Finding 1153074 (2024-009)

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

AI Summary

  • Core Issue: There is a material weakness in internal controls regarding the timely approval of semi-annual certifications for federal awards.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a) is not being met, risking submission of unallowable costs for reimbursement.
  • Recommended Follow-Up: Implement stronger controls to ensure all costs are reviewed and certified before final reimbursement claims are submitted to DPI.

Finding Text

Finding 2024-009 - Material Weakness - Allowable Costs/Cost Principles Federal Assistance Listing Number: 84.367, 84.425D, 84.425U and 84.425W Federal Program Name: Supporting Effective Instruction State Grants and COVID-19 - Education Stabilization Fund Federal Agency Name: U.S. Department of Education Pass-Through Entity Name: Wisconsin Department of Public Instruction Pass-Through Entity Identification Number: 2024-403619-DPI-TIIA-365, 2022-403619-DPI-ESSERFII-163 and 2022-403619-DPI-ESSERFIII-165, 2022-403619-DPI-ARPHCYII-173 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. 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. Supporting Effective Instruction State Grants (ALN 84.367) The final reimbursement claim for the program was due to Wisconsin Department of Public Instruction (DPI) on September 30, 2024; however, the final reimbursement claim was not submitted to DPI until January 9, 2025, due to an extension. Thirteen of the 40 individuals sampled did not have their semi-annual certifications 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. COVID-19 – Education Stabilization Fund: Elementary and Secondary School Emergency Relief (ESSER II) (ALN 84.425D), American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) (ALN 84.425U) and American Rescue Plan - Elementary and Secondary School Emergency Relief - Homelessness Children and Youth (84.425W) The final reimbursement claims for the ESSER II and the ARP ESSER programs were due to DPI on September 30, 2023, and September 30, 2024, respectively; however, the final reimbursement claims were not submitted to DPI until December 8, 2023, for ESSER II and December 6, 2024, for ARP ESSER. 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 claims, but before the date of the actual submission of the final reimbursement claim. 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: None noted. 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

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1153072 2024-010
    Material Weakness Repeat
  • 1153073 2024-010
    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