Finding 1146942 (2024-002)

2 CFR 1000.10 gives regulatory effect to the U.S. Department of Treasury for 2 CFR 200.332 which states, in part, pass-through entities must ensure every subaward includes requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. The grant’s pass-through entity is the Ohio Office of Budget and Management (OBM). State Fiscal Recovery Funds K-12 School Safety Grants Frequently Asked Questions require recipient schools to complete quarterly financial status reports via the OBM grants portal until they have spent all funds and completed their projects. Recipient schools are also required to split their expenditures across their entire district into two categories, capitalized and non-capitalized expenditures. The District did not have proper internal controls in place to ensure the accuracy of the quarterly financial status reports. During testing of quarterly financial status reports for the Coronavirus State and Local Fiscal Recovery Funds (AL #21.027), the District did not report $175,227 of capitalized expenditures as Amount Spent on Real Property / Construction Capitalized Improvements on the July 1, 2023 through September 30, 2023 ($53,952), the October 1, 2023 through December 31, 2023 ($121,113), and the January 1, 2024 through March 31, 2024 ($162) quarterly financial status reports. Failure to have the proper controls in place to ensure the accurate submission of the quarterly financial status reports could result in Treasury taking action against the District for failure to comply with programmatic requirements. The District should implement and have controls in place to ensure the quarterly expenditure reports are accurate.