Finding Text
Internal Control and Compliance over Level of Effort
Identification of the Federal Program:
Assistance Listing Number: 84.116z
Assistance Listing Title: Fund for the Improvement of Postsecondary Education
Federal Agency: Department of the Education
Pass-Through Entity: None
Federal Award Number and Award Year: P116Z220212 and 2022
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation):
Pursuant to the Grant Award Notification Section 5 – Key Personnel, the City is required to maintain level of
effort of 10% devoting to the project by the Project Director.
Condition:
We noted that the City did not meet the requirements of level of effort based on the documents provided.
Cause:
There was turnover of the Project Director position and there is lack of transition and training on the program
requirements.
Effect or Potential Effect:
Not meeting the requirements of level of effort lead to the U.S. Department of Education imposing sanctions on
the City including withholding future apportionments.
Questioned Costs:
No questioned costs were reported.
Context:
See condition above for context of the finding.
Identification as A Repeat Finding, If Applicable:
Not applicable.
Recommendation:
We recommended the City implement policies and procedures relating training and transition of program
responsibilities in event of turnover to avoid not meeting program requirements. We also recommended the City develop a process and start tracking the time and effort of the new Project Director to ensure compliance with level of effort requirement.
Views of Responsible Officials:
Management concurs with the finding and agrees to implement necessary corrective procedures.