Finding 1222895 (2023-003)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2026-07-04

AI Summary

  • Core Issue: PSS lacks proper documentation for reviewing and approving payments, which affects the accuracy of disbursements.
  • Impacted Requirements: This situation violates 2 CFR Section 200.303, which mandates effective internal controls for managing federal awards.
  • Recommended Follow-Up: PSS should enhance its documentation processes for monitoring and approving disbursements to ensure compliance.

Finding Text

Finding No. 2023-003 Federal Agency: U.S. Department of Agriculture AL Program: 10.555 National School Lunch Program (NSLP) Federal Award No.: 217NMNM3N1174, 227NMNM3N1174 and 237NMNM3N1174 Area: Allowable Costs/Cost Principles Questioned Costs: $-0- Criteria: In accordance with 2 CFR Section 200.303, non-federal entities receiving federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: Based on walkthrough procedures performed over the disbursement process of program funds, PSS lacks documented evidence of review and approval controls over check and ACH payments to ensure that payment amounts agree with approved invoice amounts. Specifically, the process did not include documented review or approval demonstrating that checks and ACH disbursements were verified against supporting invoices prior to payment. As a result, controls designed to ensure the accuracy and validity of disbursements are not adequately documented or evidenced. Cause: PSS lacks adequate documentation evidencing its monitoring and review procedures over disbursements of program funds, including review and approval controls to ensure that checks and ACH payments agree with approved invoice amounts. Effect or potential effect: PSS is in noncompliance with 2 CFR Section 200.303 related to internal control requirements. No questioned costs are identified as testing did not disclose noncompliance with allowable costs/cost principles compliance requirements. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: PSS should implement and enforce adequate documentations over its monitoring control procedures in place over disbursements of program funds. Views of Auditee and Corrective Action Plan: PSS concurs with the findings. Refer to PSS’ Corrective Action Plan for additional information.

Corrective Action Plan

Finding No.: 2023-003 AL Program: 10.555 National School Lunch Program (NSLP) Area: Allowable Costs/Cost Principles Questioned Costs: $-0- Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the findings. Financial and Grants Management policies procedures were promulgated in SOPs on September 18, 2024. The financial management system was subsequently changed to Tyler Munis to conform with CNMI central government requirements which will enhance capabilities. The SOPs and the Tyler Munis implementation are under review by an external consultant and recommendations made to improve documentation of cost allowability have been received. Corrective Action Plan: I. Finalization of Allowability and Disbursement SOPs: PSS will finalize comprehensive Standard Operating Procedures (SOPs) and policies specifically governing allowability determinations and vendor payments. II. Enhanced Disbursement Controls: PSS is implementing a documented review and approval controls over the payment process. Before any check or ACH disbursement is finalized, a reviewer must verify that the payment amount agrees exactly with the approved invoice. This verification will be physically or digitally documented on the payment voucher to provide a clear audit trail of the pre-payment review. Proposed Completion Date: In progress for FY 2024 with full implementation and documentation processes expected to be completed in 2026. As part of this improvement, we are designing a standardized, documented review process to ensure all disbursements are verified against approved invoices prior to payment. Name of Contact Person and Title: Contact: Jonathan Aguon, Director of Finance Email Address: jonathan.aguon@cnmipss.org

Categories

Allowable Costs / Cost Principles Subrecipient Monitoring School Nutrition Programs Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1222896 2023-004
    Material Weakness Repeat
  • 1222897 2023-005
    Material Weakness Repeat
  • 1222898 2023-006
    Material Weakness Repeat
  • 1222899 2023-006
    Material Weakness Repeat
  • 1222900 2023-007
    Material Weakness Repeat
  • 1222901 2023-007
    Material Weakness Repeat
  • 1222902 2023-008
    Material Weakness Repeat
  • 1222903 2023-008
    Material Weakness Repeat
  • 1222904 2023-009
    Material Weakness Repeat
  • 1222905 2023-009
    Material Weakness Repeat
  • 1222906 2023-010
    Material Weakness Repeat
  • 1222907 2023-011
    Material Weakness Repeat
  • 1222908 2023-012
    Material Weakness Repeat
  • 1222909 2023-013
    Material Weakness Repeat
  • 1222910 2023-013
    Material Weakness Repeat
  • 1222911 2023-014
    Material Weakness Repeat
  • 1222912 2023-014
    Material Weakness Repeat
  • 1222913 2023-015
    Material Weakness Repeat
  • 1222914 2023-015
    Material Weakness Repeat
  • 1222915 2023-016
    Material Weakness Repeat
  • 1222916 2023-016
    Material Weakness Repeat
  • 1222917 2023-017
    Material Weakness Repeat
  • 1222918 2023-017
    Material Weakness Repeat
  • 1222919 2023-018
    Material Weakness Repeat
  • 1222920 2023-019
    Material Weakness Repeat
  • 1222921 2023-020
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425X AMERICAN RESCUE PLAN - STATE EDUCATIONAL AGENCY (OUTLYING AREAS) (ARP-OA-SEA) $53.69M
10.555 NATIONAL SCHOOL LUNCH PROGRAM $18.00M
84.403 CONSOLIDATED GRANT TO THE OUTLYING AREAS $16.53M
84.425A EDUCATION STABILIZATION FUND - STATE EDUCATIONAL AGENCY (OUTLYING AREAS) (ESF-SEA) $6.37M
84.027A SPECIAL EDUCATION GRANTS TO STATES $4.40M
93.356 HEAD START DISASTER RECOVERY $2.02M
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $1.65M
84.372 STATEWIDE LONGITUDINAL DATA SYSTEMS $1.30M
10.766 COMMUNITY FACILITIES LOANS AND GRANTS $1.09M
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $628,205
84.027X SPECIAL EDUCATION GRANTS TO STATES $477,042
84.215K INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS $426,512
93.060 SEXUAL RISK AVOIDANCE EDUCATION $318,776
94.006 AMERICORPS STATE AND NATIONAL 94.006 $307,231
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $306,484
12.U01 ARMY JROTC EFT DISTRICT $298,397
93.092 AFFORDABLE CARE ACT (ACA) PERSONAL RESPONSIBILITY EDUCATION PROGRAM $290,881
93.612 NATIVE AMERICAN PROGRAMS $117,573
93.600 HEAD START $116,353
84.371 COMPREHENSIVE LITERACY DEVELOPMENT $96,484
84.184 SCHOOL SAFELY NATIONAL ACTIVITIES $80,580
10.579 CHILD NUTRITION DISCRETIONARY GRANTS LIMITED AVAILABILITY $73,477
93.982 MENTAL HEALTH DISASTER ASSISTANCE AND EMERGENCY MENTAL HEALTH $18,258
93.587 PROMOTE THE SURVIVAL AND CONTINUING VITALITY OF NATIVE AMERICAN LANGUAGES $17,924
84.424F STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM - STRONGER CONNECTIONS GRANT $11,351
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $9