Finding Text
Assistance Listing Number(s): 84.425V
Name of Federal Program or Cluster: COVID-19 Education Stabilization Fund (ESF), American Rescue
Plan – Emergency Assistance to Non-Public Schools (ARP EANS)
Name of Federal Agency: Department of Education
Federal Award Identification Number: S425V210042
Federal Award Date: February 26, 2021 and September 24, 2021
Name of Pass-through Entity: State of North Carolina
Pass-through Entity Identifying Number: 60-04 and 60-05
Award Period: July 1, 2022 through September 30, 2023 and July 1, 2022 through September 30, 2024
Criteria: Uniform Guidance 2 CFR 200.303(a) requires the non-federal entity to establish and maintain
effective internal control over the federal award that provides reasonable assurance that the non-federal
entity is managing the federal award in compliance with federal statutes, regulations, and the terms and
conditions of the federal award.
Condition: 54 of 60 disbursements sampled did not have documented internal control that supported
reasonable assurance of compliance with allowable activities and cost principles requirements.
Cause: A written policy and procedures over documenting internal control(s) over allowable activities and
cost principles was not designed and implemented.
Effect or Potential Effect: Costs charged to the federal award are more likely to be for unallowable activities
and not comply with allowable cost principles. These costs may be disallowed.
Context: Salesforce is used to document disbursements, but was not set up to document internal control
procedures.
Repeat Finding: No
Recommendation: All disbursements charged to the federal award should have documentation to support
internal controls performed for allowable activities and cost principles. Written policies and procedures
should be designed and implemented for documentation of internal controls performed for allowable
activities and cost principles.
Views of Responsible Officials: The organization agrees with the finding.