FAC Explorer

Finding 1161191 (2022-011)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2022
Accepted
2025-10-22
Audit: 371187
Organization: Commonwealth of the Northern Mariana Islands (MP)
Auditor: ERNST & YOUNG (CNMI) INC

AI Summary

  • Core Issue: CNMI did not provide necessary instructions to schools for collecting data to set benefit levels for P-EBT, leading to noncompliance with federal requirements.
  • Impacted Requirements: Compliance with the Families First Coronavirus Response Act and the April 2022 Compliance Supplement, which mandate proper data collection and record-keeping for federal awards.
  • Recommended Follow-Up: CNMI should implement monitoring to ensure schools receive clear instructions for data collection, aligning with the P-EBT State Plan.

Finding Text

Finding No. 2022-011 Federal Agency: U.S. Department of Agriculture AL Program: 10.542 Pandemic EBT Food Benefits (P-EBT) Federal Award No.: 7NM400NM2 Area: Activities Allowed or Unallowed Questioned Costs: $-0- Criteria: 1. In accordance with Section 1101(b)(f)(2) of the Families First Coronavirus Response Act, as amended, a State agency may develop and use simplifying assumptions (including a State or local public health ordinance developed in response to COVID-19) and the best feasibly available data to determine the status of a school or covered child care facility as opened, closed, or operating with a reduced number of days or hours, establish State or regionally-based benefits levels, identify eligible children, and establish eligibility periods for eligible children. 2. In accordance with the CNMI State Plan, the Nutrition Assistance Program (NAP) will receive data from the CNMI Department of Education, Child Nutrition Program, the agency which shall receive all school information from the public schools, the private schools, and childcare centers. 3. In accordance with the April 2022 Compliance Supplement, the state agency is to instruct schools and school districts appropriately in order to collect the data necessary to set benefit levels consistent with the terms of the state plan. In addition, use of funds made available for P-EBT must also comply with government accounting and record keeping requirements in 2 CFR 200.334, for which the recipient and subrecipient must retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Condition: Documentation of the instructions provided to schools and school districts in order for the CNMI NAP to appropriately collect the necessary data to set benefit levels consistent with the terms of the state plan, was not provided. Cause: The CNMI did not provide instructions appropriately to schools and school districts in order to collect the data necessary to set benefit levels consistent with the terms of the state plan. Effect: The CNMI is in noncompliance with applicable activities allowed or unallowed compliance requirements. Recommendation: The CNMI should implement and enforce monitoring over the required instructions that state agency is to provide to schools and school districts appropriately in order to collect the data necessary to set benefit levels consistent with the terms of the CNMI’s P-EBT State Plan. Views of Responsible Officials: CNMI NAP disagrees with this finding. The 2022 Compliance Supplement states that the LEA, in this instance, the CNMI Public School System (PSS), is responsible for verifying the current free and reduced-price eligibility of households, unless the LEA is exempt from the verification requirement. PSS is not exempt from the verification requirement and the CNMI NAP has never given instructions to PSS for data collection as it is the PSS’ responsibility to supply the data to CNMI NAP for P-EBT. CNMI NAP’s role is to distribute the benefits only. Similar to the SUN Bucks (S-EBT) program, PSS furnishes the student listing to CNMI NAP, after which CNMI NAP distributes the benefits according to the listing provided by PSS. Refer to CNMI’s Corrective Action Plan for additional information. Auditor Response: The 2022 Compliance Supplement being referenced by CNMI NAP pertains to ALN 10.551 Supplemental Nutrition Assistance Program (SNAP). CNMI NAP should refer to the April 2022 Compliance Supplement specifically for ALN 10.542 Pandemic EBT Food Benefits (P-EBT). In addition, documentation that CNMI NAP is not required to provide instructions to schools and school district were not provided.

Corrective Action Plan

Finding No.: 2022-011 AL Program: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Activities Allowed or Unallowed Questioned Costs: $-0- Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: CNMI NAP respectfully disagrees with this finding. The April 2022 Compliance Supplement referenced by the auditor states: Special Tests and Provisions. 1. Verification of Free and Reduced-Price Applications (NSLP) Compliance Requirements: By November 15th of each school year, the LEA (or state in certain cases) must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reduced-price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1st. A state agency may, with FNS approval, assume from LEAs under its jurisdiction the responsibility for performing the verifications. If the LEA performs the verification function it must be in accordance with instructions provided by the state agency. The LEA must follow up on children whose eligibility status has changed as the result of verification activities to put them in the correct category. CNMI NAP response: The 2022 Compliance Supplement states that the LEA, in this instance, PSS, is responsible for verifying the current free and reduced-price eligibility of households unless the LEA is exempt from the verification requirement. PSS is not exempt from the verification requirement and the CNMI NAP has never given instructions to PSS for data collection as it is the PSS’ responsibility to supply the data to NAP for P-EBT. NAP’s role is to distribute the benefits only. Similar to the SUN Bucks (S-EBT) program, PSS furnishes the student listing to NAP, after which NAP distributes the benefits according to the listing provided by PSS. Proposed Completion Date: Ongoing

Categories

Subrecipient Monitoring School Nutrition Programs Eligibility

Other Findings in this Audit

  • 1161189 2022-010
    Material Weakness Repeat
  • 1161190 2022-010
    Material Weakness Repeat
  • 1161192 2022-012
    Material Weakness Repeat
  • 1161193 2022-013
    Material Weakness Repeat
  • 1161194 2022-014
    Material Weakness Repeat
  • 1161195 2022-015
    Material Weakness Repeat
  • 1161196 2022-016
    Material Weakness Repeat
  • 1161197 2022-017
    Material Weakness Repeat
  • 1161198 2022-018
    Material Weakness Repeat
  • 1161199 2022-019
    Material Weakness Repeat
  • 1161200 2022-013
    Material Weakness Repeat
  • 1161201 2022-014
    Material Weakness Repeat
  • 1161202 2022-015
    Material Weakness Repeat
  • 1161203 2022-016
    Material Weakness Repeat
  • 1161204 2022-017
    Material Weakness Repeat
  • 1161205 2022-018
    Material Weakness Repeat
  • 1161206 2022-019
    Material Weakness Repeat
  • 1161207 2022-013
    Material Weakness Repeat
  • 1161208 2022-014
    Material Weakness Repeat
  • 1161209 2022-015
    Material Weakness Repeat
  • 1161210 2022-016
    Material Weakness Repeat
  • 1161211 2022-017
    Material Weakness Repeat
  • 1161212 2022-018
    Material Weakness Repeat
  • 1161213 2022-019
    Material Weakness Repeat
  • 1161214 2022-013
    Material Weakness Repeat
  • 1161215 2022-014
    Material Weakness Repeat
  • 1161216 2022-015
    Material Weakness Repeat
  • 1161217 2022-016
    Material Weakness Repeat
  • 1161218 2022-017
    Material Weakness Repeat
  • 1161219 2022-018
    Material Weakness Repeat
  • 1161220 2022-019
    Material Weakness Repeat
  • 1161221 2022-020
    Material Weakness Repeat
  • 1161222 2022-021
    Material Weakness Repeat
  • 1161223 2022-022
    Material Weakness Repeat
  • 1161224 2022-023
    Material Weakness Repeat
  • 1161225 2022-024
    Material Weakness Repeat
  • 1161226 2022-025
    Material Weakness Repeat
  • 1161227 2022-026
    Material Weakness Repeat
  • 1161228 2022-027
    Material Weakness Repeat
  • 1161229 2022-028
    Material Weakness Repeat
  • 1161230 2022-029
    Material Weakness Repeat
  • 1161231 2022-030
    Material Weakness Repeat
  • 1161232 2022-031
    Material Weakness Repeat
  • 1161233 2022-032
    Material Weakness Repeat
  • 1161234 2022-033
    Material Weakness Repeat
  • 1161235 2022-032
    Material Weakness Repeat
  • 1161236 2022-033
    Material Weakness Repeat
  • 1161237 2022-032
    Material Weakness Repeat
  • 1161238 2022-033
    Material Weakness Repeat
  • 1161239 2022-032
    Material Weakness Repeat
  • 1161240 2022-033
    Material Weakness Repeat
  • 1161241 2022-034
    Material Weakness Repeat
  • 1161242 2022-035
    Material Weakness Repeat
  • 1161243 2022-036
    Material Weakness Repeat
  • 1161244 2022-037
    Material Weakness Repeat
  • 1161245 2022-038
    Material Weakness Repeat
  • 1161246 2022-039
    Material Weakness Repeat
  • 1161247 2022-040
    Material Weakness Repeat
  • 1161248 2022-041
    Material Weakness Repeat
  • 1161249 2022-038
    Material Weakness Repeat
  • 1161250 2022-039
    Material Weakness Repeat
  • 1161251 2022-040
    Material Weakness Repeat
  • 1161252 2022-041
    Material Weakness Repeat
  • 1161253 2022-042
    Material Weakness Repeat
  • 1161254 2022-043
    Material Weakness Repeat
  • 1161255 2022-044
    Material Weakness Repeat
  • 1161256 2022-042
    Material Weakness Repeat
  • 1161257 2022-043
    Material Weakness Repeat
  • 1161258 2022-044
    Material Weakness Repeat
  • 1161259 2022-045
    Material Weakness Repeat
  • 1161260 2022-046
    Material Weakness Repeat
