Finding Text
Federal agency: U.S. Department of Education Federal program title: Student Support and Academic Enrichment Program Supporting Effective Instruction Grant English Language Acquisition Grant Coronavirus Capital Projects Fund Assistance Listing Number: 84.367, 84.365, 84.424A, 21.029 Federal Award Identification Number and Year: S367A230030: 7/1/2023-12/31/2026 S365A220031: 7/1/2022 - 12/31/2025 S424A230032: 7/1/2023-12/31/2026 CPFFN0199: 2/4/2022 - 12/31/2026 Pass-Through Agency: N/A Pass-Through Number(s): N/A Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per Federal Programs Cross-Cutting Risk Assessment Created by the Department, "The PED uses the Federal Programs Cross-Cutting Risk Assessment Tool to conduct the annual risk assessment in the spring/summer. The data and information used to populate the crosscutting subrecipient risk assessment tool are gathered and compiled from multiple sources...After the data and information are entered into the cross-cutting risk assessment tool, the data and information are analyzed to determine the level of risk." Additionally, the Pass-Through Entity must make the subrecipient aware of the award information required by 2 CFR section 200.331(a) sufficient for the PTE to comply with Federal statutes, regulations, and the terms and conditions of the award Condition: 84.367: 16 of 16 samples selected did not retain the FY25 Federal Programs Cross-Cutting Risk Assessment Tool in order to determine appropriate risk level and subrecipient monitoring procedure. 84.365: 10 of 10 samples selected did not retain the FY25 Federal Programs Cross-Cutting Risk Assessment Tool in order to determine appropriate risk level and subrecipient monitoring procedure. 84.424: 6 of 6 samples selected did not retain the FY25 Federal Programs Cross-Cutting Risk Assessment Tool in order to determine appropriate risk level and subrecipient monitoring procedure. 21.029 The subaward agreements lacked all required elements of a subaward. The ALN numbers provided did not match the correct ALN (21.027 vs 21.029). Questioned costs: None. Context: This was identified during Subrecipient Monitoring testing. The samples described above were statistically valid samples. Cause: The Department has not maintained internal controls and procedures over subrecipient communications designed to reasonably ensure documents are retained for an extended period of time and ensure all required elements are communicated to subawardees Effect: Noncompliance with Department policy and applicable federal regulations. Other elements of monitoring were conducted by the Department over the respective programs that mitigate the impact. Repeat Finding: No Recommendation: We noted improvements have been made during the audit period, including retainage of the FY26 Federal Programs Cross-Cutting Risk Assessment Tool. We recommend the Department continues to follow new procedures in place. Additionally, we recommend the Department implement effective processes and procedures to ensure all required elements are included in the communications to subawardees. Views of responsible officials: ALN 84.367 Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.365 Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.424D Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 21.029 Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline.