activities. The total paid to the four employees from the School Lunch Fund 800 without proper documentation was $34,827 which was considered questioned costs. The lack of internal controls and noncompliance were isolated to the payments 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). . . ." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 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. INDIANA STATE BOARD OF ACCOUNTS 20 SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $34,827 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
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 Numbers and Years (or Other Identifying Numbers): SY 2020-2021, SY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective system of internal controls 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. INDIANA STATE BOARD OF ACCOUNTS 19 SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) During the audit period, four employees tested were assigned both Child Nutrition Cluster grant activities and other nonfederal duties. The four employees did not maintain documentation of time spent on federal program and nonfederal program activities. The total paid to the four employees from the School Lunch Fund 800 without proper documentation was $34,827 which was considered questioned costs. The lack of internal controls and noncompliance were isolated to the payments 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). . . ." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 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. INDIANA STATE BOARD OF ACCOUNTS 20 SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $34,827 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
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 Numbers and Years (or Other Identifying Numbers): SY 2020-2021, SY 2021-2022 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective system of internal controls 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. INDIANA STATE BOARD OF ACCOUNTS 19 SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) During the audit period, four employees tested were assigned both Child Nutrition Cluster grant activities and other nonfederal duties. The four employees did not maintain documentation of time spent on federal program and nonfederal program activities. The total paid to the four employees from the School Lunch Fund 800 without proper documentation was $34,827 which was considered questioned costs. The lack of internal controls and noncompliance were isolated to the payments 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). . . ." 7 CFR 220.7(e) states in part: ". . . the School Food Authority shall, with respect to participating schools under its jurisdiction: (1) (i) Maintain a nonprofit school food service; (ii) . . . use all revenues received by such food service only for the operation or improvement of that food service . . ." 7 CFR 210.14(a) states in part: "Nonprofit school food service. School food authorities shall maintain a nonprofit school food service. Revenues received by the nonprofit school food service are to be used only for the operation or improvement of such food service, except that, such revenues shall not be used to purchase land or buildings, unless otherwise approved by FNS, or to construct buildings. . . ." 7 CFR 225.15(a)(1) states: "Sponsors shall operate the food service in accordance with: the provisions of this part; any instructions and handbooks issued by FNS under this part; and any instructions and handbooks issued by the State agency which are not inconsistent with the provisions of this part." 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. INDIANA STATE BOARD OF ACCOUNTS 20 SCHOOL TOWN OF MUNSTER SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 grant agreement and the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective system of internal controls, as well as adequately document costs, enabled noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could result in the loss of future federal funds to the School Corporation. Questioned Costs Known questioned costs of $34,827 were identified as detailed in the Condition and Context. Recommendation We recommended that the School Corporation's management establish a system of internal controls to ensure that documentation will be maintained and made available for audit and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Program: Various, including AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 ? Temporary Assistance for Needy Families; AL 93.566 ? Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 ? Child Care and Development Block Grant ? Allowable Costs/Cost Principles Grant Number & Year: Various, including 202121S251443, FFY 2021; 202222S251443, FFY 2022; 1901NETANF, FFY 2019; 2101NERCMA, FFY 2021; 2201NERCMA, FFY 2022; 2201NECCDD, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: 45 CFR ? 75.303 (October 1, 2021) states, in relevant part, the following: 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be necessary, reasonable, and adequately documented. 45 CFR ? 75.302 (October 1, 2021) requires financial management systems of the State sufficient to permit both preparation of required reports and tracing of funds to expenditures adequate to establish that the use of those funds was in accordance with applicable regulations. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 400.1 (January 1, 2022), the U.S. Department of Agriculture adopted the OMB Uniform Guidance as its policies and procedures for uniform administrative requirements, cost principles, and audit requirements for Federal awards. 2 CFR ? 200.303 (January 1, 2022) states, in part, the following: 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. 45 CFR ? 75.511(b) and 2 CFR ? 200.511(b) (January 1, 2022) state, in relevant part, the following: The summary schedule of prior audit findings must report the status of all audit findings included in the prior audit?s schedule of findings and questioned costs. . . . * * * * (2) When audit findings were not corrected or were only partially corrected, the summary schedule must describe the reasons for the finding?s recurrence and planned corrective action, and any partial corrective action taken. When corrective action taken is significantly different from corrective action previously reported in a corrective action plan or in the Federal agency?s or pass-through entity?s management decision, the summary schedule must provide an explanation. Good internal control requires procedures to ensure that amounts charged to Federal programs are proper. Condition: The Agency did not properly charge Federal programs for seven allocations tested. A similar finding was noted in the prior audit. The Summary Schedule of Prior Audit Findings lists the status as completed. Repeat Finding: 2021-031, 2021-032 Questioned Costs: $44,356 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: For seven of 14 allocations tested, we noted the following: ? We tested the allocation of cost center 25C21940 Field Office Resource Development for the quarter ended September 30, 2021, which is allocated based on Time & Effort reports. The payroll costs for 85 employees were charged to the cost center; however, four of the employees? payroll costs should not have been charged to the cost center. The four employees tested included a Federal Aid Administrator, a Program Accuracy Specialist, and two Office Specialists. The supervisors they worked with were not charged to this cost center, and the employees were not employed as Resource Developers, which was the job title of most of the employees included in this cost center. As a result of these employees being charged to the Resource Development cost center instead of their appropriate cost centers, Child Care and Development, Foster Care, Adoption Assistance, Guardianship Assistance, and Medicaid were not charged correctly, ranging from undercharges of $2,653 to overcharges of $2,402. Additionally, we were unable to determine how the payroll costs of $9,858 to the Federal Aid Administrator should have been allocated. The Resource Development cost center allocated $1,444,162 for the quarter ended September 30, 2021. A similar finding was noted in the prior audit. ? We tested the allocation of cost center 25C20680 Legal Services General Legal Teams for the quarter ended June 30, 2022, which is allocated based on Time & Effort reports. The payroll costs for a Legislative Coordinator were recorded to this cost center during the quarter. However, these costs should have been recorded to cost center 25C20720 Communications and Legislative Services Administration. As a result, this employee?s payroll costs of $15,777 during the quarter were not allocated to Federal programs correctly. We were unable to determine how these payroll costs should have been allocated. The Legal Services General Legal Teams cost center allocated $1,332,052 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21960 Field Office Social Services Casework for quarter ended September 30, 2021, which is allocated based on random moment time studies (RMTS) results. The Bridges to Independence program and Guardianship Assistance program should have been allocated $1,464 each from this cost center; however, the Agency did not include these programs in the allocation. As a result, the Federal grants for Refugee and Entrant Assistance, Child Care and Development, Foster Care, Adoption Assistance, Temporary Assistance to Needy Families (TANF), Supplemental Nutrition Assistance Program (SNAP), and Medicaid were overcharged, ranging from $3 to $982, and the Guardianship Assistance grant was undercharged $732. The Field Office Social Services Casework cost center allocated $8,099,617 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C21920 Field Office Child Protection & Safety Services for the quarter ended June 30, 2022, which is allocated based on RMTS results. The Agency began using a new RMTS system in January 2022; however, the Agency did not set up the quarterly summary reports correctly. Below are the issues noted: o RMTS observations for Trial Home Visits were not included in the allocation. As a result, State programs were undercharged, and Federal programs were overcharged. o The RMTS observations for Child Protection Initial Assessment were not properly allocated. As a result, Foster Care was overcharged, and Adoption and Guardianship were undercharged. o The RMTS observations for Before or After Work Hours were incorrectly included in the State?s allocation. As a result, Federal programs were undercharged. In total, Federal grants for Adoption Assistance, Foster Care, and Guardianship Assistance were undercharged $28,560, $113,762, and $1,990, respectively. The Field Office Child Protection & Safety Services cost center allocated $12,429,881 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21910 Field Office Administration for the quarter ended June 30, 2022, which is allocated based on labor hours. The Agency did not include all of the applicable labor hours for the Medicaid program. As a result, the Federal grants for Adoption Assistance, Foster Care, Guardianship Assistance, Refugee and Entrant Assistance, Child Care and Development, TANF, and SNAP were overcharged, ranging from $265 to $30,556, and the Medicaid grant was undercharged $235,906. The Field Office Administration cost center allocated $3,236,547 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C20990 IST Application NFOCUS Applications for the quarter ended September 30, 2021, which is allocated based on client counts per NFOCUS/MMIS reports. We noted that the Foster Care and TANF recipient counts used in the allocation did not agree to support. The Foster Care count included 71 clients that were paid with State funds, resulting in $265 being overcharged to the Foster Care grant, and the TANF count included 48 clients that were paid with State funds, resulting in $358 being overcharged to the TANF grant. Additionally, we were unable to trace the member counts to documentation that supported allocating $1,853,284 to Medicaid and $283,190 to the Children?s Health Insurance Program (CHIP). The Agency did not maintain the member count reports used at the time of the allocation. The Agency was able to generate a historical report; however, while the report amounts were similar, they did not agree with the counts used in the allocation. The Agency did maintain system summary reports at the time of the allocation, and the total counts on the summary reports did agree to amounts used for the allocation. However, as the summary reports used did not maintain the detail of members counted, we could not verify the accuracy of the reports used. The IST Application Services NFOCUS Applications cost center allocated $3,800,340 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C23823 iServe IAPD H971 ? Shared for the quarter ending June 30, 2022. The Agency is developing the new iServe Nebraska Portal, which is an application for Nebraskans to apply for benefits from Federal and State programs. This application will be replacing ACCESSNebraska, the current application used by Nebraskans to apply for benefits. For the implementation phase of the project, the Agency was only allocating costs to the following four programs: LIHEAP, TANF, SNAP, and Medicaid. However, there are other Federal and State programs that will utilize the iServe application. We asked for documentation to support that these were the only four programs that were benefiting from this stage of the project. The Agency provided correspondence from its Federal contacts, which stated: ?As long as SNAP, Medicaid, LIHEAP, and TANF are the only benefiting programs for the State?s iServe Nebraska Portal project, the State may just include these four programs in the development of its cost allocation plan. If/when the State decides to add other Federal programs that will benefit from enhancements to the portal, it will need to revisit and adjust its cost allocation plan.? We asked again for documentation, such as internal planning documents, to support that these were the only four programs benefiting from this stage of the project. The Agency replied that it did not have the documentation at this time. The iServe IAPD H971 ? Shared cost center allocated $6,019,121 for the quarter ended June 30, 2022. We were unable to determine questioned costs as we were not able to determine which Federal and State program should receive an allocation, and the basis for how the costs would be allocated to these programs. Cause: Inadequate procedures to ensure that system reports were set up correctly, employees coded their time correctly, and allocations were adequately supported and calculated correctly. Effect: Without adequate documentation to support the allocation of costs, there is increased risk of programs not being charged the proper amounts. Recommendation: We recommend the Agency improve procedures to ensure that employee pay is recorded correctly in E1, system reports are set up correctly, and costs are properly allocated and charged. Management Response: The Agency agrees.
