Finding 11596 (2022-009)

Material Weakness
Requirement
F
Questioned Costs
$1
Year
2022
Accepted
2024-02-04

AI Summary

  • Core Issue: The District failed to accurately identify and report all capital expenditures related to the Education Stabilization Fund, leading to potential compliance violations.
  • Impacted Requirements: The District did not maintain proper property records or obtain necessary pre-approval for certain equipment purchases, violating federal regulations.
  • Recommended Follow-Up: Enhance training for staff on capital asset purchasing requirements and improve internal communication to ensure all expenditures are recorded and approved correctly.

Finding Text

Federal Program Information: Funding Agency: U.S. Department of Education Title: Education Stabilization Fund FAL Number: 84.425D,U,W Passthrough: New Mexico Public Education Department Award Year: 2022 Criteria: §200.213 Equipment. (d)(1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Additionally, according to grant requirements and the Compliance Supplement, when Education Stabilization Funds are used for capital expenditures the “…subrecipient must receive prior approval for capital expenditures for equipment acquisition or improvements to land, buildings, or equipment.” Condition: During our review of capital expenditures by the District, we identified the following issues: • The District had not properly identified all expenditures from the Education Stabilization Fund which were for capital additions to the District’s assets. The District had been approved for the addition of 500 Promethean boards. However, in the initial capital asset addition detail provided to us, only $300,000 of the total costs of $2,985,480.15 had been included on the listing. • The District did not obtain from the New Mexico Public Education Department (NMPED) an “Equipment >= $5,000 Preapproval to Purchase Form” for the purchase of seven Windsor 20” riding floor scrubbing machines at a cost of $76,193.46. The District did obtain the required forms for all other equipment purchases and construction/maintenance projects funded under the grant. Additionally, the NMPED did approve reimbursement of the $76,193.46. Questioned Costs: $76,193.46 The NMPED did reimburse these funds, but they could be called into question for not obtaining the release form prior to purchasing the equipment. Cause: The District had not captured all costs which required capitalization when the fixed asset and depreciation detail was provided to the auditors. Additional amounts were identified by the auditors and by District staff which caused the significant increase in the final value of capital asset additions for the year which were funded by the grant. The District expended significant funds for equipment, land improvements, and building improvements during the year under audit with more than 40 separate construction projects in place and millions of dollars of additions for single purchase items for equipment and vehicles. Identifying and capturing all of these costs were significant for the two individuals who are responsible for these duties when combined with all of their other duties in the District. The significant increase in the number of projects and the purchases of equipment and vehicles made in the year made capturing all items timely, correctly categorizing them, and processing depreciation amounts by the end of the year very difficult. Also, at times, the correct object codes for the items were not used when the original purchase orders were created. The system is designed to “hook” those items with pre-identified object codes that should be capitalized. However, when incorrect object codes are used for capital items that need to be captured and included in the detail identifying these items must be done manually, and this is a very time-consuming process. District personnel had missed communicating internally the purchase of the floor scrubbers and that this equipment was going to be purchased with grant funds. As such, the department responsible for obtaining all equipment authorizations was unaware of the need to initiate the form and obtain NMPED approval. Effect: The District is not in compliance with Federal regulations related to internal control procedures and compliance requirements in relation to the grant and could put funding in jeopardy or require the District to reimburse the program. Auditor’s Recommendation: We recommend the District emphasize the importance of accurately identifying all fixed asset additions and construction projects during the year and work to capture all relevant costs prior to the audit so that they may be coded and tracked to the grant funds used. These costs should be identified, recorded, and categorized into the proper capital asset categories in order to maintain accurate records. Original purchase orders should contain the proper fund and object codes to allow for the system to automatically capture these additions for review. Finally, when the District engages in as many projects and purchases that occurred in the year under audit, modifications to work schedules and responsibilities may need to be contemplated in order to provide sufficient time to capture and complete all the required tasks in a timely manner. We recommend that all individuals involved with creating purchase orders in grant funds be trained in the requirements for purchasing capital assets and the needed pre-authorizations required. Additionally, we recommend that all individuals involved be trained to contact the department assigned to obtain the pre-authorization forms from NMPED so that there is no miscommunication in the future. Responsible Official’s Plan: • Specific corrective action plan for finding: The Finance Grants department along with the Federal Programs department have discovered the need to add additional approver to include Federal Programs Coordinator and/or Federal Programs Specialist in requisition process of all purchases involving federal funds. This adjustment in the approval process will assist in catching all needed documentation required for the accurate justification and federal compliance. Grants Staff to seek training for purchasing capital assets using grant funds. In addition, verify items that cost over 5k and to make sure there is a 5k equipment form completed/signed and approved by PED and have it attached to the requisition. • Timeline for completion of corrective action plan: June 2023 • Employee position(s) responsible for meeting the timeline: Grants Specialist and Federal Programs staff.

Corrective Action Plan

The Finance Grants department along with the Federal Programs department have discovered the need to add additional approver to include Federal Programs Coordinator and/or Federal Programs Specialist in requisition process of all purchases involving federal funds. This adjustment in the approval process will assist in catching all needed documentation required for accurate justification and federal compliance. Grants Staff to seek training in purchasing capital assets using grant funds. In addition, verify items that cost over 5k and to make sure there is a 5k equipment form completed/signed and approved by PED and have it attached to the requisition.

Categories

Questioned Costs Equipment & Real Property Management Procurement, Suspension & Debarment Subrecipient Monitoring Cash Management HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 11595 2022-008
    Material Weakness
  • 11597 2022-007
    Significant Deficiency
  • 11598 2022-006
    Significant Deficiency
  • 588037 2022-008
    Material Weakness
  • 588038 2022-009
    Material Weakness
  • 588039 2022-007
    Significant Deficiency
  • 588040 2022-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.041 Impact Aid $6.51M
10.555 National School Lunch Program $2.89M
84.027 Special Education_grants to States $1.94M
84.060 Indian Education_grants to Local Educational Agencies $1.05M
10.553 School Breakfast Program $677,172
84.040 Impact Aid_facilities Maintenance $546,757
15.130 Indian Education_assistance to Schools $530,696
84.367 Improving Teacher Quality State Grants $408,011
10.565 Commodity Supplemental Food Program $336,760
84.365 English Language Acquisition State Grants $126,793
84.424 Student Support and Academic Enrichment Program $118,295
10.582 Fresh Fruit and Vegetable Program $108,348
84.048 Career and Technical Education -- Basic Grants to States $98,431
84.173 Special Education_preschool Grants $43,118
10.579 Child Nutrition Discretionary Grants Limited Availability $25,000
84.196 Education for Homeless Children and Youth $14,087
93.981 Improving Student Health and Academic Achievement Through Nutrition, Physical Activity and the Management of Chronic Conditions in Schools $8,202
84.425 Education Stabilization Fund $3,741
84.010 Title I Grants to Local Educational Agencies $675
84.287 Twenty-First Century Community Learning Centers $223