Finding Text
Finding No.: 2023-011
Federal Agency: U.S. Department of Education
AL Program: 84.403 Consolidated Grant to the Outlying Areas
Area: Period of Performance
Questioned Costs: $11,004
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 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:
Cause:
GDOE did not enforce monitoring controls over compliance with applicable period of performance
requirements.
Finding No.: 2023-011, continued
Federal Agency: U.S. Department of Education
AL Program: 84.403 Consolidated Grant to the Outlying Areas
Area: Period of Performance
Questioned Costs: $11,004
Effect:
GDOE is in noncompliance with applicable period of performance requirements. The reportable
questioned cost is $11,004.
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 disagrees with condition 1 related to FY 2024 purchase orders (PO). GDOE PO 20240171
is a copy over of the third-party fiduciary agent (TPFA) PO 20230010 which was issued in
December 2022, within the CG 21 period of performance. GDOE acknowledges that the re-issued
GDOE purchase order was not timely processed, however the purchase order which encumbered
the funds occurred in the appropriate performance period.
Additionally, relative to payroll, FPD requests a list (i.e. Staffing Pattern) of all Federally funded
personnel from HR. FPD distributes the list to CG Project Leads to validate and compare to the
Federal Roster as approved in the Consolidated Grants (CG) Application. The list is updated to
make any corrections necessary. Once validated by Project Leads and FPD, HR is given a memo
requesting to change/correct the funding year to the new grant award.
In GDOE’s Munis system, if the Human Resources (HR) employee salary records are not
accurately updated, GDOE payroll will reflect dated pay tables until such time HR makes the
appropriate updates based on project lead requests to update accounts to current grant year. GDOE
recorded journal entries to transfer the improperly charged payroll expenditure to the appropriate
grant year.
Finding No.: 2023-011, continued
Federal Agency: U.S. Department of Education
AL Program: 84.403 Consolidated Grant to the Outlying Areas
Area: Period of Performance
Questioned Costs: $11,004
Views of Responsible Officials, continued:
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 work
with the HR and Business Office any changes to accounts charged for federally funded payroll
expenditures. 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: There is no clear notation on the GDOE PO 20240171-01 document itself or within
the financial management system entry to indicate that such purchase order is a copy over of TPFA
PO 2023010.