Program: AL 93.558 ? Temporary Assistance to Needy Families; AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.658 ? Foster Care Title IV-E ? Allowable Cost/Cost Principles Grant Number & Year: 1901NETANF, FFY 2019; 2101NEFOST, FFY 2021; 2201NEFOST, FFY 2022; 202121S251443, FFY 2021; 202222S251443, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: Per 45 CFR ? 75.303 (October 1, 2021): 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be reasonable, necessary, and adequately documented. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 200.303 (January 1, 2022): The non-Federal entity must: (a) Establish and maintain effective internal control 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per the CAP, ?The RMTS Administrator is an employee of the Division of Children and Family Services and is responsible for . . . . verification that all forms are submitted to the Completed Surveys database, review of the worker entries to validate consistent practice among participants . . . .? Per the CAP, ?Each worker should be trained in the completion of the observation form and to the importance of providing accurate and timely responses.? According to RMTS Explanations: 1. Case Work ? Select this item if you were working on a specific case at the observation time. If you select this item you will be asked to enter the NFOCUS master case number. If there is not an NFOCUS master case, use any other number or description that can be used to identify the case . . . . According to the RMTS Instructions for the Worker: ?After the observation form has been submitted and validated (if selected for validation), it is reviewed by a member of the CFS and Cost Accounting Office for consistency.? According to the RMTS Instructions for the Supervisor: ?If you agree with the worker?s selections, you can click the ?VALIDATION? button. If you do not agree with the worker?s selections, you need to confer with the worker on the selection process and reach agreement on the proper selections for the form. Make updates as needed, and click the ?VALIDATION? button to attach the supervisor?s electronic signature and validate the form.? Good internal control and sound accounting practices require procedures to ensure that staff know how to complete accurate random moment time studies, which are used to allocate costs to Federal programs. Condition: The Agency did not have adequate procedures to ensure the accuracy of the RMTS. A similar finding was noted in the prior audit. Repeat Finding: 2021-033 Questioned Costs: $14,131 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: The RMTS is conducted on an ongoing basis to provide data for the allocation of direct and indirect costs to various programs. The objective is to identify employee efforts directly related to programs administered by the Agency. We tested 48 validated RMTS observations and noted that inadequate documentation was provided on 11 of them. We noted the following: ? For two of four Foster Care IV-E observations tested, the observations should have been reported as Foster Care Non IV-E per the documentation in the case files. For one of these observations, the case worker noted in the comments that she selected the wrong option. However, it was still validated without correction. ? For five of 21 SNAP observations tested, the RMTS observation form appeared to have been completed incorrectly by the case worker. For two of these observations, the case worker selected the SNAP program; however, per the case files, the case worker appeared to be working on other programs along with SNAP at the time of the observation or was not working on SNAP at all at the time of the observation. As we could not confirm from the documentation on file what the case worker was working on, the questioned costs are unknown. For the other three observations, the case workers did not document which cases they were working on. ? For four of 12 TANF observations tested, the RMTS observation forms appeared to have been completed incorrectly by the case workers. The case workers selected the TANF program; however, per the case files, the case workers appeared to be working on other programs along with TANF at the time of the observation, or, for one case, not working on TANF at all. As we could not confirm from the documentation on file what the case worker was working on, the questioned costs are unknown. Total known Federal payment errors, amount tested, error rate (amount of errors/ amount tested), total dollars charged via RMTS, and potential dollars at risk (dollar rate multiplied by the population total dollars charged) are summarized below by program: See Schedule of Findings and Questioned Costs for chart/table. The APA also inquired with Agency staff to determine if they were provided training in how to complete the random moment time studies. For one individual, the Agency was unable to provide documentation to support that the employee selected had completed RMTS training. Cause: The Agency?s training of staff and supervisory reviews of RMTS observations were not sufficient to ensure the observations were accurately completed. Effect: Random moment sampling is based on the laws of probability, which state, in essence, that there is a high probability that a relatively small number of random observations will yield an accurate depiction of the overall characteristics of the population for which the sample was taken. If RMTS observations are not accurate, there is an increased risk costs will be allocated incorrectly between programs. Recommendation: We recommend the Agency improve procedures to ensure that random moment observations are accurate and adequately reviewed. Management Response: The Agency agrees.
Program: AL 84.010 ? Title I Grants to Local Educational Agencies ? Allowability and Subrecipient Monitoring Grant Number & Year: S010A190027, FFY 2020; S010A200027, FFY 2021 Federal Grantor Agency: U.S. Department of Education Criteria: Per 2 CFR ? 3474.1 (January 1, 2022), the U.S. Department of Education adopted the OMB Uniform Guidance in 2 CFR part 200, except for 2 CFR ? 200.102(a) and 200.207(a). Per 2 CFR ? 200.403 (January 1, 2022), allowable costs must be necessary, reasonable, and adequately documented. 2 CFR ? 200.430(i)(1) (January 1, 2022) states, in relevant part, the following: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities . . . . ; (iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity . . . . ; and * * * * (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Enclosure A of the ?Letter to Chief State School Officers on Granting Administrative Flexibility for Better Measures of Success? (September 7, 2012) provides guidelines for local educational agencies (LEAs), using a substitute system for time-and-effort reporting. Enclosure A states, in relevant part, the following: (3) Employee schedules must: a. Indicate the specific activity or cost objective that the employee worked on for each segment of the employee?s schedule; b. Account for the total hours for which each employee is compensated during the period reflected on the employee?s schedule; and c. Be certified at least semiannually and signed by the employee and a supervisory official having firsthand knowledge of the work performed by the employee. 2 CFR ? 200.332 (January 1, 2022) states, in relevant part, the following: All pass-through entities must: * * * * (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: * * * * (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient . . . . A good internal control plan requires that adequate documentation be maintained to support amounts claimed by and paid to subrecipients. Good internal control also requires procedures to follow up with subrecipients to ensure they are correcting deficiencies and in compliance with applicable regulations. Condition: The Agency lacked procedures to ensure that subrecipients documented their use of Federal awards appropriately. Repeat Finding: No Questioned Costs: $145,101 known (S010A190027, $8,041; S010A200027, $137,060) Statistical Sample: No Context: We randomly selected 25 subrecipient payments and also chose the largest subrecipient payment for testing. We noted the following: ? Several employees? salaries and benefits were included in the reimbursement requests; however, the Agency did not require subrecipients to submit documentation for these expenditures, other than reports from their accountings systems, at the time of reimbursement. We provided the Agency with an opportunity to request documentation from its subrecipients to support that their salaries and benefits expenses were allowable and in accordance with Federal cost principles; however, two of the subrecipients did not provide adequate support to show that their salaries and benefits were allocable to the grant, resulting in $8,041 sample questioned costs and $137,060 non-sample questioned costs. ? The Agency?s procedure is to perform fiscal reviews of each subrecipient at least once every three years. We reviewed the most recent fiscal reviews for the same 26 subrecipients selected for testing above. For five of these reviews, the Agency noted that the subrecipient did not maintain adequate documentation for salaries and benefits. When we inquired with the Agency regarding what had been done to follow up on its findings, the Agency replied that the findings did not require follow-up. Payment errors noted for the sample tested were $8,041. The total sample tested was $1,494,006. Subrecipient aid payments for the fiscal year ended June 30, 2022, totaled $91,043,602. The sample population was $84,396,850 (total population $91,043,602 less $6,646,752 to largest subrecipient that was separately determined to be allowable). Based on the sample tested, the case error rate was 8% (2/25). The dollar error rate for the sample was 0.54% ($8,041/$1,494,006), which estimates the potential dollars at risk for fiscal year 2022 to be $455,753 (dollar rate multiplied by the population). Cause: Inadequate procedures. Effect: Without adequate supporting documentation and monitoring procedures, there is an increased risk that Federal awards could be used for unallowable costs. Recommendation: We recommend the Agency improve procedures to monitor subrecipients, including reviewing detailed supporting documentation for payroll expenses and following up with subrecipients to ensure that they correct errors noted. Management Response: The Department agrees the two subrecipients sampled did not complete one time and effort certification semi-annually (rather completed annually instead) or with all language suggested in the guidelines from the U.S. Department of Education. However, the Department disagrees with the reimbursement being questioned costs as the time and effort certifications demonstrated adequate documentation to support the employees? activities were allowable for the Title I grant. In the absence of this information, the Department submitted affidavits from the two LEA?s supervisory staff with personal knowledge of the work performed consistent with the U.S. Department of Education?s audit resolutions practices; whereas the APA does not consider documentation after the fact to be adequate to eliminate the finding. The findings noted in the subrecipient fiscal monitoring exit letters were identified for technical assistance purposes only and not considered to have met a level of materiality that required a corrective action plan. Corrective action plans are clearly noted in subrecipient fiscal monitoring exit letters when issued and proper follow-up action is taken when this occurs. Technical assistance was provided to each of the subrecipients at the time of the monitoring review as well as to all subrecipients periodically throughout the year. APA Response: Per the Uniform Guidance, questioned costs include expenditures that lack adequate supporting documentation at the time of the audit. 2 CFR ? 200.430(i)(1) (January 1, 2022), as referenced in the report comment, says that such documentation must ?accurately reflect the work performed? and be ?supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.? Affidavits dated February 27, 2023, some 18 months after the salary and benefit expenses occurred, cannot possibly satisfy either of these requirements and are, therefore, not acceptable. As the documentation provided did not meet the minimum requirements set forth in Uniform Guidance and guidance issued by the U.S. Department of Education, the expenditures at issue must be considered questioned costs. Moreover, the Uniform Guidance requires the Agency, as the pass-through entity, to ensure that the subrecipient takes timely and appropriate action to address deficiencies identified not only during audits but also from the Agency?s own reviews. The Agency has noted issues similar to those addressed by the APA ? namely, that the subrecipients have lacked adequate supporting documentation for salary and benefit expenses. The Agency performs subrecipient fiscal monitoring for most subrecipients only every third year. Thus, effective follow-up procedures, as required by 2 CFR ? 200.332 (January 1, 2022), are needed to ensure that subrecipients implement the technical assistance provided by the Agency.
Program: Various, including AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 ? Temporary Assistance for Needy Families; AL 93.566 ? Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 ? Child Care and Development Block Grant ? Allowable Costs/Cost Principles Grant Number & Year: Various, including 202121S251443, FFY 2021; 202222S251443, FFY 2022; 1901NETANF, FFY 2019; 2101NERCMA, FFY 2021; 2201NERCMA, FFY 2022; 2201NECCDD, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: 45 CFR ? 75.303 (October 1, 2021) states, in relevant part, the following: 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be necessary, reasonable, and adequately documented. 45 CFR ? 75.302 (October 1, 2021) requires financial management systems of the State sufficient to permit both preparation of required reports and tracing of funds to expenditures adequate to establish that the use of those funds was in accordance with applicable regulations. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 400.1 (January 1, 2022), the U.S. Department of Agriculture adopted the OMB Uniform Guidance as its policies and procedures for uniform administrative requirements, cost principles, and audit requirements for Federal awards. 2 CFR ? 200.303 (January 1, 2022) states, in part, the following: 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. 45 CFR ? 75.511(b) and 2 CFR ? 200.511(b) (January 1, 2022) state, in relevant part, the following: The summary schedule of prior audit findings must report the status of all audit findings included in the prior audit?s schedule of findings and questioned costs. . . . * * * * (2) When audit findings were not corrected or were only partially corrected, the summary schedule must describe the reasons for the finding?s recurrence and planned corrective action, and any partial corrective action taken. When corrective action taken is significantly different from corrective action previously reported in a corrective action plan or in the Federal agency?s or pass-through entity?s management decision, the summary schedule must provide an explanation. Good internal control requires procedures to ensure that amounts charged to Federal programs are proper. Condition: The Agency did not properly charge Federal programs for seven allocations tested. A similar finding was noted in the prior audit. The Summary Schedule of Prior Audit Findings lists the status as completed. Repeat Finding: 2021-031, 2021-032 Questioned Costs: $44,356 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: For seven of 14 allocations tested, we noted the following: ? We tested the allocation of cost center 25C21940 Field Office Resource Development for the quarter ended September 30, 2021, which is allocated based on Time & Effort reports. The payroll costs for 85 employees were charged to the cost center; however, four of the employees? payroll costs should not have been charged to the cost center. The four employees tested included a Federal Aid Administrator, a Program Accuracy Specialist, and two Office Specialists. The supervisors they worked with were not charged to this cost center, and the employees were not employed as Resource Developers, which was the job title of most of the employees included in this cost center. As a result of these employees being charged to the Resource Development cost center instead of their appropriate cost centers, Child Care and Development, Foster Care, Adoption Assistance, Guardianship Assistance, and Medicaid were not charged correctly, ranging from undercharges of $2,653 to overcharges of $2,402. Additionally, we were unable to determine how the payroll costs of $9,858 to the Federal Aid Administrator should have been allocated. The Resource Development cost center allocated $1,444,162 for the quarter ended September 30, 2021. A similar finding was noted in the prior audit. ? We tested the allocation of cost center 25C20680 Legal Services General Legal Teams for the quarter ended June 30, 2022, which is allocated based on Time & Effort reports. The payroll costs for a Legislative Coordinator were recorded to this cost center during the quarter. However, these costs should have been recorded to cost center 25C20720 Communications and Legislative Services Administration. As a result, this employee?s payroll costs of $15,777 during the quarter were not allocated to Federal programs correctly. We were unable to determine how these payroll costs should have been allocated. The Legal Services General Legal Teams cost center allocated $1,332,052 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21960 Field Office Social Services Casework for quarter ended September 30, 2021, which is allocated based on random moment time studies (RMTS) results. The Bridges to Independence program and Guardianship Assistance program should have been allocated $1,464 each from this cost center; however, the Agency did not include these programs in the allocation. As a result, the Federal grants for Refugee and Entrant Assistance, Child Care and Development, Foster Care, Adoption Assistance, Temporary Assistance to Needy Families (TANF), Supplemental Nutrition Assistance Program (SNAP), and Medicaid were overcharged, ranging from $3 to $982, and the Guardianship Assistance grant was undercharged $732. The Field Office Social Services Casework cost center allocated $8,099,617 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C21920 Field Office Child Protection & Safety Services for the quarter ended June 30, 2022, which is allocated based on RMTS results. The Agency began using a new RMTS system in January 2022; however, the Agency did not set up the quarterly summary reports correctly. Below are the issues noted: o RMTS observations for Trial Home Visits were not included in the allocation. As a result, State programs were undercharged, and Federal programs were overcharged. o The RMTS observations for Child Protection Initial Assessment were not properly allocated. As a result, Foster Care was overcharged, and Adoption and Guardianship were undercharged. o The RMTS observations for Before or After Work Hours were incorrectly included in the State?s allocation. As a result, Federal programs were undercharged. In total, Federal grants for Adoption Assistance, Foster Care, and Guardianship Assistance were undercharged $28,560, $113,762, and $1,990, respectively. The Field Office Child Protection & Safety Services cost center allocated $12,429,881 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21910 Field Office Administration for the quarter ended June 30, 2022, which is allocated based on labor hours. The Agency did not include all of the applicable labor hours for the Medicaid program. As a result, the Federal grants for Adoption Assistance, Foster Care, Guardianship Assistance, Refugee and Entrant Assistance, Child Care and Development, TANF, and SNAP were overcharged, ranging from $265 to $30,556, and the Medicaid grant was undercharged $235,906. The Field Office Administration cost center allocated $3,236,547 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C20990 IST Application NFOCUS Applications for the quarter ended September 30, 2021, which is allocated based on client counts per NFOCUS/MMIS reports. We noted that the Foster Care and TANF recipient counts used in the allocation did not agree to support. The Foster Care count included 71 clients that were paid with State funds, resulting in $265 being overcharged to the Foster Care grant, and the TANF count included 48 clients that were paid with State funds, resulting in $358 being overcharged to the TANF grant. Additionally, we were unable to trace the member counts to documentation that supported allocating $1,853,284 to Medicaid and $283,190 to the Children?s Health Insurance Program (CHIP). The Agency did not maintain the member count reports used at the time of the allocation. The Agency was able to generate a historical report; however, while the report amounts were similar, they did not agree with the counts used in the allocation. The Agency did maintain system summary reports at the time of the allocation, and the total counts on the summary reports did agree to amounts used for the allocation. However, as the summary reports used did not maintain the detail of members counted, we could not verify the accuracy of the reports used. The IST Application Services NFOCUS Applications cost center allocated $3,800,340 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C23823 iServe IAPD H971 ? Shared for the quarter ending June 30, 2022. The Agency is developing the new iServe Nebraska Portal, which is an application for Nebraskans to apply for benefits from Federal and State programs. This application will be replacing ACCESSNebraska, the current application used by Nebraskans to apply for benefits. For the implementation phase of the project, the Agency was only allocating costs to the following four programs: LIHEAP, TANF, SNAP, and Medicaid. However, there are other Federal and State programs that will utilize the iServe application. We asked for documentation to support that these were the only four programs that were benefiting from this stage of the project. The Agency provided correspondence from its Federal contacts, which stated: ?As long as SNAP, Medicaid, LIHEAP, and TANF are the only benefiting programs for the State?s iServe Nebraska Portal project, the State may just include these four programs in the development of its cost allocation plan. If/when the State decides to add other Federal programs that will benefit from enhancements to the portal, it will need to revisit and adjust its cost allocation plan.? We asked again for documentation, such as internal planning documents, to support that these were the only four programs benefiting from this stage of the project. The Agency replied that it did not have the documentation at this time. The iServe IAPD H971 ? Shared cost center allocated $6,019,121 for the quarter ended June 30, 2022. We were unable to determine questioned costs as we were not able to determine which Federal and State program should receive an allocation, and the basis for how the costs would be allocated to these programs. Cause: Inadequate procedures to ensure that system reports were set up correctly, employees coded their time correctly, and allocations were adequately supported and calculated correctly. Effect: Without adequate documentation to support the allocation of costs, there is increased risk of programs not being charged the proper amounts. Recommendation: We recommend the Agency improve procedures to ensure that employee pay is recorded correctly in E1, system reports are set up correctly, and costs are properly allocated and charged. Management Response: The Agency agrees.
Program: AL 93.558 ? Temporary Assistance to Needy Families; AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.658 ? Foster Care Title IV-E ? Allowable Cost/Cost Principles Grant Number & Year: 1901NETANF, FFY 2019; 2101NEFOST, FFY 2021; 2201NEFOST, FFY 2022; 202121S251443, FFY 2021; 202222S251443, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: Per 45 CFR ? 75.303 (October 1, 2021): 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be reasonable, necessary, and adequately documented. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 200.303 (January 1, 2022): The non-Federal entity must: (a) Establish and maintain effective internal control 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per the CAP, ?The RMTS Administrator is an employee of the Division of Children and Family Services and is responsible for . . . . verification that all forms are submitted to the Completed Surveys database, review of the worker entries to validate consistent practice among participants . . . .? Per the CAP, ?Each worker should be trained in the completion of the observation form and to the importance of providing accurate and timely responses.? According to RMTS Explanations: 1. Case Work ? Select this item if you were working on a specific case at the observation time. If you select this item you will be asked to enter the NFOCUS master case number. If there is not an NFOCUS master case, use any other number or description that can be used to identify the case . . . . According to the RMTS Instructions for the Worker: ?After the observation form has been submitted and validated (if selected for validation), it is reviewed by a member of the CFS and Cost Accounting Office for consistency.? According to the RMTS Instructions for the Supervisor: ?If you agree with the worker?s selections, you can click the ?VALIDATION? button. If you do not agree with the worker?s selections, you need to confer with the worker on the selection process and reach agreement on the proper selections for the form. Make updates as needed, and click the ?VALIDATION? button to attach the supervisor?s electronic signature and validate the form.? Good internal control and sound accounting practices require procedures to ensure that staff know how to complete accurate random moment time studies, which are used to allocate costs to Federal programs. Condition: The Agency did not have adequate procedures to ensure the accuracy of the RMTS. A similar finding was noted in the prior audit. Repeat Finding: 2021-033 Questioned Costs: $14,131 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: The RMTS is conducted on an ongoing basis to provide data for the allocation of direct and indirect costs to various programs. The objective is to identify employee efforts directly related to programs administered by the Agency. We tested 48 validated RMTS observations and noted that inadequate documentation was provided on 11 of them. We noted the following: ? For two of four Foster Care IV-E observations tested, the observations should have been reported as Foster Care Non IV-E per the documentation in the case files. For one of these observations, the case worker noted in the comments that she selected the wrong option. However, it was still validated without correction. ? For five of 21 SNAP observations tested, the RMTS observation form appeared to have been completed incorrectly by the case worker. For two of these observations, the case worker selected the SNAP program; however, per the case files, the case worker appeared to be working on other programs along with SNAP at the time of the observation or was not working on SNAP at all at the time of the observation. As we could not confirm from the documentation on file what the case worker was working on, the questioned costs are unknown. For the other three observations, the case workers did not document which cases they were working on. ? For four of 12 TANF observations tested, the RMTS observation forms appeared to have been completed incorrectly by the case workers. The case workers selected the TANF program; however, per the case files, the case workers appeared to be working on other programs along with TANF at the time of the observation, or, for one case, not working on TANF at all. As we could not confirm from the documentation on file what the case worker was working on, the questioned costs are unknown. Total known Federal payment errors, amount tested, error rate (amount of errors/ amount tested), total dollars charged via RMTS, and potential dollars at risk (dollar rate multiplied by the population total dollars charged) are summarized below by program: See Schedule of Findings and Questioned Costs for chart/table. The APA also inquired with Agency staff to determine if they were provided training in how to complete the random moment time studies. For one individual, the Agency was unable to provide documentation to support that the employee selected had completed RMTS training. Cause: The Agency?s training of staff and supervisory reviews of RMTS observations were not sufficient to ensure the observations were accurately completed. Effect: Random moment sampling is based on the laws of probability, which state, in essence, that there is a high probability that a relatively small number of random observations will yield an accurate depiction of the overall characteristics of the population for which the sample was taken. If RMTS observations are not accurate, there is an increased risk costs will be allocated incorrectly between programs. Recommendation: We recommend the Agency improve procedures to ensure that random moment observations are accurate and adequately reviewed. Management Response: The Agency agrees.
