Finding 1134615 (2024-001)

Criteria: Under P.L. 2021 Chapter 109, boards of education are required to offer up to one year of additional or compensatory special education and related services, including transition services, to students with disabilities if a determination is made by the student’s Individualized Education Program (IEP) team and the student’s parent that the student requires such additional or compensatory special education and related services. As P.L.2021, c.109 went into effect in June 2021, this law impacts students with disabilities who exceed, or will exceed the current age of eligibility for special education and related services (21 years old) in the 2021-2022, 2022-2023 and 2023-2024 school years. Condition and Context: The New Jersey Department of Education issued a grant monitoring report on the Fiscal Years 2023 and 2024 ACSERS grants on September 17, 2024. That report detailed that per review of the supporting documentation provided (contracts, invoices, POs, etc.), it was determined that the District utilized a portion of its FY23 ASCERS funding to pay for substitute services for the special education classrooms of all its schools from April- June 2023. Although the substitute services were for the benefit of all special education students in the affected classrooms, the ACSERS award should be used for the benefit of individual students and his/her related services. Given that the substitute services were not tied directly to specific students eligible to receive continued education under the ACSERS program, these costs were deemed unallowable and the portion allocated to pay for substitute services was deemed a finding and questioned cost in the amount of $65,386 by the NJ Department of Education. Effect: Unallowable costs were charged to the FY23 ACSERS grant. Cause: The District did not closely review allowable purposes under the grant requirements and other provisions prior to submitting costs for reimbursement. Recommendation: It is recommended that the District put into place a review process that validates that all expenditures to be submitted for reimbursement conform to any limitations, exclusions or rules set forth in the grant to ensure that costs submitted for reimbursement are allowable.