Finding Text
Finding No.: 2024-006 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Grants to States Area: Period of Performance Questioned Costs: $39,665 Criteria: In accordance with applicable period of performance (POP) requirements, a non-federal entity may charge only allowable costs incurred during a federal award’s period of performance. Unless the federal awarding agency authorizes an extension, a non-federal entity must liquidate all financial obligations incurred under the federal award not later than 120 calendar days after the end date of the period of performance as specified in the terms and conditions of the federal award or in the approved extension. Furthermore, 2 CFR 200.303(a) states that the recipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the COSO. Conditions: Of sixty items, aggregating $384,666 of $3,198,523 of expenditures subjected to period of performance test, deficiencies were noted, as follows: 1. For 4 items or (7%), GDOE charged costs to a federal award after the period of performance ended and liquidated obligations of a federal award after the approved liquidation end date: Federal Award No. Purchase Order/ Invoice No. Invoice Date POP End Date Liquidation End Date Liquidation Date Expenditures Questioned Costs H027A210013 20232230 08/27/2024 09/30/2023 01/28/2024 08/01/2025 3,240 3,240 H027A220013 20233151 01/28/2025 09/30/2024 01/28/2025 Not yet paid 17,953 17,953 H027A220013 20233151 01/28/2025 09/30/2024 01/28/2025 Not yet paid 10,636 10,636 H027A220013 20240021 04/29/2025 09/30/2024 01/28/2025 Not yet paid 7,408 7,408 $39,237 $39,237 Finding No.: 2024-006, continued Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Grants to States Area: Period of Performance Questioned Costs: $39,665 Conditions, continued: 2. For 1 item or (2%), compliance with period of performance of expenditure (PO# 20241462) amounting to $428 could not be determined as supporting documents such as an invoice or canceled check was not made available for examination. 3. There is no review in place to ensure that liquidation of the obligation occur within the allowable time period. Cause: GDOE did not enforce monitoring controls over compliance with applicable period of performance requirements relating to charging of costs to a federal award within the period of performance. Also, GDOE’s internal control policies and procedures in place are not suitably designed to ensure that liquidation of the obligation occurs within the allowable time period. Effect: GDOE is in noncompliance with applicable period of performance requirements. The reportable questioned cost is $39,665. Identified as a Repeat Finding: 2023-009 Recommendation: Responsible personnel should enforce monitoring controls over compliance with applicable period of performance requirements. Prior to charging costs to a federal award or liquidating obligations incurred under a federal award, responsible personnel should verify that the period of performance, including the liquidation end date, has not expired. Views of Responsible Officials: The Division of Special Education is currently reviewing the details of the finding in order to provide an adequate response and corrective action plan.