Program: Various, including AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 ? Temporary Assistance for Needy Families; AL 93.566 ? Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 ? Child Care and Development Block Grant ? Allowable Costs/Cost Principles Grant Number & Year: Various, including 202121S251443, FFY 2021; 202222S251443, FFY 2022; 1901NETANF, FFY 2019; 2101NERCMA, FFY 2021; 2201NERCMA, FFY 2022; 2201NECCDD, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: 45 CFR ? 75.303 (October 1, 2021) states, in relevant part, the following: 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be necessary, reasonable, and adequately documented. 45 CFR ? 75.302 (October 1, 2021) requires financial management systems of the State sufficient to permit both preparation of required reports and tracing of funds to expenditures adequate to establish that the use of those funds was in accordance with applicable regulations. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 400.1 (January 1, 2022), the U.S. Department of Agriculture adopted the OMB Uniform Guidance as its policies and procedures for uniform administrative requirements, cost principles, and audit requirements for Federal awards. 2 CFR ? 200.303 (January 1, 2022) states, in part, the following: 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. 45 CFR ? 75.511(b) and 2 CFR ? 200.511(b) (January 1, 2022) state, in relevant part, the following: The summary schedule of prior audit findings must report the status of all audit findings included in the prior audit?s schedule of findings and questioned costs. . . . * * * * (2) When audit findings were not corrected or were only partially corrected, the summary schedule must describe the reasons for the finding?s recurrence and planned corrective action, and any partial corrective action taken. When corrective action taken is significantly different from corrective action previously reported in a corrective action plan or in the Federal agency?s or pass-through entity?s management decision, the summary schedule must provide an explanation. Good internal control requires procedures to ensure that amounts charged to Federal programs are proper. Condition: The Agency did not properly charge Federal programs for seven allocations tested. A similar finding was noted in the prior audit. The Summary Schedule of Prior Audit Findings lists the status as completed. Repeat Finding: 2021-031, 2021-032 Questioned Costs: $44,356 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: For seven of 14 allocations tested, we noted the following: ? We tested the allocation of cost center 25C21940 Field Office Resource Development for the quarter ended September 30, 2021, which is allocated based on Time & Effort reports. The payroll costs for 85 employees were charged to the cost center; however, four of the employees? payroll costs should not have been charged to the cost center. The four employees tested included a Federal Aid Administrator, a Program Accuracy Specialist, and two Office Specialists. The supervisors they worked with were not charged to this cost center, and the employees were not employed as Resource Developers, which was the job title of most of the employees included in this cost center. As a result of these employees being charged to the Resource Development cost center instead of their appropriate cost centers, Child Care and Development, Foster Care, Adoption Assistance, Guardianship Assistance, and Medicaid were not charged correctly, ranging from undercharges of $2,653 to overcharges of $2,402. Additionally, we were unable to determine how the payroll costs of $9,858 to the Federal Aid Administrator should have been allocated. The Resource Development cost center allocated $1,444,162 for the quarter ended September 30, 2021. A similar finding was noted in the prior audit. ? We tested the allocation of cost center 25C20680 Legal Services General Legal Teams for the quarter ended June 30, 2022, which is allocated based on Time & Effort reports. The payroll costs for a Legislative Coordinator were recorded to this cost center during the quarter. However, these costs should have been recorded to cost center 25C20720 Communications and Legislative Services Administration. As a result, this employee?s payroll costs of $15,777 during the quarter were not allocated to Federal programs correctly. We were unable to determine how these payroll costs should have been allocated. The Legal Services General Legal Teams cost center allocated $1,332,052 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21960 Field Office Social Services Casework for quarter ended September 30, 2021, which is allocated based on random moment time studies (RMTS) results. The Bridges to Independence program and Guardianship Assistance program should have been allocated $1,464 each from this cost center; however, the Agency did not include these programs in the allocation. As a result, the Federal grants for Refugee and Entrant Assistance, Child Care and Development, Foster Care, Adoption Assistance, Temporary Assistance to Needy Families (TANF), Supplemental Nutrition Assistance Program (SNAP), and Medicaid were overcharged, ranging from $3 to $982, and the Guardianship Assistance grant was undercharged $732. The Field Office Social Services Casework cost center allocated $8,099,617 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C21920 Field Office Child Protection & Safety Services for the quarter ended June 30, 2022, which is allocated based on RMTS results. The Agency began using a new RMTS system in January 2022; however, the Agency did not set up the quarterly summary reports correctly. Below are the issues noted: o RMTS observations for Trial Home Visits were not included in the allocation. As a result, State programs were undercharged, and Federal programs were overcharged. o The RMTS observations for Child Protection Initial Assessment were not properly allocated. As a result, Foster Care was overcharged, and Adoption and Guardianship were undercharged. o The RMTS observations for Before or After Work Hours were incorrectly included in the State?s allocation. As a result, Federal programs were undercharged. In total, Federal grants for Adoption Assistance, Foster Care, and Guardianship Assistance were undercharged $28,560, $113,762, and $1,990, respectively. The Field Office Child Protection & Safety Services cost center allocated $12,429,881 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21910 Field Office Administration for the quarter ended June 30, 2022, which is allocated based on labor hours. The Agency did not include all of the applicable labor hours for the Medicaid program. As a result, the Federal grants for Adoption Assistance, Foster Care, Guardianship Assistance, Refugee and Entrant Assistance, Child Care and Development, TANF, and SNAP were overcharged, ranging from $265 to $30,556, and the Medicaid grant was undercharged $235,906. The Field Office Administration cost center allocated $3,236,547 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C20990 IST Application NFOCUS Applications for the quarter ended September 30, 2021, which is allocated based on client counts per NFOCUS/MMIS reports. We noted that the Foster Care and TANF recipient counts used in the allocation did not agree to support. The Foster Care count included 71 clients that were paid with State funds, resulting in $265 being overcharged to the Foster Care grant, and the TANF count included 48 clients that were paid with State funds, resulting in $358 being overcharged to the TANF grant. Additionally, we were unable to trace the member counts to documentation that supported allocating $1,853,284 to Medicaid and $283,190 to the Children?s Health Insurance Program (CHIP). The Agency did not maintain the member count reports used at the time of the allocation. The Agency was able to generate a historical report; however, while the report amounts were similar, they did not agree with the counts used in the allocation. The Agency did maintain system summary reports at the time of the allocation, and the total counts on the summary reports did agree to amounts used for the allocation. However, as the summary reports used did not maintain the detail of members counted, we could not verify the accuracy of the reports used. The IST Application Services NFOCUS Applications cost center allocated $3,800,340 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C23823 iServe IAPD H971 ? Shared for the quarter ending June 30, 2022. The Agency is developing the new iServe Nebraska Portal, which is an application for Nebraskans to apply for benefits from Federal and State programs. This application will be replacing ACCESSNebraska, the current application used by Nebraskans to apply for benefits. For the implementation phase of the project, the Agency was only allocating costs to the following four programs: LIHEAP, TANF, SNAP, and Medicaid. However, there are other Federal and State programs that will utilize the iServe application. We asked for documentation to support that these were the only four programs that were benefiting from this stage of the project. The Agency provided correspondence from its Federal contacts, which stated: ?As long as SNAP, Medicaid, LIHEAP, and TANF are the only benefiting programs for the State?s iServe Nebraska Portal project, the State may just include these four programs in the development of its cost allocation plan. If/when the State decides to add other Federal programs that will benefit from enhancements to the portal, it will need to revisit and adjust its cost allocation plan.? We asked again for documentation, such as internal planning documents, to support that these were the only four programs benefiting from this stage of the project. The Agency replied that it did not have the documentation at this time. The iServe IAPD H971 ? Shared cost center allocated $6,019,121 for the quarter ended June 30, 2022. We were unable to determine questioned costs as we were not able to determine which Federal and State program should receive an allocation, and the basis for how the costs would be allocated to these programs. Cause: Inadequate procedures to ensure that system reports were set up correctly, employees coded their time correctly, and allocations were adequately supported and calculated correctly. Effect: Without adequate documentation to support the allocation of costs, there is increased risk of programs not being charged the proper amounts. Recommendation: We recommend the Agency improve procedures to ensure that employee pay is recorded correctly in E1, system reports are set up correctly, and costs are properly allocated and charged. Management Response: The Agency agrees.
Program: Various, including AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 ? Temporary Assistance for Needy Families; AL 93.566 ? Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 ? Child Care and Development Block Grant ? Allowable Costs/Cost Principles Grant Number & Year: Various, including 202121S251443, FFY 2021; 202222S251443, FFY 2022; 1901NETANF, FFY 2019; 2101NERCMA, FFY 2021; 2201NERCMA, FFY 2022; 2201NECCDD, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: 45 CFR ? 75.303 (October 1, 2021) states, in relevant part, the following: 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be necessary, reasonable, and adequately documented. 45 CFR ? 75.302 (October 1, 2021) requires financial management systems of the State sufficient to permit both preparation of required reports and tracing of funds to expenditures adequate to establish that the use of those funds was in accordance with applicable regulations. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 400.1 (January 1, 2022), the U.S. Department of Agriculture adopted the OMB Uniform Guidance as its policies and procedures for uniform administrative requirements, cost principles, and audit requirements for Federal awards. 2 CFR ? 200.303 (January 1, 2022) states, in part, the following: 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. 45 CFR ? 75.511(b) and 2 CFR ? 200.511(b) (January 1, 2022) state, in relevant part, the following: The summary schedule of prior audit findings must report the status of all audit findings included in the prior audit?s schedule of findings and questioned costs. . . . * * * * (2) When audit findings were not corrected or were only partially corrected, the summary schedule must describe the reasons for the finding?s recurrence and planned corrective action, and any partial corrective action taken. When corrective action taken is significantly different from corrective action previously reported in a corrective action plan or in the Federal agency?s or pass-through entity?s management decision, the summary schedule must provide an explanation. Good internal control requires procedures to ensure that amounts charged to Federal programs are proper. Condition: The Agency did not properly charge Federal programs for seven allocations tested. A similar finding was noted in the prior audit. The Summary Schedule of Prior Audit Findings lists the status as completed. Repeat Finding: 2021-031, 2021-032 Questioned Costs: $44,356 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: For seven of 14 allocations tested, we noted the following: ? We tested the allocation of cost center 25C21940 Field Office Resource Development for the quarter ended September 30, 2021, which is allocated based on Time & Effort reports. The payroll costs for 85 employees were charged to the cost center; however, four of the employees? payroll costs should not have been charged to the cost center. The four employees tested included a Federal Aid Administrator, a Program Accuracy Specialist, and two Office Specialists. The supervisors they worked with were not charged to this cost center, and the employees were not employed as Resource Developers, which was the job title of most of the employees included in this cost center. As a result of these employees being charged to the Resource Development cost center instead of their appropriate cost centers, Child Care and Development, Foster Care, Adoption Assistance, Guardianship Assistance, and Medicaid were not charged correctly, ranging from undercharges of $2,653 to overcharges of $2,402. Additionally, we were unable to determine how the payroll costs of $9,858 to the Federal Aid Administrator should have been allocated. The Resource Development cost center allocated $1,444,162 for the quarter ended September 30, 2021. A similar finding was noted in the prior audit. ? We tested the allocation of cost center 25C20680 Legal Services General Legal Teams for the quarter ended June 30, 2022, which is allocated based on Time & Effort reports. The payroll costs for a Legislative Coordinator were recorded to this cost center during the quarter. However, these costs should have been recorded to cost center 25C20720 Communications and Legislative Services Administration. As a result, this employee?s payroll costs of $15,777 during the quarter were not allocated to Federal programs correctly. We were unable to determine how these payroll costs should have been allocated. The Legal Services General Legal Teams cost center allocated $1,332,052 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21960 Field Office Social Services Casework for quarter ended September 30, 2021, which is allocated based on random moment time studies (RMTS) results. The Bridges to Independence program and Guardianship Assistance program should have been allocated $1,464 each from this cost center; however, the Agency did not include these programs in the allocation. As a result, the Federal grants for Refugee and Entrant Assistance, Child Care and Development, Foster Care, Adoption Assistance, Temporary Assistance to Needy Families (TANF), Supplemental Nutrition Assistance Program (SNAP), and Medicaid were overcharged, ranging from $3 to $982, and the Guardianship Assistance grant was undercharged $732. The Field Office Social Services Casework cost center allocated $8,099,617 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C21920 Field Office Child Protection & Safety Services for the quarter ended June 30, 2022, which is allocated based on RMTS results. The Agency began using a new RMTS system in January 2022; however, the Agency did not set up the quarterly summary reports correctly. Below are the issues noted: o RMTS observations for Trial Home Visits were not included in the allocation. As a result, State programs were undercharged, and Federal programs were overcharged. o The RMTS observations for Child Protection Initial Assessment were not properly allocated. As a result, Foster Care was overcharged, and Adoption and Guardianship were undercharged. o The RMTS observations for Before or After Work Hours were incorrectly included in the State?s allocation. As a result, Federal programs were undercharged. In total, Federal grants for Adoption Assistance, Foster Care, and Guardianship Assistance were undercharged $28,560, $113,762, and $1,990, respectively. The Field Office Child Protection & Safety Services cost center allocated $12,429,881 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C21910 Field Office Administration for the quarter ended June 30, 2022, which is allocated based on labor hours. The Agency did not include all of the applicable labor hours for the Medicaid program. As a result, the Federal grants for Adoption Assistance, Foster Care, Guardianship Assistance, Refugee and Entrant Assistance, Child Care and Development, TANF, and SNAP were overcharged, ranging from $265 to $30,556, and the Medicaid grant was undercharged $235,906. The Field Office Administration cost center allocated $3,236,547 for the quarter ended June 30, 2022. ? We tested the allocation of cost center 25C20990 IST Application NFOCUS Applications for the quarter ended September 30, 2021, which is allocated based on client counts per NFOCUS/MMIS reports. We noted that the Foster Care and TANF recipient counts used in the allocation did not agree to support. The Foster Care count included 71 clients that were paid with State funds, resulting in $265 being overcharged to the Foster Care grant, and the TANF count included 48 clients that were paid with State funds, resulting in $358 being overcharged to the TANF grant. Additionally, we were unable to trace the member counts to documentation that supported allocating $1,853,284 to Medicaid and $283,190 to the Children?s Health Insurance Program (CHIP). The Agency did not maintain the member count reports used at the time of the allocation. The Agency was able to generate a historical report; however, while the report amounts were similar, they did not agree with the counts used in the allocation. The Agency did maintain system summary reports at the time of the allocation, and the total counts on the summary reports did agree to amounts used for the allocation. However, as the summary reports used did not maintain the detail of members counted, we could not verify the accuracy of the reports used. The IST Application Services NFOCUS Applications cost center allocated $3,800,340 for the quarter ended September 30, 2021. ? We tested the allocation of cost center 25C23823 iServe IAPD H971 ? Shared for the quarter ending June 30, 2022. The Agency is developing the new iServe Nebraska Portal, which is an application for Nebraskans to apply for benefits from Federal and State programs. This application will be replacing ACCESSNebraska, the current application used by Nebraskans to apply for benefits. For the implementation phase of the project, the Agency was only allocating costs to the following four programs: LIHEAP, TANF, SNAP, and Medicaid. However, there are other Federal and State programs that will utilize the iServe application. We asked for documentation to support that these were the only four programs that were benefiting from this stage of the project. The Agency provided correspondence from its Federal contacts, which stated: ?As long as SNAP, Medicaid, LIHEAP, and TANF are the only benefiting programs for the State?s iServe Nebraska Portal project, the State may just include these four programs in the development of its cost allocation plan. If/when the State decides to add other Federal programs that will benefit from enhancements to the portal, it will need to revisit and adjust its cost allocation plan.? We asked again for documentation, such as internal planning documents, to support that these were the only four programs benefiting from this stage of the project. The Agency replied that it did not have the documentation at this time. The iServe IAPD H971 ? Shared cost center allocated $6,019,121 for the quarter ended June 30, 2022. We were unable to determine questioned costs as we were not able to determine which Federal and State program should receive an allocation, and the basis for how the costs would be allocated to these programs. Cause: Inadequate procedures to ensure that system reports were set up correctly, employees coded their time correctly, and allocations were adequately supported and calculated correctly. Effect: Without adequate documentation to support the allocation of costs, there is increased risk of programs not being charged the proper amounts. Recommendation: We recommend the Agency improve procedures to ensure that employee pay is recorded correctly in E1, system reports are set up correctly, and costs are properly allocated and charged. Management Response: The Agency agrees.
Program: AL 93.558 ? Temporary Assistance to Needy Families; AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.658 ? Foster Care Title IV-E ? Allowable Cost/Cost Principles Grant Number & Year: 1901NETANF, FFY 2019; 2101NEFOST, FFY 2021; 2201NEFOST, FFY 2022; 202121S251443, FFY 2021; 202222S251443, FFY 2022 Federal Grantor Agency: U.S. Department of Agriculture and U.S. Department of Health and Human Services Criteria: Per 45 CFR ? 75.303 (October 1, 2021): 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. 45 CFR ? 75.403 (October 1, 2021) requires costs to be reasonable, necessary, and adequately documented. 45 CFR ? 75.405(a) (October 1, 2021) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per 2 CFR ? 200.303 (January 1, 2022): The non-Federal entity must: (a) Establish and maintain effective internal control 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. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. 2 CFR ? 200.405(a) (January 1, 2022) states, in part, the following: A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Per the CAP, ?The RMTS Administrator is an employee of the Division of Children and Family Services and is responsible for . . . . verification that all forms are submitted to the Completed Surveys database, review of the worker entries to validate consistent practice among participants . . . .? Per the CAP, ?Each worker should be trained in the completion of the observation form and to the importance of providing accurate and timely responses.? According to RMTS Explanations: 1. Case Work ? Select this item if you were working on a specific case at the observation time. If you select this item you will be asked to enter the NFOCUS master case number. If there is not an NFOCUS master case, use any other number or description that can be used to identify the case . . . . According to the RMTS Instructions for the Worker: ?After the observation form has been submitted and validated (if selected for validation), it is reviewed by a member of the CFS and Cost Accounting Office for consistency.? According to the RMTS Instructions for the Supervisor: ?If you agree with the worker?s selections, you can click the ?VALIDATION? button. If you do not agree with the worker?s selections, you need to confer with the worker on the selection process and reach agreement on the proper selections for the form. Make updates as needed, and click the ?VALIDATION? button to attach the supervisor?s electronic signature and validate the form.? Good internal control and sound accounting practices require procedures to ensure that staff know how to complete accurate random moment time studies, which are used to allocate costs to Federal programs. Condition: The Agency did not have adequate procedures to ensure the accuracy of the RMTS. A similar finding was noted in the prior audit. Repeat Finding: 2021-033 Questioned Costs: $14,131 known See Schedule of Findings and Questioned Costs for chart/table. Statistical Sample: No Context: The RMTS is conducted on an ongoing basis to provide data for the allocation of direct and indirect costs to various programs. The objective is to identify employee efforts directly related to programs administered by the Agency. We tested 48 validated RMTS observations and noted that inadequate documentation was provided on 11 of them. We noted the following: ? For two of four Foster Care IV-E observations tested, the observations should have been reported as Foster Care Non IV-E per the documentation in the case files. For one of these observations, the case worker noted in the comments that she selected the wrong option. However, it was still validated without correction. ? For five of 21 SNAP observations tested, the RMTS observation form appeared to have been completed incorrectly by the case worker. For two of these observations, the case worker selected the SNAP program; however, per the case files, the case worker appeared to be working on other programs along with SNAP at the time of the observation or was not working on SNAP at all at the time of the observation. As we could not confirm from the documentation on file what the case worker was working on, the questioned costs are unknown. For the other three observations, the case workers did not document which cases they were working on. ? For four of 12 TANF observations tested, the RMTS observation forms appeared to have been completed incorrectly by the case workers. The case workers selected the TANF program; however, per the case files, the case workers appeared to be working on other programs along with TANF at the time of the observation, or, for one case, not working on TANF at all. As we could not confirm from the documentation on file what the case worker was working on, the questioned costs are unknown. Total known Federal payment errors, amount tested, error rate (amount of errors/ amount tested), total dollars charged via RMTS, and potential dollars at risk (dollar rate multiplied by the population total dollars charged) are summarized below by program: See Schedule of Findings and Questioned Costs for chart/table. The APA also inquired with Agency staff to determine if they were provided training in how to complete the random moment time studies. For one individual, the Agency was unable to provide documentation to support that the employee selected had completed RMTS training. Cause: The Agency?s training of staff and supervisory reviews of RMTS observations were not sufficient to ensure the observations were accurately completed. Effect: Random moment sampling is based on the laws of probability, which state, in essence, that there is a high probability that a relatively small number of random observations will yield an accurate depiction of the overall characteristics of the population for which the sample was taken. If RMTS observations are not accurate, there is an increased risk costs will be allocated incorrectly between programs. Recommendation: We recommend the Agency improve procedures to ensure that random moment observations are accurate and adequately reviewed. Management Response: The Agency agrees.
Program: Various, including AL 93.778 ? Medical Assistance Program ? Allowable Costs/Cost Principles Grant Number & Year: Various, including #2105NE5ADM, FFY 2021 Federal Grantor Agency: U.S. Department of Health and Human Services Criteria: 2 CFR ? 200.403 (January 1, 2022) and 45 CFR ? 75.403 (October 1, 2021) state, in relevant part, the following: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: * * * * (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. * * * * (g) Be adequately documented. 2 CFR ? 200.405(b) (January 1, 2022) and 45 CFR ? 75.405(b) (October 1, 2021) state, in relevant part, the following: All activities which benefit from the non-Federal entity?s indirect (F&A) cost, including unallowable activities and donated services by the non-Federal entity or third parties, will receive an appropriate allocation of indirect costs. 2 CFR ? 200.444(a) (January 1, 2022) and 45 CFR ? 75.444(a) (October 1, 2021) state, in relevant part, the following: For states, local governments, and Indian Tribes, the general costs of government are unallowable ?.Unallowable costs include: (1) Salaries and expenses of the Office of the Governor of a state . . . [.] (2) Salaries and other expenses of a state legislature . . . [.] 2 CFR ? 200, Appendix V, subsection (G)(2), (January 1, 2022) and 45 CFR ? 75, Appendix V, subsection (G)(2), (October 1, 2021) state the following: Internal service funds are dependent upon a reasonable level of working capital reserve to operate from one billing cycle to the next. Charges by an internal service activity to provide for the establishment and maintenance of a reasonable level of working capital reserve, in addition to the full recovery of costs, are allowable. A working capital reserve as part of retained earnings of up to 60 calendar days cash expenses for normal operating purposes is considered reasonable. A working capital reserve exceeding 60 calendar days may be approved by the cognizant agency for indirect costs in exceptional cases. 2 CFR ? 200, Appendix V, subsection (G)(4), (January 1, 2022) and 45 CFR ? 75, Appendix V, subsection (G)(4), (October 1, 2021) state, in relevant part, the following: Billing rates used to charge Federal awards must be based on the estimated costs of providing the services, including an estimate of the allocable central service costs. A comparison of the revenue generated by each billed service (including total revenues whether or not billed or collected) to the actual allowable costs of the service will be made at least annually and an adjustment will be made for the difference between the revenue and the allowable costs. These adjustments will be made through one of the following adjustment methods: (a) a cash refund including earned or imputed interest from the date of transfer and debt interest, if applicable, chargeable in accordance with applicable Federal cognizant agency for indirect costs regulations to the Federal Government for the Federal share of the adjustment, (b) credits to the amounts charged to the individual programs, (c) adjustments to future billing rates, or (d) adjustments to allocated central service costs. A good internal control plan requires: ? Procedures to ensure rate charges are equitable, reflect actual costs incurred, and are reviewed periodically to ensure such charges are appropriate for the services provided. ? Maintenance of adequate documentation to support both rates charged and the approval of those rates. ? Periodic review of internal service fund balances to ensure revenues are not in excess of expenses. ? Internal service rates that are published and available for State agency review and applied consistently for all State agencies. Condition: The Agency did not have adequate documentation to support the allocation of security costs in developing building rental rates. Additionally, the Agency?s Material Division did not maintain adequate documentation to support that charges were reasonable, equitable, and consistently applied. A similar finding was noted in prior audits since 2015. Lastly, the Accounting Internal Service Fund balance was greater than 60 calendar days for cash expenses for normal operations incurred. A similar finding was noted in the prior audit. Repeat Finding: 2021-024 Questioned Costs: Unknown Statistical Sample: No Context: We noted the following: Building Division The rental rate charged to agencies for building space includes an allocation for indirect costs for administration, grounds keeping, security, and energy management. We noted that neither the State Capitol nor the Governor?s residence were allocated any costs for security, even though there is security at both locations. Because these locations were not allocated any security costs, Federal programs could be overcharged. Additionally, security costs to the State Capitol and the Governor?s residence are general costs of government and, therefore, not allowable. The fiscal year 2022 indirect allocations for security totaled $884,797. Material Division We tested three Print Shop billings and noted the following: ? In prior audits, we noted that 24 Print Shop rates were based on calculations from fiscal year 2008, and 3 other Print Shop rates were based on calculations from fiscal year 2011. The Print Shop increased all the rates by 10% in fiscal year 2019, then increased the rates by an additional 5% in fiscal year 2020. In 2022, the rates were decreased by 5%. No support was provided to show that the current rates are reasonable. ? The Agency?s published markup price for special purchases, paper costs, plate material, special order supplies, and colored ink was 35%. The Agency did not have adequate documentation to support the reasonableness of the markup percentage rate. Receipts from sales of print shop services during the fiscal year ended June 30, 2022, totaled $2,835,540. Accounting Division Per the Agency?s calculation, as of June 30, 2021, the Accounting Services Internal Service Fund Balance for allowable costs was $4.528 million; however, the allowable reserve was only $1.007 million, a difference of $3.521 million, more than triple the allowable reserve. The Agency has not completed its calculation for June 30, 2022. The Auditor of Public Accounts (APA) estimate of the fund balance, per review of the accounting system, as of June 30, 2022, was $4.388 million, and the APA estimate of the allowable reserve was $1.007 million, a difference of $3.381 million. Therefore, the Agency appears to be charging too much for services. Cause: Inadequate procedures. Effect: When security costs are not allocated to all buildings in an equitable manner, Federal programs will not be charged in accordance with Federal cost principles. Additionally, without adequate controls and procedures to ensure rates are equitable and based on actual costs, there is an increased risk that Federal programs will be overcharged for services, and the Agency?s internal service funds will exceed the allowable threshold per Federal regulations. Recommendation: We recommend the Agency review its allocation of security costs to ensure that such costs are allocated in an equitable manner to all activities that benefit from the services. Additionally, we recommend the Agency maintain adequate documentation to support charges and ensure rates are equitable and reflect the actual costs incurred for services. Lastly, we recommend the Agency implement procedures to ensure fund balances do not exceed the allowable threshold. Management Response: The Building and Grounds security allocation is based on a management business decision. The Print Shop lacked the data needed to substantiate current rates at the individual service line level. In response to the prior year finding, the Print Shop purchased a Cost Rate Advisor license to support future rate setting methodology at the individual service line level. The Print Shop expects to finalize its analysis by July 2023. State Accounting Rates were reduced by $450,000 in fiscal year 2021, and from that level reduced another $132,000 in fiscal year?s 2022 and 2023 (current biennium). Further offsets of $700,000 are planned for each year of the coming biennium, and planned expenditures will exceed billed revenues by $1.7 million to bring the cash balance to within a 60-day operating level by June 2025.
