Finding 1153072 (2024-010)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
$1
Year
2024
Accepted
2025-09-15
Audit: 366326
Organization: Milwaukee Public Schools (WI)

AI Summary

  • Core Issue: There is a material weakness in the approval process for semi-annual certifications, leading to potential unallowable costs being submitted for reimbursement.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a) and 2 CFR 200.430(i) is lacking, as timely approvals of certifications were not consistently obtained before final reimbursement claims were submitted.
  • Recommended Follow-Up: Implement stronger internal controls to ensure all costs are reviewed and certified before the final reimbursement deadlines to avoid unallowable charges.

Finding Text

Finding 2024-010 - Material Weakness - Allowable Costs/Cost Principles Federal Assistance Listing Number: 84.010, 93.600 Federal Program Name: Title I Grants to Local Educational Agencies and Head Start Cluster Federal Agency Name: U.S. Department of Education and U.S. Department of Health and Human Services Pass-Through Entity Name: Wisconsin Department of Public Instruction Pass-Through Entity Identification Number: 2024-403619-DPI-TIA-141, 2024-403619-DPI-CSI-148 Criteria: In accordance with 2 CFR 200.303(a), the non-Federal entity must 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. In accordance with 2 CFR 200.430(i), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Additionally, 2 CFR 200.403(g) requires that costs are adequately documented to be allowable under Federal awards. Condition/Context: The District supports time charged to federal awards via semi-annual certifications which are approved by the grant administrator or the building principal. In order for a cost to be supported at the time of final reimbursement, the semi-annual certifications should be approved by the grant administrator or the building principal. Title I Grants to Local Educational Agencies (ALN 84.010) The final reimbursement claim for the Title I Grants to Local Educational Agencies (Title I) program were due to Wisconsin Department of Public Instruction (DPI) on September 30, 2024; however, the final reimbursement claim for the Part A award was not submitted to DPI until November 18, 2024, and the CSI award was not submitted to DPI until October 1, 2024, due to an extension. Five of the 40 individuals sampled had their semi-annual certifications not approved timely and were approved after the due date of the final reimbursement claim, but before the date of the actual submission of the final reimbursement claim. An additional two individuals of the 40 sampled had their semi-annual certifications approved after the final reimbursement claims were submitted. Upon further review of all the spring semi-annual certifications for the Title I awards, there were an additional 50 individuals that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim but before the submission of the final reimbursement. Additionally, nine individuals had their semi-annual certifications approved after the final reimbursement date of the Part A award and another 59 individuals from Part A did not have their semi-annual certifications approved at all. Head Start Cluster (ALN 93.600) The final reimbursement claim for the program was submitted to the Federal agency on November 22, 2024. Four of the 40 individuals sampled had their semi-annual certifications approved by the Head Start administrator after the submission date of the final reimbursement claims. Upon further review of the all the spring semi-annual certifications, there was an additional individual that had their semi-annual certifications approved by the principal after the due date of the final reimbursement claim and another four individuals that did not have their semi-annual certifications approved at all. The samples were not statistically valid. Cause: There was a lack of internal control over the timely approval of the semi-annual certifications. Effect or Potential Effect: By not having an approved semi-annual certification before the date of the final reimbursement claims, unallowable costs may be submitted for reimbursement. Questioned Costs: The payroll costs and related fringe benefits charged at a rate of 52.48% are unallowable. Title I Grants to Local Educational Agencies (ALN 84.010) • 2024-403619-DPI-CSI-148: The two sampled individuals’ payroll and fringe benefits for the particular transaction totaled $507. • 2024-403619-DPI-TIA-141: The additional individuals' payroll and fringe benefits for the spring semi-annual certifications reviewed that were approved after the final reimbursement submission date and those that were not approved at all totaled $2,077,880. Head Start Cluster (ALN 93.600) • 05CH010537: After the additional testing, the total payroll and related fringe benefits for the spring semi-annual certifications that were approved after the final reimbursement request submission date or not approved at all totaled $241,794. Recommendations: We recommend that controls be implemented that will allow costs to be reviewed and fully supported prior to the date the final reimbursement claims are due to DPI. Views of Responsible Official: Management concurs with the finding.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1153073 2024-010
    Material Weakness Repeat
  • 1153074 2024-009
    Material Weakness Repeat
  • 1153075 2024-009
    Material Weakness Repeat
  • 1153076 2024-009
    Material Weakness Repeat
  • 1153077 2024-009
    Material Weakness Repeat
  • 1153078 2024-010
    Material Weakness Repeat
  • 1153079 2024-010
    Material Weakness Repeat
  • 1153080 2024-011
    Material Weakness Repeat
  • 1153081 2024-012
    Material Weakness Repeat
  • 1153082 2024-012
    Material Weakness Repeat
  • 1153083 2024-012
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $36.90M
84.027 Special Education Grants to States $29.49M
10.553 School Breakfast Program $13.49M
93.778 Medical Assistance Program $7.52M
84.010 Title I Grants to Local Educational Agencies $7.06M
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $5.85M
84.424 Student Support and Academic Enrichment Program $5.28M
84.287 Twenty-First Century Community Learning Centers $4.37M
10.582 Fresh Fruit and Vegetable Program $1.84M
84.425 Education Stabilization Fund $1.79M
84.048 Career and Technical Education -- Basic Grants to States $1.57M
10.558 Child and Adult Care Food Program $1.53M
84.173 Special Education Preschool Grants $1.38M
93.600 Head Start $986,627
84.206 Javits Gifted and Talented Students Education $834,305
15.662 Great Lakes Restoration $764,115
10.559 Summer Food Service Program for Children $656,042
84.299 Indian Education -- Special Programs for Indian Children $549,460
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $549,157
84.215 Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Directed Spending for Elementary and Secondary Education Community Projects $470,210
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $261,714
84.282 Charter Schools $205,824
84.411 Education Innovation and Research (formerly Investing in Innovation (i3) Fund) $182,437
93.327 Demonstration Grants for Domestic Victims of Human Trafficking $181,756
20.205 Highway Planning and Construction $162,618
10.935 Urban Agriculture and Innovative Production $106,324
84.060 Indian Education Grants to Local Educational Agencies $98,114
66.609 Protection of Children From Environmental Health Risks $98,026
84.365 English Language Acquisition State Grants $22,259
32.009 Emergency Connectivity Fund Program $7,997
10.902 Soil and Water Conservation $6,842
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $-180
84.196 Education for Homeless Children and Youth $-312
10.574 Team Nutrition Grants $-657
84.184 School Safely National Activities $-698
93.500 Pregnancy Assistance Fund Program $-49,297
47.070 Computer and Information Science and Engineering $-82,759