Finding 1179662 (2023-002)

Material Weakness Repeat Finding
Requirement
ABI
Questioned Costs
-
Year
2023
Accepted
2026-03-16

AI Summary

  • Core Issue: The School District lacks procedures to follow its written policies for federal grants, violating Uniform Guidance requirements.
  • Impacted Requirements: Key areas affected include time and effort tracking, equipment management, procurement standards, and competition methods.
  • Recommended Follow-Up: The School District should revise its policies and develop necessary procedures to ensure compliance with the Uniform Guidance.

Finding Text

Revise Written Policies and Develop Procedures over Administration of Federal Grants Federal Agency: U.S. Department of Education Pass-through Agency: New Hampshire Department of Education Program: Elementary and Secondary School Emergency Relief Fund Assistance Listing Number: 84.425 Compliance Requirements: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Equipment Management; and Procurement, Suspension and Debarment Criteria: The Uniform Guidance requires nonfederal entities that receive federal awards to establish written policies and procedures as described in the following sections: • Time and effort (2 CFR 200.431) • Equipment (2 CFR 200.313) • General procurement standards (2 CFR 200.318) • Competition (2 CFR 200.319) • Methods of procurement to be followed (2 CFR 200.320) Condition: The School District did not have procedures to comply with its written policies relative to federal awards as required by the Uniform Guidance. Cause: The School District was not aware of these compliance requirements. Effect: The School District is not in compliance with the Uniform Guidance with respect to these written policies. Recommendation: We recommend that the School District update its policies and procedures to comply with the Uniform Guidance requirements stated above. Management’s Response: Management agrees with the finding.

Corrective Action Plan

Cause: While policies were in place, detailed written procedures for consistent grant administration had not been developed or formally documented. Corrective Action Taken: A procedure manual has been written to incorporate required compliance areas, including allowability of costs, procurement, equipment management, cash management, time and effort reporting, suspension and debarment, and record retention. Planned Corrective Actions / Preventive Measures: 1. Procedure Development: Document clear written procedures including requisitioning, approvals, reimbursements, reporting, and monitoring. 2. Training and Implementation: Provide training to all staff involved in grant administration on the new procedures. Establish a schedule for periodic refresher training and updates when regulations or program requirements change. 3. Ongoing Monitoring: Designate the Business Administrator (or designee) to monitor compliance and review procedures annually. Update policies and procedures as needed to reflect changes in federal requirements or internal practices. Timeline: Procedures completed: September 2024. Staff training and implementation: June 2026. Ongoing monitoring: Annually, beginning March 2026 Responsible Parties: Lori Schmidt, Business Administrator: Oversight of policy and procedure revision, implementation, and monitoring. Scott LaFortune, Finance Manager/Grant Manager: Day-to-day adherence to procedures and reporting. School Board: Formal policy approval.

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1179659 2023-001
    Material Weakness Repeat
  • 1179660 2023-002
    Material Weakness Repeat
  • 1179661 2023-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 EDUCATION STABILIZATION FUND $669,852
84.027 SPECIAL EDUCATION GRANTS TO STATES $524,617
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $461,272
10.555 NATIONAL SCHOOL LUNCH PROGRAM $340,602
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $254,392
10.855 DISTANCE LEARNING AND TELEMEDICINE LOANS AND GRANTS $246,155
10.553 SCHOOL BREAKFAST PROGRAM $130,442
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $91,821
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $69,858
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $68,921
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $65,957
84.358 RURAL EDUCATION $20,285
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $9,677