Program: AL 20.509 ? Formula Grants for Rural Areas ? Allowability & Subrecipient Monitoring Grant Number & Year: NE-2019-013-00, FFY 2017 Federal Grantor Agency: U.S. Department of Transportation Criteria: Per 2 CFR ? 1201.1 (January 1, 2022), the U.S. Department of Transportation adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements set forth at Title 2 CFR part 200. 2 CFR ? 200.403 (January 1, 2022) requires costs to be reasonable, necessary, and adequately documented. A good internal control plan requires procedures to be in place to ensure compliance with Federal and State requirements. 2 CFR ? 200.332(d) (January 1, 2022) requires the pass-through entity to do the following: Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. 2 CFR ? 200.430(i)(1) (January 1, 2022) states the following, in relevant part: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; * * * * (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards . . . [.] Per 2 CFR ? 200.405(a) (January 1, 2022), ?A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.? Condition: The Agency lacked adequate documentation to support that payments were for allowable activities and in accordance with Federal cost principles. A similar finding was noted in the prior audit. Repeat Finding: 2021-065 Questioned Costs: $64,704 known Statistical Sample: No Context: We tested 25 payments to 22 subrecipients and three vendors. The Agency performed financial desk reviews for subrecipients; however, the reviews tested were not adequate. When desk reviews were not adequate, we provided the Agency with the opportunity to obtain additional support from the subrecipient; however, adequate support was not obtained. We noted the following: ? For nine subrecipients tested, documentation was not adequate to support that personnel charges were allowable and in accordance with Federal cost principles. The Agency did not have timesheets, time certifications, or other payroll documentation on file for all reimbursement requests. In some cases, payroll documentation was on file, but there was not adequate support to verify that the correct amount was charged to the program, as timesheets were not sufficient to identify time allocated to the program when the employee did not work entirely on the Federal program. In addition, for some subrecipients there was not sufficient documentation to support the benefits reimbursed. ? For one subrecipient tested, fuel costs and maintenance expenses were not adequately supported. The expenses were not supported by invoices. ? For seven subrecipients tested, capital and nonoperating costs were not adequately supported. The Agency did not obtain documentation to support the percentage of nonoperating expenditures allocated to the program. Subrecipients may share building space with other city or county offices and, therefore, may be charged a portion of the rent and utilities. While this is allowable, the Agency must obtain documentation to support that the percent allocated to the transit program is reasonable; however, such supporting documentation was not available. We also noted that one subrecipient was improperly reimbursed for sales taxes. The sample population totaled $15,537,764, which included $12,810,135 paid to 60 subrecipients and $2,727,629 vendor payments. Federal payment errors noted in the sample totaled $24,600. The total Federal sample tested was $353,695. Based on the sample tested, the dollar error rate was 6.96% ($24,600/$353,695), which estimates the potential dollars at risk for fiscal year 2022 to be $1,081,428 (dollar error rate multiplied by population). North Fork Area Transit During the course of our audit, we became aware of potential fraud related to the North Fork Area Transit (NFAT), a subrecipient of the Agency. On December 15, 2022, the Director of NFAT was suspended. A warrant was issued for his arrest the next day, alleging theft of up to $1 million between April and December 2022. From April 1, 2022, through June 30, 2022, the Program reimbursed NFAT a total of $582,587. As a result, we selected the April 2022 reimbursement paid to NFAT in June 2022, totaling $101,519, for additional testing. During that testing we identified $40,104 in questioned costs due to the following: ? For all four non-operating personnel (director and managers), documentation was inadequate to support that personnel charges were allowable and in accordance with Federal cost principles, as the timesheets identified only times in and out and did not specify what work the nonoperating employee was performing for the Federal grant. Questioned costs due to the lack of support for nonoperating personnel totaled $24,104. ? A $20,000 payment for vehicle insurance was reported; however, there was no documentation to support how the amount was determined or why it was reasonable. Furthermore, the $20,000 paid was inconsistent with past vehicle insurance payments. We observed a check in March 2022 for $600 with the description that it was for March bus insurance, and previous testing identified $600 bus insurance checks in August 2020 and August 2021. As a result, we question the Federal share of $16,000. ? We also noted inconsistencies in supporting documentation for operating personnel (drivers and dispatchers). Variances were noted between timesheet hours and the payroll register. Due to the NFAT concerns, the APA has now commenced a thorough review of this entire matter, which will be reported separately at a later date. Cause: Procedures were not adequate to ensure that costs were in accordance with Federal requirements. Effect: Increased risk for errors or misuse of funds. Recommendation: We recommend the Agency strengthen subrecipient monitoring procedures. We further recommend the Agency improve procedures to ensure expenditures are allowable and in accordance with Federal regulations. Management Response: The NDOT Local Assistance Division has increased transit staff by 1.5 FTEs for a total of 3.5 FTEs dedicated to reviewing monthly invoices. NDOT continues to engage and educate transit recipients. In late 2022, the North Fork Area Transit (NFAT) Board began an internal review process which revealed an inappropriate use of funds and authorities were notified. In December 2022, the NFAT Board engaged NDOT and requested assistance from the Mobility Management Team following the allegation. The Mobility Management Team is assisting the NFAT Board in managing operations, review of existing reporting and financial policies, and review and update of step-by-step checks and balances process. NDOT is financially supporting the Mobility Management Team in an effort to support and resume services at NFAT.
Program: AL 21.023 ? COVID-19 Emergency Rental Assistance ? Allowability & Earmarking Grant Number & Year: N/A Federal Grantor Agency: U.S. Department of the Treasury Criteria: Per 2 CFR ? 1000.10 (January 1, 2022), the U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements set forth at 2 CFR part 200. 2 CFR ? 200.403 (January 1, 2022) states, in relevant part, the following: 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. 2 CFR ? 200.404 (January 1, 2022) states the following: A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when the non-Federal entity is predominantly federally-funded. In determining reasonableness of a given cost, consideration must be given to: (a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award. (b) The restraints or requirements imposed by such factors as: sound business practices; arm?s-length bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of the Federal award. (c) Market prices for comparable goods or services for the geographic area. (d) Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal Government. (e) Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award?s cost. 2 CFR ? 200.459 (January 1, 2022) states, in relevant part, the following: (a) Costs of professional and consultant services rendered by persons who are members of a particular profession or possess a special skill, and who are not officers or employees of the non-Federal entity, are allowable, subject to paragraphs (b) and (c) of this section when reasonable in relation to the services rendered and when not contingent upon recovery of the costs from the Federal Government. . . . (b) In determining the allowability of costs in a particular case, no single factor or any special combination of factors is necessarily determinative. However, the following factors are relevant: (1) The nature and scope of the service rendered in relation to the service required. * * * * (6) Whether the service can be performed more economically by direct employment rather than contracting. (7) The qualifications of the individual or concern rendering the service and the customary fees charged, especially on non-federally funded activities. (8) Adequacy of the contractual agreement for the service (e.g., description of the service, estimate of time required, rate of compensation, and termination provisions). Division N ? Additional Coronavirus Response and Relief, Title V ? Banking, Section 501(c)(2)(A) of the Consolidated Appropriations Act, 2021, states, in relevant part: Not less than 90 percent of the funds received by an eligible grantee from a payment made under this section shall be used to provide financial assistance to eligible households . . . . Division N ? Additional Coronavirus Response and Relief, Title V ? Banking, Section 501(c)(3) of the Consolidated Appropriations Act, 2021, states, in relevant part: Not more than 10 percent of funds received by an eligible grantee from a payment made under this section may be used to provide eligible households with case management and other services related to the novel coronavirus disease (COVID-19) outbreak, as defined by the Secretary, intended to help keep households stably housed. Division N ? Additional Coronavirus Response and Relief, Title V ? Banking, Section 501(c)(5)(A) of the Consolidated Appropriations Act, 2021, states, in relevant part: Not more than 10 percent of the amount paid to an eligible grantee under this section may be used for administrative costs attributable to providing financial assistance and housing stability services under paragraphs (2) and (3), respectively, including for data collection and reporting requirements related to such funds. Per the amended Emergency Rental Assistance terms, dated March 26, 2021, ?The total of all administrative costs, whether direct or indirect costs, may not exceed 10 percent of the total amount of the total award.? The Reallocation Guidance from the U.S. Department of the Treasury (Treasury), dated March 30, 2022, states the following: A Grantee may spend up to 10% of its initial ERA1 allocation for administrative expenses only if the Grantee obligates at least 30% of its initial allocation for the provision of financial assistance and housing stability services on behalf of eligible households by September 30, 2022. If a Grantee has obligated less than 30% of its initial allocation providing financial assistance and housing stability services as of September 30, 2022, Treasury will presume that the Grantee?s administrative expenses were not attributable to such services ? and therefore were not permissible uses of ERA1 funds ? to the extent that the administrative expenses exceed 10% of the Grantee?s allocation after deducting amounts recaptured or reallocated as excess funds, unless the Grantee can demonstrate that those costs are related to the delivery of the program. Condition: The contractual agreement to receive and evaluate applications for Emergency Rental Assistance (ERA) did not have adequate limitations or provisions to ensure costs were reasonable. A similar finding was noted in the prior audit. Repeat Finding: 2021-063 Questioned Costs: $3,580,007 known Statistical Sample: No Context: The State of Nebraska was initially awarded $158,572,581 for ERA to assist eligible households that have difficulty making timely payments of rent and utilities due to the COVID-19 pandemic. At least 90% of funds are to be earmarked for financial aid to eligible households. Not more than 10% of funds may be used for administrative costs. The Agency entered into a contract with Deloitte & Touche LLP (Deloitte) to provide program administration and case management. Eligibility determinations were made by Deloitte and then sent to the State for review and to process the aid payments to eligible recipients. Deloitte was paid $8,672,561 during the fiscal year ended June 30, 2022. We tested one payment for $531,314 and noted the following: ? Adequate support was not on file to allow for a determination as to whether the contracted amount was reasonable. There were no maximums or limitations other than the $14,627,160 cap specified in the contract. The contract was paid on an hourly rate and did not have any stipulations regarding the number of hours paid per application or performance measures to be achieved. ? Per guidance from Treasury, if the State obligates less than 30% of its initial allocation providing financial aid by September 30, 2022, Treasury will presume that the State?s administrative expenses were not attributable to the program, at least to the extent that the administrative expenses exceed 10% of the Grantee?s allocation after deducting amounts recaptured or reallocated as excess funds. The State voluntarily reallocated $84,700,000 to local governments and was required to return an additional $11,716,548 for reallocation. Therefore, State administrative expenses would be limited to $6,215,603 (10% of awarded amount less reallocations). Administrative expenses in fiscal year 2021 and 2022 totaled $9,795,610. As a result, we question costs of $3,580,007 for administrative costs exceeding 10%. As of January 17, 2023, the Agency has spent $26,399,517 on financial aid, and $13,080,572 for administrative expenses, of which $12,563,227 was paid to Deloitte. This is 33.13% of the total amount paid as of January 17, 2023. Without spending 30% of its award on financial aid, the Agency will not meet the earmarking requirements per the guidance released from Treasury. Based on the amount of financial aid spent, the administrative costs appear unreasonable. Cause: The contract was not competitively bid, and contract provisions were not specific enough to ensure that amounts paid were reasonable. The Agency lacked adequate procedures to ensure adherence to earmarking requirements. Effect: Without such adequate procedures, there is an increased risk for misuse of Federal funds. The Agency did not meet earmarking requirements. Recommendation: We recommend the Agency improve its procedures for ensuring the reasonableness of contractual service payments. Management Response: The Military Department does not agree with this finding. Vendor Contract: The State performed procurement procedures soliciting Requests for Information from vendors in 2020 to support COVID-19 related tasks. A contractual agreement was completed with the vendor once the State determined the program costs, estimated level-of-effort, and key assumptions were reasonable based on the scope of services the State requested. In addition, the state complied with the procurement standards set forth in 2 CFR 200.317-200.327, including expected contract provisions, key program assumptions, and not-to-exceed thresholds. The contractual agreement was completed to enable the State to proactively monitor vendor performance and analyze detailed information on associated cost. Vendor performance was monitored through twice-weekly status meetings, bi-weekly executive status briefings with executives across multiple agencies, bi-weekly Executive Steering Committee meetings, and review of detailed invoices. The State as the Grantee is able to demonstrate that the administrative costs are related to the delivery of the program in a timely fashion and is aligned with US Treasury Guidance. APA Response: As of January 17, 2023, the Agency has spent $1 in administration costs for every $2 spent for aid. This does not appear reasonable and is not in accordance with earmarking requirements. Thus, in addition to the questioned administrative costs identified for 2022, the agency appears to be on track for incurring millions of dollars more in such questioned costs for 2023.
