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.