Finding Text
2 CFR § 3474.1 provides that the Department of Education (ODE) adopts the Office of Management and Budget (OMB) guidance in 2 CFR part 200. Thus, this part gives regulatory effect to the OMB guidance and supplements the guidance as needed for the ODE, except as otherwise noted in that section. 2 CFR § 200.303 states a recipient and subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Due to deficiencies in internal policies and procedures, the Academy did not approve three out of six (50%) of invoices that were for allowable costs and activities prior to being paid. Failure to have the appropriate controls in place may result in the Academy using federal funds for unallowable costs or activities. The Academy should develop internal control policies over Federal awards to help ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.