Program: AL 21.023 ? COVID-19 Emergency Rental Assistance ? Allowability & Eligibility Grant Number & Year: N/A Federal Grantor Agency: U.S. Department of the Treasury Criteria: Per 2 CFR ? 1000.10 (January 1, 2022), the U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements set forth at 2 CFR part 200. 2 CFR ? 200.303 (January 1, 2022) states, in relevant part, the following: 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. . . . Good internal controls require risk assessments to be performed, and procedures to verify the validity of applicants prior to payment. 2 CFR ? 200.403 (January 1, 2022) 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. * * * * (g) Be adequately documented. The Nebraska ERA Program FAQ states, ?Who is eligible? You are eligible if you answer YES to ALL of the following: . . .Your landlord is not an immediate family member.? Division N ? Additional Coronavirus Response and Relief, Title V ? Banking, Section 501(k)(3)(A) of the Consolidated Appropriations Act, 2021, states that an eligible household is a household of one or more individuals that is obligated to pay rent on a residential dwelling. Good internal controls require procedures to verify the validity of applicants prior to payment. Condition: Procedures were not adequate to ensure that payments were allowable, and individuals were eligible for assistance. A similar finding was noted in the prior audit. Repeat Finding: 2021-064 Questioned Costs: $76,050 known Statistical Sample: No Context: During testing of 40 aid payments, we noted one payment, totaling $1,350, made to an applicant whose landlord was an immediate relative. The total sample tested was $87,526, and total assistance payments for the fiscal year were $17,456,087. The dollar error rate for the sample was 1.54% ($1,350/$87,526), which estimates the potential dollars at risk for fiscal year 2022 to be $268,824 (dollar rate multiplied by the population.) In the prior and current audit, we noted that the Agency identified likely fraudulent payments. As of January 9, 2023, the Agency had identified $155,360 and $822,188 of likely fraudulent payments in fiscal years ended June 30, 2021, and June 30, 2022, respectively. We reviewed five of these payments, totaling $74,700, in fiscal year 2022. For all five payments, we noted indicators of possible fraud, as information on the application provided was inconsistent with the information from other databases or systems. Examples of such indicators include the following: 1) the owner of the property per the County Assessors website not agreeing to the owner listed on the application; 2) generic and editable supporting documentation; and 3) tenants and landlords having out-of-state identification and telephone numbers. According to the Agency, these payments have been referred to the State Patrol for further investigation. Cause: The Agency had various procedures for ensuring that application information was accurate; however, verifying the property owner to County Assessor information was not required. Effect: There is an increased risk for fraudulent payments. Once fraudulent payments have been made, the likelihood of recouping them is low. Recommendation: We recommend the Agency improve its procedures for verifying the validity of applicants prior to payments. We further recommend the Agency continue to work with law enforcement to recoup improper payments. Management Response: The Military Department does not agree with this finding. The State has implemented a strong system of internal controls to determine program eligibility. These controls include detailed pre-payment and post-payment analytics to help identify applications at risk for fraud. As the ERA program progressed in Nebraska and nationally, program procedures continued to be enhanced to monitor for and prevent potentially fraudulent applications. During its life the program provided proactive fraud detection for over 56,000 tenant and landlord applications and prevented approximately $23M of funding from being paid out erroneously. Additionally, the State turns over any paid applications that have been subsequently determined at risk of being fraudulent to the State Patrol for further investigation and potential prosecution. APA Response: In addition to the one of 40 payments tested with errors, five payments we reviewed noted possible indications of fraud. Once fraudulent payments have been made, the likelihood of recouping them is low. 2 CFR ? 200.516 (January 1, 2022) requires reporting known or likely fraud affecting a Federal award.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
2022 ? 004: Allowable Costs/Costs Principles Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster (IDEA) Assistance Listing Numbers: 84.027/84.173 Federal Award Identification Number and Year: H027A180084 - FY2019, FY2020, FY2021; H173A190104 - FY2019, FY2020, FY2021 Pass-Through Agency: Indiana Department of Education Pass-Through Number(s): H027A180084; H173A190104 Award Period: FY2019, FY2020, FY2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR 200.303 states in part: "The non-Federal entity must: 1. 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: 1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2. 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. . . ." Condition: During the process of obtaining an understanding of internal controls and processing of payroll expenditures and testing payroll expenditures, we noted that the School Corporation failed to maintain documentation in accordance with the time and effort requirements. Questioned costs: The noted exceptions in the context of this finding had $90 of known payroll costs charged to the Program. Context: We selected sixty transactions for payroll disbursement testing. We noted that wages charged to the program for two of the sixty items tested did not include time and effort documentation for payroll expense charged to the grants. Cause: Salary figures were charged to the federal grant that did not have time and effort documentation for amount charged. Effect: The organization has not fully followed compliance attributes with the allowable costs principles set forth by the Compliance Supplement related to allocation of salaries being charged based on approved time worked for a program and other expenses being adequately documented to support the details of the expense charged to the grant. Personnel need to reinforce policies to ensure control procedures are in place to ensure salaries charged to a grant are appropriately based on approved time worked in a program and expenses charged to the grant are adequately supported. Repeat Finding: No Recommendation: We recommend the organization charge compensation for personnel services to the federal grant based on approved hours worked in the program. Views of responsible officials: There is no disagreement with the audit finding.
Federal agency: Department of Education Federal program title: 21st Century Community Learning Centers CFDA Number 84.287 Award Period: 7/1/2021-6/30/2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements (the Uniform Guidance), section 200.403(g), requires that charges to Federal awards must be adequately documented. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: From a sample of forty general expenditures allocated to the program during the year, five selections lacked documentation of approval. Context: A sample of forty charges allocated to the program, totaling $7,078, were selected for audit from a population of general expenditures allocated to the program totaling $303,054. There were 5 charges that lacked sufficient documentation of review and approval per the Center?s policies. Questioned Costs: Known questioned costs total $951. Cause: Riverside Educational Center requires that supporting documentation be retained for expenditures allocated to federal funding sources, including approval of receipts and invoices. However, five of the incurred expenses on credit cards issued by the Center for procuring program supplies did not have proper approval for the charges on receipts. Effect: When adequate documentation is not retained and used to support the amount charged to the federal program, there is a risk that unsupported or inaccurate costs are being charged to the federal program. Recommendation: Proper control activities should be implemented to allow for a consistent, accurate, and allowable method to support distribution of general expenditures to federal programs. The Center should develop a means to adequately track approvals for expenditures. View of responsible officials: Management is in agreement
2 CFR ? 3474.1 give regulatory effect to the U.S. Department of Education for 2 CFR ? 200.403, which requires, except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards. For fiscal year 2022, three of the forty tested expenditures paid out of the Elementary and Secondary School Emergency Relief (ESSER) Fund totaling $15,360 were determined to not be allowable based on the ESSER grant's guidelines. The noncompliance was due to the District improperly adjusting various athletics-related expenditures to the ESSER Fund based on a misinterpretation of ESSER grant guidance provided by the Ohio Department of Education. The District should implement additional control procedures to help ensure expenditures charged to the Elementary and Secondary School Emergency Relief (ESSER) Fund follow the guidelines for the grant program.
2 CFR ? 3474.1 give regulatory effect to the U.S. Department of Education for 2 CFR ? 200.403, which requires, except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards. For fiscal year 2022, three of the forty tested expenditures paid out of the Elementary and Secondary School Emergency Relief (ESSER) Fund totaling $15,360 were determined to not be allowable based on the ESSER grant's guidelines. The noncompliance was due to the District improperly adjusting various athletics-related expenditures to the ESSER Fund based on a misinterpretation of ESSER grant guidance provided by the Ohio Department of Education. The District should implement additional control procedures to help ensure expenditures charged to the Elementary and Secondary School Emergency Relief (ESSER) Fund follow the guidelines for the grant program.
2 CFR ? 3474.1 give regulatory effect to the U.S. Department of Education for 2 CFR ? 200.403, which requires, except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards. For fiscal year 2022, three of the forty tested expenditures paid out of the Elementary and Secondary School Emergency Relief (ESSER) Fund totaling $15,360 were determined to not be allowable based on the ESSER grant's guidelines. The noncompliance was due to the District improperly adjusting various athletics-related expenditures to the ESSER Fund based on a misinterpretation of ESSER grant guidance provided by the Ohio Department of Education. The District should implement additional control procedures to help ensure expenditures charged to the Elementary and Secondary School Emergency Relief (ESSER) Fund follow the guidelines for the grant program.
2 CFR ? 3474.1 give regulatory effect to the U.S. Department of Education for 2 CFR ? 200.403, which requires, except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards. For fiscal year 2022, three of the forty tested expenditures paid out of the Elementary and Secondary School Emergency Relief (ESSER) Fund totaling $15,360 were determined to not be allowable based on the ESSER grant's guidelines. The noncompliance was due to the District improperly adjusting various athletics-related expenditures to the ESSER Fund based on a misinterpretation of ESSER grant guidance provided by the Ohio Department of Education. The District should implement additional control procedures to help ensure expenditures charged to the Elementary and Secondary School Emergency Relief (ESSER) Fund follow the guidelines for the grant program.
Assistance Listing Number, Federal Agency, and Program Name - 84.425U, Department of Education, COVID-19 - Elementary and Secondary School Emergency Relief Fund Federal Award Identification Number and Year - S425D210041; 2022 Pass through Entity - Chicago Public Schools Finding Type - Significant deficiency Repeat Finding - No Criteria - All nonfederal entities must follow generally accepted accounting principles (GAAP) when recording federal revenue and expenses (2 CFR 200.403 (e)) Condition - Controls in place did not identify a portion of expenditures, related to summer school stipends, incurred in fiscal year 2023 that were applied to the federal award in fiscal year 2022. Questioned Costs - $22,096 Identification of How Questioned Costs Were Computed - The questioned costs represent total federal expenditures incurred in fiscal year 2023 that are included on the accompanying schedule of expenditures of federal awards. Context - A total of $34,525 was recorded as federal expenditures related to summer school stipends paid in June and July 2022. 16 of the 25 days in the summer school term took place during fiscal year 2023. As such, only 9/25 of these expenditures should be reflected on the accompanying schedule of expenditures of federal awards. Cause and Effect - While the School had procedures in place to review for allowable costs, management's review did not prevent management from recording $22,096 more of expenditures of federal awards during fiscal year 2022 than what was incurred. Recommendation - We recommend the School review its procedures and controls to ensure costs are incurred in the same period as they are applied to federal awards. Views of Responsible Officials and Corrective Action Plan - The error was the result of a misunderstanding with the pass through entity regarding the reimbursement process. Going forward, a review will be performed to ensure federal revenue is recorded in the same period as the corresponding expense.
