Finding 1173278 (2023-006)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2026-02-11
Audit: 386791
Auditor: HAGA KOMMER LTD

AI Summary

  • Core Issue: Required SF-429 forms for real property acquisition were not submitted, violating federal regulations.
  • Impacted Requirements: Compliance with 45 CFR §1303.44 – 1303.47 mandates prior approval and annual reporting for properties with federal interest.
  • Recommended Follow-Up: Implement procedures for annual SF-429-A submissions and provide training on real property requirements to staff.

Finding Text

Federal Program: Head Start Cluster (CFDA #93.600) Federal Agency: U.S. Department of Health and Human Services Federal Award Number(s): 08CH012021-02-01 Compliance Requirement: Reporting Questioned Costs: None noted Condition – During testing of reporting requirements for the Head Start program we noted that SF-429-B was not submitted prior to purchasing land during the budget period and SF-429-A for the budget period July 1, 2022 through June 30, 2023 was also not submitted. Criteria – 45 CFR §1303.44 – 1303.47 requires grantees to obtain prior approval from the Office of Head Start (OHS) before purchasing real property and to record a federal interest. SF-429-B must be submitted and approved prior to the acquisition and SF-429-A must be submitted annually for each property in which the federal government retains an interest. Cause – Due to staffing changes not all staff responsible for grant administration were fully aware of the SF-429 reporting obligations associated with real property acquisition under the Head Start program. Effect – Lack of required reporting increases the risk that real property may be acquired, used, or disposed of without proper federal oversight, which may result in administrative action or potential disallowance of costs. Recommendation – We recommend that the government establishes procedures to ensure that SF-429-A is submitted annually for all properties with a federal interest. As well as provide training to program staff on Head Start real property requirements under 45 CFR Part 1303. Client Response – We worked with those in charge of the Head Start grant closely through the process regarding the federal interest. We no longer own the property and have no plans to do so in the future. Status of Finding – This is not a repeat finding from the prior year.

Corrective Action Plan

Contact Person – Benjamin Schafer, Executive Director Corrective Action Plan – The Cooperative has no plans to own any property going forward. However, should this situation occur in the future training will be provided for all employees involved with the grant. Completion Date – As needed.

Categories

Reporting Equipment & Real Property Management Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1173276 2023-004
    Material Weakness Repeat
  • 1173277 2023-005
    Material Weakness Repeat
  • 1173279 2023-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.600 HEAD START $595,345
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $140,401
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $50,000
10.558 CHILD AND ADULT CARE FOOD PROGRAM $20,641
84.425 EDUCATION STABILIZATION FUND $11,158
84.371 COMPREHENSIVE LITERACY DEVELOPMENT $5,500
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $1,870