Finding Text
Entity: Eugenio Maria de Hostos Charter School
Federal agency: U.S. Department of Education
Federal program: COVID-19 Education Stabilization Fund:
American Rescue Plan – Elementary and Secondary Schools Emergency Relief
Fund
Assistance Listing Number: 84.425U ESSER
Federal Award Identification Number and Year: S425U210028, 2021 ESSER
Pass-Through Agencies: Pennsylvania Department of Education
Pass-Through Number: 223-21-0837 ESSER and 225-21-0837 ESSER
Award Period: 03/13/2020 - 09/30/2024 ESSER
Type of Finding:
• Other Matter
• Significant Deficiency in Internal Control Over Compliance
Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the
provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that the
nonfederal 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). The Organization is responsible for
having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash
on Hand – Quarterly Report is a required filing for projects that received payments in a previous
quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of
Education’s Financial Accounting Information website, we noted there were five Reconciliation of Cash
on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the
reports submitted were filed late to the Pennsylvania Department of Education.
Questioned Cost: None
Cause: One report was late for a month as a result of the extensive reconciliations and expense
reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late
due to the change of the portal and the process the PA Department of Education managed for the grant
Final Expenditure Report. The portal availability was well after the deadline.
Effect: Noncompliance with the reporting requirements as described in both the grant awards and
2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the
scheduled monthly payments to be suspended due to the delinquent submission of the Reconciliation
of Cash on Hand – Quarterly Report.
Recommendation: To ensure accountability with the required reporting to the Pennsylvania
Department of Education, we recommend management review and update procedures to establish
consistent preparation, review, and submission of all program reports to ensure reporting requirements
are being met. Such controls would ensure timely and accurate reporting being produced and optimum
cash flow management.
Views of Responsible Officials: Management agrees with the finding.