2022-001: Internal Control Over Grant Reporting Federal Grantor: U.S. Department of Labor Pass-Through Grantor: Central Workforce Development Board Federal Assistance Listing Number: 17.258, 17.259, 17.278 Program Title: WIOA Cluster Pass-through Entity Identifying Number: 10-09-09-20C, 10-09-09-21C Award Year: 2020 and 2021 Questioned Costs: $34,867 Criteria: 2 CFR 200.303 states that non-federal entities must ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.403 states that ?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?(e) Be determined in accordance with generally accepted accounting principles (GAAP)?(g) Be adequately documented.? Condition: The organization does not have adequate procedures in place to reconcile costs claimed for reimbursement on reports submitted to the grantor with actual costs incurred by the organization. The organization maintains monthly Payment Trackers which record the payment of non-staff payroll related costs and are submitted to the Central Workforce Development Board (CWDB) for reimbursement on a weekly basis. The organization also maintains monthly Staff Billing Worksheets and CPR reports which report staff payroll and benefit costs and are submitted to the (CWDB) for reimbursement on a monthly basis. These reports are kept outside of the general ledger accounting system, which is maintained on the cash basis and is reconciled to the bank statements on a monthly basis. However, there is no process in place to reconcile these spreadsheets to the general ledger to ensure the accuracy of the reports and the costs being claimed for reimbursement. During our audit, we noted the following discrepancies between the spreadsheets and the general ledger: ? The organization charged $45,738 of accrued vacation costs through reporting on the monthly staff billing worksheets. However, when staff use their accrued vacation, these costs are reported as part of the salary expenses on the staff billing worksheets, so accrued vacation expenses are reported when they are earned and when they are used. ? The organization charged $173 of expenses for participant work experience workers compensation insurance on the Payment Trackers. However, the Payment Trackers also reported the workers compensation insurance policy premiums when paid. The policy covers work experience participants. ? The organization did not reduce health insurance premiums reported on the monthly staff billing worksheets for $9,433 of employee withholdings for the employee portion of health insurance. ? The organization charged $2,655 of costs on the monthly Payment Trackers for three checks that were subsequently voided in the general ledger but no adjustment was made on the Trackers to remove the costs. ? In addition to the above costs which were charged to the grant in error, there were $23,132 of allowable costs incurred by the organization noted in the general ledger that were not reported on either the Payment Trackers or staff billing worksheets for reimbursement. Cause: The spreadsheets which are submitted to the CWDB for reimbursement do not use a double entry general ledger accounting system as their basis, and there is not a sufficient process in place to reconcile the spreadsheets to the general ledger to ensure the completeness and accuracy of grant expenditures being reported for reimbursement. Effect: The lack of a sufficient process for reconciling the spreadsheets to the general ledger resulted in several discrepancies between the amounts of grant expenditures reported and costs actually incurred by the organization. Recommendation: We recommend that the organization implement procedures to reconcile the grant reporting spreadsheets and the general ledger from the accounting system to ensure that the expenditures being reported to the grantor are complete and accurate.
2022-001: Internal Control Over Grant Reporting Federal Grantor: U.S. Department of Labor Pass-Through Grantor: Central Workforce Development Board Federal Assistance Listing Number: 17.258, 17.259, 17.278 Program Title: WIOA Cluster Pass-through Entity Identifying Number: 10-09-09-20C, 10-09-09-21C Award Year: 2020 and 2021 Questioned Costs: $34,867 Criteria: 2 CFR 200.303 states that non-federal entities must ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.403 states that ?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?(e) Be determined in accordance with generally accepted accounting principles (GAAP)?(g) Be adequately documented.? Condition: The organization does not have adequate procedures in place to reconcile costs claimed for reimbursement on reports submitted to the grantor with actual costs incurred by the organization. The organization maintains monthly Payment Trackers which record the payment of non-staff payroll related costs and are submitted to the Central Workforce Development Board (CWDB) for reimbursement on a weekly basis. The organization also maintains monthly Staff Billing Worksheets and CPR reports which report staff payroll and benefit costs and are submitted to the (CWDB) for reimbursement on a monthly basis. These reports are kept outside of the general ledger accounting system, which is maintained on the cash basis and is reconciled to the bank statements on a monthly basis. However, there is no process in place to reconcile these spreadsheets to the general ledger to ensure the accuracy of the reports and the costs being claimed for reimbursement. During our audit, we noted the following discrepancies between the spreadsheets and the general ledger: ? The organization charged $45,738 of accrued vacation costs through reporting on the monthly staff billing worksheets. However, when staff use their accrued vacation, these costs are reported as part of the salary expenses on the staff billing worksheets, so accrued vacation expenses are reported when they are earned and when they are used. ? The organization charged $173 of expenses for participant work experience workers compensation insurance on the Payment Trackers. However, the Payment Trackers also reported the workers compensation insurance policy premiums when paid. The policy covers work experience participants. ? The organization did not reduce health insurance premiums reported on the monthly staff billing worksheets for $9,433 of employee withholdings for the employee portion of health insurance. ? The organization charged $2,655 of costs on the monthly Payment Trackers for three checks that were subsequently voided in the general ledger but no adjustment was made on the Trackers to remove the costs. ? In addition to the above costs which were charged to the grant in error, there were $23,132 of allowable costs incurred by the organization noted in the general ledger that were not reported on either the Payment Trackers or staff billing worksheets for reimbursement. Cause: The spreadsheets which are submitted to the CWDB for reimbursement do not use a double entry general ledger accounting system as their basis, and there is not a sufficient process in place to reconcile the spreadsheets to the general ledger to ensure the completeness and accuracy of grant expenditures being reported for reimbursement. Effect: The lack of a sufficient process for reconciling the spreadsheets to the general ledger resulted in several discrepancies between the amounts of grant expenditures reported and costs actually incurred by the organization. Recommendation: We recommend that the organization implement procedures to reconcile the grant reporting spreadsheets and the general ledger from the accounting system to ensure that the expenditures being reported to the grantor are complete and accurate.
2022-001: Internal Control Over Grant Reporting Federal Grantor: U.S. Department of Labor Pass-Through Grantor: Central Workforce Development Board Federal Assistance Listing Number: 17.258, 17.259, 17.278 Program Title: WIOA Cluster Pass-through Entity Identifying Number: 10-09-09-20C, 10-09-09-21C Award Year: 2020 and 2021 Questioned Costs: $34,867 Criteria: 2 CFR 200.303 states that non-federal entities must ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.403 states that ?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?(e) Be determined in accordance with generally accepted accounting principles (GAAP)?(g) Be adequately documented.? Condition: The organization does not have adequate procedures in place to reconcile costs claimed for reimbursement on reports submitted to the grantor with actual costs incurred by the organization. The organization maintains monthly Payment Trackers which record the payment of non-staff payroll related costs and are submitted to the Central Workforce Development Board (CWDB) for reimbursement on a weekly basis. The organization also maintains monthly Staff Billing Worksheets and CPR reports which report staff payroll and benefit costs and are submitted to the (CWDB) for reimbursement on a monthly basis. These reports are kept outside of the general ledger accounting system, which is maintained on the cash basis and is reconciled to the bank statements on a monthly basis. However, there is no process in place to reconcile these spreadsheets to the general ledger to ensure the accuracy of the reports and the costs being claimed for reimbursement. During our audit, we noted the following discrepancies between the spreadsheets and the general ledger: ? The organization charged $45,738 of accrued vacation costs through reporting on the monthly staff billing worksheets. However, when staff use their accrued vacation, these costs are reported as part of the salary expenses on the staff billing worksheets, so accrued vacation expenses are reported when they are earned and when they are used. ? The organization charged $173 of expenses for participant work experience workers compensation insurance on the Payment Trackers. However, the Payment Trackers also reported the workers compensation insurance policy premiums when paid. The policy covers work experience participants. ? The organization did not reduce health insurance premiums reported on the monthly staff billing worksheets for $9,433 of employee withholdings for the employee portion of health insurance. ? The organization charged $2,655 of costs on the monthly Payment Trackers for three checks that were subsequently voided in the general ledger but no adjustment was made on the Trackers to remove the costs. ? In addition to the above costs which were charged to the grant in error, there were $23,132 of allowable costs incurred by the organization noted in the general ledger that were not reported on either the Payment Trackers or staff billing worksheets for reimbursement. Cause: The spreadsheets which are submitted to the CWDB for reimbursement do not use a double entry general ledger accounting system as their basis, and there is not a sufficient process in place to reconcile the spreadsheets to the general ledger to ensure the completeness and accuracy of grant expenditures being reported for reimbursement. Effect: The lack of a sufficient process for reconciling the spreadsheets to the general ledger resulted in several discrepancies between the amounts of grant expenditures reported and costs actually incurred by the organization. Recommendation: We recommend that the organization implement procedures to reconcile the grant reporting spreadsheets and the general ledger from the accounting system to ensure that the expenditures being reported to the grantor are complete and accurate.
2022-001: Internal Control Over Grant Reporting Federal Grantor: U.S. Department of Labor Pass-Through Grantor: Central Workforce Development Board Federal Assistance Listing Number: 17.258, 17.259, 17.278 Program Title: WIOA Cluster Pass-through Entity Identifying Number: 10-09-09-20C, 10-09-09-21C Award Year: 2020 and 2021 Questioned Costs: $34,867 Criteria: 2 CFR 200.303 states that non-federal entities must ?Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.403 states that ?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?(e) Be determined in accordance with generally accepted accounting principles (GAAP)?(g) Be adequately documented.? Condition: The organization does not have adequate procedures in place to reconcile costs claimed for reimbursement on reports submitted to the grantor with actual costs incurred by the organization. The organization maintains monthly Payment Trackers which record the payment of non-staff payroll related costs and are submitted to the Central Workforce Development Board (CWDB) for reimbursement on a weekly basis. The organization also maintains monthly Staff Billing Worksheets and CPR reports which report staff payroll and benefit costs and are submitted to the (CWDB) for reimbursement on a monthly basis. These reports are kept outside of the general ledger accounting system, which is maintained on the cash basis and is reconciled to the bank statements on a monthly basis. However, there is no process in place to reconcile these spreadsheets to the general ledger to ensure the accuracy of the reports and the costs being claimed for reimbursement. During our audit, we noted the following discrepancies between the spreadsheets and the general ledger: ? The organization charged $45,738 of accrued vacation costs through reporting on the monthly staff billing worksheets. However, when staff use their accrued vacation, these costs are reported as part of the salary expenses on the staff billing worksheets, so accrued vacation expenses are reported when they are earned and when they are used. ? The organization charged $173 of expenses for participant work experience workers compensation insurance on the Payment Trackers. However, the Payment Trackers also reported the workers compensation insurance policy premiums when paid. The policy covers work experience participants. ? The organization did not reduce health insurance premiums reported on the monthly staff billing worksheets for $9,433 of employee withholdings for the employee portion of health insurance. ? The organization charged $2,655 of costs on the monthly Payment Trackers for three checks that were subsequently voided in the general ledger but no adjustment was made on the Trackers to remove the costs. ? In addition to the above costs which were charged to the grant in error, there were $23,132 of allowable costs incurred by the organization noted in the general ledger that were not reported on either the Payment Trackers or staff billing worksheets for reimbursement. Cause: The spreadsheets which are submitted to the CWDB for reimbursement do not use a double entry general ledger accounting system as their basis, and there is not a sufficient process in place to reconcile the spreadsheets to the general ledger to ensure the completeness and accuracy of grant expenditures being reported for reimbursement. Effect: The lack of a sufficient process for reconciling the spreadsheets to the general ledger resulted in several discrepancies between the amounts of grant expenditures reported and costs actually incurred by the organization. Recommendation: We recommend that the organization implement procedures to reconcile the grant reporting spreadsheets and the general ledger from the accounting system to ensure that the expenditures being reported to the grantor are complete and accurate.