  • 1161261 2022-047
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $243.39M
17.225 UNEMPLOYMENT INSURANCE $49.29M
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $16.73M
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $11.02M
10.542 PANDEMIC EBT FOOD BENEFITS $10.37M
97.030 COMMUNITY DISASTER LOANS $8.04M
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $7.82M
10.539 CNMI NUTRITION ASSISTANCE $7.49M
97.039 HAZARD MITIGATION GRANT $4.56M
21.026 HOMEOWNER ASSISTANCE FUND $4.16M
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $2.73M
66.801 HAZARDOUS WASTE MANAGEMENT STATE PROGRAM SUPPORT $2.51M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $2.44M
66.600 ENVIRONMENTAL PROTECTION CONSOLIDATED GRANTS FOR THE INSULAR AREAS - PROGRAM SUPPORT $2.34M
12.617 ECONOMIC ADJUSTMENT ASSISTANCE FOR STATE GOVERNMENTS $1.85M
20.526 BUSES AND BUS FACILITIES FORMULA, COMPETITIVE, AND LOW OR NO EMISSIONS PROGRAMS $1.74M
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $1.39M
15.605 SPORT FISH RESTORATION $1.32M
15.611 WILDLIFE RESTORATION AND BASIC HUNTER EDUCATION AND SAFETY $1.28M
93.489 CHILD CARE DISASTER RELIEF $1.24M
20.509 FORMULA GRANTS FOR RURAL AREAS AND TRIBAL TRANSIT PROGRAM $1.19M
11.419 COASTAL ZONE MANAGEMENT ADMINISTRATION AWARDS $954,712
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $830,622
97.067 HOMELAND SECURITY GRANT PROGRAM $781,287
97.U01 FEMA-JFO/DRC-Guard Services $661,485
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $644,809
84.126 REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES $625,444
97.012 BOATING SAFETY FINANCIAL ASSISTANCE $600,225
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $582,229
93.569 COMMUNITY SERVICES BLOCK GRANT $555,046
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $481,476
15.615 COOPERATIVE ENDANGERED SPECIES CONSERVATION FUND $474,763
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $452,548
17.277 WIOA NATIONAL DISLOCATED WORKER GRANTS / WIA NATIONAL EMERGENCY GRANTS $444,555
16.034 CORONAVIRUS EMERGENCY SUPPLEMENTAL FUNDING PROGRAM $442,103
16.575 CRIME VICTIM ASSISTANCE $417,507
10.025 PLANT AND ANIMAL DISEASE, PEST CONTROL, AND ANIMAL CARE $409,547
11.482 CORAL REEF CONSERVATION PROGRAM $404,632
17.258 WIOA ADULT PROGRAM $382,903
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $368,487
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $360,286
15.634 STATE WILDLIFE GRANTS $333,981
17.259 WIOA YOUTH ACTIVITIES $333,058
93.778 MEDICAL ASSISTANCE PROGRAM $318,867
93.434 EVERY STUDENT SUCCEEDS ACT/PRESCHOOL DEVELOPMENT GRANTS $287,347
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $282,833
81.041 STATE ENERGY PROGRAM $281,655
81.042 WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS $278,491
10.649 PANDEMIC EBT ADMINISTRATIVE COSTS $258,116
20.218 MOTOR CARRIER SAFETY ASSISTANCE $246,279
12.600 COMMUNITY INVESTMENT $242,221
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $238,819
17.504 CONSULTATION AGREEMENTS $234,374
97.062 SCIENTIFIC LEADERSHIP AWARDS $216,694
17.235 SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM $207,151
15.904 HISTORIC PRESERVATION FUND GRANTS-IN-AID $185,830
64.203 VETERANS CEMETERY GRANTS PROGRAM $175,658
15.663 NFWF-USFWS CONSERVATION PARTNERSHIP $160,217
12.022 DOD MENTOR-PROTEGE PROGRAM $160,121
45.310 GRANTS TO STATES $156,947
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $148,552
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $143,315
16.750 SUPPORT FOR ADAM WALSH ACT IMPLEMENTATION GRANT PROGRAM $135,657
93.590 COMMUNITY-BASED CHILD ABUSE PREVENTION GRANTS $135,591
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $118,439
97.047 BRIC: BUILDING RESILIENT INFRASTRUCTURE AND COMMUNITIES $112,435
11.472 UNALLIED SCIENCE PROGRAM $112,262
93.464 ACL ASSISTIVE TECHNOLOGY $111,566
17.285 REGISTERED APPRENTICESHIP $104,348
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $103,317
59.061 STATE TRADE EXPANSION $99,650
10.170 SPECIALTY CROP BLOCK GRANT PROGRAM - FARM BILL $98,021
11.437 PACIFIC FISHERIES DATA PROGRAM $93,960
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $83,128
45.025 PROMOTION OF THE ARTS PARTNERSHIP AGREEMENTS $79,513
10.664 COOPERATIVE FORESTRY ASSISTANCE $78,427
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $73,223
97.U03 FEMA-IGSA Enhdisasterlegalserv $70,131
11.467 METEOROLOGIC AND HYDROLOGIC MODERNIZATION DEVELOPMENT $64,229
93.048 SPECIAL PROGRAMS FOR THE AGING, TITLE IV, AND TITLE II, DISCRETIONARY PROJECTS $62,557
21.029 CORONAVIRUS CAPITAL PROJECTS FUND $59,975
16.017 SEXUAL ASSAULT SERVICES FORMULA PROGRAM $59,393
10.680 FOREST HEALTH PROTECTION $56,252
97.050 PRESIDENTIAL DECLARED DISASTER ASSISTANCE TO INDIVIDUALS AND HOUSEHOLDS - OTHER NEEDS $44,486
93.747 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM $42,583
97.008 NON-PROFIT SECURITY PROGRAM $40,698
93.499 LOW INCOME HOUSEHOLD WATER ASSISTANCE PROGRAM $40,185
10.179 MICRO-GRANTS FOR FOOD SECURITY PROGRAM $39,793
93.667 SOCIAL SERVICES BLOCK GRANT $38,860
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $37,209
16.585 TREATMENT COURT DISCRETIONARY GRANT PROGRAM $36,068
97.U02 FEMA Cost Share For Tinian $34,834
20.703 INTERAGENCY HAZARDOUS MATERIALS PUBLIC SECTOR TRAINING AND PLANNING GRANTS $31,544
90.404 HAVA ELECTION SECURITY GRANTS $30,376
17.273 TEMPORARY LABOR CERTIFICATION FOR FOREIGN WORKERS $29,237
10.766 COMMUNITY FACILITIES LOANS AND GRANTS $27,077
12.300 BASIC AND APPLIED SCIENTIFIC RESEARCH $21,582
93.369 ACL INDEPENDENT LIVING STATE GRANTS $21,096
45.129 PROMOTION OF THE HUMANITIES FEDERAL/STATE PARTNERSHIP $19,840
93.643 CHILDREN'S JUSTICE GRANTS TO STATES $18,435
84.177 REHABILITATION SERVICES INDEPENDENT LIVING SERVICES FOR OLDER INDIVIDUALS WHO ARE BLIND $18,377
66.040 DIESEL EMISSIONS REDUCTION ACT (DERA) STATE GRANTS $17,137
12.113 STATE MEMORANDUM OF AGREEMENT PROGRAM FOR THE REIMBURSEMENT OF TECHNICAL SERVICES $16,417
20.100 AVIATION EDUCATION $14,689
93.669 CHILD ABUSE AND NEGLECT STATE GRANTS $14,311
93.450 EBOLA HEALTHCARE PREPAREDNESS AND RESPONSE FOR SELECT CITIES WITH ENHANCED AIRPORT ENTRANCE SCREENINGS FROM AFFECTED COUNTRIES IN WEST AFRICA $13,717
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $13,076
20.205 HIGHWAY PLANNING AND CONSTRUCTION $12,910
93.630 DEVELOPMENTAL DISABILITIES BASIC SUPPORT AND ADVOCACY GRANTS $11,986
10.U01 DLNR CNMI Fisheries Training $8,033
93.042 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 2, LONG TERM CARE OMBUDSMAN SERVICES FOR OLDER INDIVIDUALS $7,552
19.976 International Narcotics Control and Law Enforcement $6,973
21.019 CORONAVIRUS RELIEF FUND $5,204
11.454 UNALLIED MANAGEMENT PROJECTS $4,630
11.407 INTERJURISDICTIONAL FISHERIES ACT OF 1986 $4,260
11.016 STATISTICAL, RESEARCH, AND METHODOLOGY ASSISTANCE $3,469
15.657 ENDANGERED SPECIES RECOVERY IMPLEMENTATION $2,790
15.631 PARTNERS FOR FISH AND WILDLIFE $2,755
17.600 MINE HEALTH AND SAFETY GRANTS $2,465
66.442 WATER INFRASTRUCTURE IMPROVEMENTS FOR THE NATION SMALL AND UNDERSERVED COMMUNITIES EMERGING CONTAMINANTS GRANT PROGRAM $852
20.514 PUBLIC TRANSPORTATION RESEARCH, TECHNICAL ASSISTANCE, AND TRAINING $794
93.041 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 3, PROGRAMS FOR PREVENTION OF ELDER ABUSE, NEGLECT, AND EXPLOITATION $70