Finding Text
Finding No.: 2023-009
Federal Agency: U.S. Department of Education
AL Program: 84.027 Special Education Grants to States
Area: Period of Performance
Questioned Costs: $80,983
Criteria:
In accordance with applicable period of performance (POP) requirements, a non-federal entity may
charge only allowable costs incurred during a federal award’s period of performance. Unless the
federal awarding agency authorizes an extension, a non-federal entity must liquidate all financial
obligations incurred under the federal award not later than 120 calendar days after the end date of
the period of performance as specified in the terms and conditions of the federal award or in the
approved extension.
Condition:
1. GDOE charged costs to a federal award before the period of performance started and after
the period of performance ended, as follows:
No questioned cost is presented for the FY 2024 payroll costs because GDOE subsequently
recorded journal entries between August 2024 and October 2024 to transfer such costs
appropriately to grant year 2022.
2. GDOE liquidated obligations of a federal award after the approved liquidation end date, as
follows:
Finding No.: 2023-009, continued
Federal Agency: U.S. Department of Education
AL Program: 84.027 Special Education Grants to States
Area: Period of Performance
Questioned Costs: $80,983
Cause:
GDOE did not enforce monitoring controls over compliance with applicable period of performance
requirements.
Effect:
GDOE is in noncompliance with applicable period of performance requirements. The reportable
questioned cost is $80,983.
Identified as a Repeat Finding: 2022-004
Recommendation:
Responsible personnel should enforce monitoring controls over compliance with applicable period
of performance requirements. Prior to charging costs to a federal award or liquidating obligations
incurred under a federal award, responsible personnel should verify that the period of performance,
including the liquidation end date, has not expired.
Views of Responsible Officials:
GDOE agrees with Condition 1 questioned costs of $560. The questioned charges are related to
TPFA purchase orders issued in fiscal year 2019, which falls outside of the period of performance.
The expenditure for the 2019 purchase order was transferred from the TPFA Munis and recorded
in the incorrect GDOE Munis account.
GDOE disagrees with Condition 2 questioned costs of $18,041. In line with federal regulations,
GDOE paid (liquidated) the obligations in question on January 4 and 26, 2024, which is before the
liquidation end date of January 28, 2024. E&Y auditors are citing GDOE for the issued checks
clearing the bank after the liquidation end date, however, liquidation occurs when the recipient
draws funds from the grants management system and pays obligations and not specifically when
checks clear the bank.
Finding No.: 2023-009, continued
Federal Agency: U.S. Department of Education
AL Program: 84.027 Special Education Grants to States
Area: Period of Performance
Questioned Costs: $80,983
Views of Responsible Officials, continued:
GDOE agrees with Condition 2 $62,382 questioned costs. While GDOE Munis system has
recorded expenses of $62,382 related to Special Education (SPED) obligations, funds were not
drawn for these expenditures. In GDOE’s federal review process, drawdowns are reviewed in
alignment with specific conditions for allowability and in compliance with period of performance
timelines. The identified funds were not expended from SPED grants. To correct this reporting
deficiency, GDOE will record journal entries to transfer the expenditures to appropriate funding
sources.
Similarly, GDOE improperly charged $3.1 million in payroll expenditures to SPED grants after
the period of performance. Subsequently, GDOE corrected this finding by making the appropriate
journal entries to transfer the improperly charged payroll expenditure to the appropriate grant year.
Plan of action and completion date:
The GDOE will perform a monthly review of all transactions to ensure charges are recorded in the
appropriate grant year. Additionally, Grant Project Managers and Program Coordinators will
timely communicate to the Human Resources and Business Office any changes to accounts
charged for federally funded payroll expenditures. The IAO now provides an independent review
of drawdown requests – a control that will help prevent liquidation after applicable period of
performance.
Plan to monitor and responsible officials:
Financial Affairs under the leadership of the Deputy of Finance and Administrative Services,
Morgan W. Paul, and the GDOE Comptroller (vacant), will ensure an accountant is monitoring
the expenditures of federal grants and the corresponding periods of performance and liquidation
periods. Grant Project Managers and Federal Compliance review team will also provide timely
communication for changes in grant year funding to HR relative to federal payroll.
Auditor Response:
Condition 1: The purchase order in 2019 constitutes an obligation prior to the period of
performance start date of 07/01/2020 for Grant Year 2020.
Condition 2: We acknowledge that the checks are dated prior to the liquidation end date;
however, program determination letters from U.S. ED from prior years have sustained audit
findings wherein auditors cited the check clearing date as the liquidation date.