Finding Text
Assistance Listing, Federal Agency, and Program Name - 84.425U - COVID-19 ESSER Formula Fund III Grants to Local Education Agencies
Federal Award Identification Number and Year - 213713
Pass-through Entity - Michigan Department of Education
Finding Type - Significant deficiency and material noncompliance with laws and regulations
Repeat Finding - No
Criteria - The Academy applies the simplified method to determine indirect costs for the ESSER program. The allocation of indirect costs and the computation of an indirect cost rate may be accomplished through simplified allocation procedures described in 2 CFR Part 200, Appendix VII, paragraph C.2. The indirect cost rate is approved by the Michigan Department of Education.
Condition - The Academy did not accurately apply the approved indirect cost rate for the program at the time drawdown requests were submitted creating a cash management issue involving unallowable cost reimbursements.
Questioned Costs - $60,672
Identification of How Questioned Costs Were Computed - Not Applicable
Context - Proper segregation of duties and review functions are critical key internal control functions to detect errors prior to requesting a grant reimbursement. The indirect cost allocation for the ESSER program included an error in the indirect cost rate applied causing draw downs on unallowable costs. Management identified the error after the draw occurred and reduced the indirect costs charged to the ESSER program by $60,672 prior to year end to correct the error. A deferred revenue balance is reported for the program at June 30, 2024. This deferred balance is attributed to the excess reimbursement request and reduction of indirect costs for the accurate rate after the drawdown was completed.
Cause and Effect - The Academy calculated indirect costs using an inaccurate rate, then submitted and received reimbursement requests for overstated indirect costs.
Recommendation - We recommend that prior to drawdowns occurring, a review of the indirect cost calculations occur to detect errors in the indirect cost rates applied to prevent noncompliance in cash management.
Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding and is in the process of enhancing procedures to prevent overdrawn amounts in the future.