Finding Text
Finding 2025-004: Material Weakness - Internal Control and Compliance Over Activities Allowed/Allowable Costs Program: COVID-19: Education Stabilization Fund Assistance Listing Number: 84.425 Pass-Through Agency: Wisconsin Department of Public Instruction Repeat of Prior Year Finding 2024-004 Criteria: A system of internal control should be in place and operating effectively to achieve a higher reliability that errors or irregularities in expenditure recording would be identified by the District. This system should include approval of all inputs. Additionally, ESSER funds are subject to the Tydings amendment in section 421(b) of the General Education Provisions Act, 20 U.S.C. 1225(b), and are therefore available for obligation through September 30, 2024. As such, all expenditures must be obligated by September 30, 2024. Condition: Approval was not consistently documented on invoices and extended pay wages lacked documented approval. Of the 40 expenditures tested, 16 lacked adequate internal control documentation of review and approval and 3 were for purchases made after September 30, 2024 with no prior obligation. The sample was not statistically valid. Cause: The District did not ensure that the proper reviews and approvals were in place prior to payment and did not adhere to the obligation requirements. Context: Of the 40 expenses tested, two payroll transactions involving extended pay were found to not have approval over the amounts paid by the District and 14 invoices were found to not have documented approval. Of these invoices, three were incurred after the end of the grant period with no obligation made in the allowable time period. One person handles the majority of the supporting documents, with no outside review. Extended pay rates were approved many years ago, but no documentation of the approved amounts exists. Purchase orders are generally approved with account coding, but this was not done for purchases that fell outside the usual PO process. Effect: Because of the lack of internal controls, it is less likely that errors or irregularities in the expenditures would be discovered internally. Unallowable costs could be paid for with grant funds and costs were incurred outside of the grant period. Questioned Costs: Questioned costs for Assistance Listing Number 84.425 include $159,233 of expenditures that were not obligated or incurred before the end of the grant period. Recommendation: An appropriate, knowledgeable employee should review all invoices and timecards prior to payment, including extended time for training session compensation, and approval should be documented. We also recommend that employer extended pay rates should be approved annually by the School Board, and documentation of approved rates should be retained. District staff should review and understand the terms of grants to ensure expenditures are made within required time periods. Views of Responsible Officials: The District acknowledges this finding. Invoices are reviewed by the Administration and Board of Education monthly. Additional reviews by administration will be put into place. The Board of Education shall approve the pay rates annually and appropriate documentation kept.