Finding 1222899 (2023-006)

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

AI Summary

  • Core Issue: PSS lacks proper documentation and monitoring controls for program costs, leading to questioned costs of $5,130.
  • Impacted Requirements: Noncompliance with federal cost principles as outlined in CFR §200.403, affecting both nonpayroll and payroll expenditures.
  • Recommended Follow-Up: PSS should strengthen monitoring controls and improve documentation filing systems to ensure compliance and support for program costs.

Finding Text

Finding No. 2023-006 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Cluster - Grants to States (IDEA, Part B) Federal Award No.: H027A200106, H027A210106, H027X210106, H027A22106, H027A230106 Area: Activities Allowed/Unallowed, Allowable Costs/Cost Principles Questioned Costs: $5,130 Criteria: 1. Per CFR §200.403(a), costs must be necessary and reasonable for the performance of the Federal award. 2. In accordance with 2 CFR §200.403, costs must be adequately documented in order to be allowable under federal programs. Condition: 1. Of ten nonpayroll expenditures tested, aggregating $184,105 of a total population of $1,241,478, one (or 10%), transaction pertains to an off-island travel from Rota to Saipan to attend PSS’ education day celebration event. There was no documentation provided to justify that such an event is necessary and reasonable for the performance of the federal award, for which the corresponding directly associated travel costs are also questioned. 2. Of thirty payroll expenditures tested, aggregating $75,035 of a total population of $3,488,866, the following were noted: a. For one (or 3%), the differential pay rate for the nine hours paid to an employee was not provided, for which the corresponding directly associated payroll costs are also questioned. b. For one (or 3%), the gross pay comprised of the employee’s payroll cost and annual leave pay out; however, the approved timesheet for the hours worked was not provided, for which the corresponding directly associated costs are also questioned. Cause: 1. PSS lacks monitoring control procedures to ensure program costs are supported; and 2. Inadequate documentation and inadequate systematic filing of relevant documentation supporting program costs. Effect or potential effect: PSS is in noncompliance with the applicable allowable costs/cost principles compliance requirements and questioned costs of $5,130 result as the projected questioned costs exceed the $25,000 threshold. Identification as Repeat Finding: Finding No. 2022-003 Recommendation: 1. PSS should implement and enforce monitoring controls over compliance with applicable allowable costs/cost principles; and 2. Establish and maintain effective systematic filing of relevant documentation to support program costs and for easier retrieval. Views of Auditee and Corrective Action Plan: PSS concurs with the audit findings and the associated questioned costs. Refer to PSS’ Corrective Action Plan for additional information.

Corrective Action Plan

Finding No.: 2023-006 AL Program: 84.027 Special Education Cluster - Grants to States (IDEA, Part B) Area: Activities Allowed/Unallowed, Allowable Costs/Cost Principles Questioned Costs: $5,130 Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the audit findings and the associated questioned costs. Financial and Grants Management policies procedures were promulgated in a 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: To prevent future occurrences and ensure full compliance with federal cost principles, PSS will implement the following: I. Review of Travel Authorization Requirements: PSS will conduct a review of its travel policy to require a written statement of alignment with program goals or objectives for every travel request. This statement must explicitly document how the travel is necessary and reasonable for the performance of the specific federal award. II. Centralized Digital Documentation Protocol: To resolve the inadequate systematic filing issue, PSS implemented a protocol to improve its digital filing procedures. All supporting documents, including invoices, boarding passes, approved timesheets, and pay rate authorizations, must be uploaded and verified before the final liquidation of any federal drawdowns. III. Strengthening Review Process: Finalize expanded SOPs and policies to include more detail on time and effort reporting (including differential pay) and travel justifications specific to allowability determinations that are currently in draft including an analysis rubric and checklist for review. Where necessary, program specific supplemental guidance for allowability determinations will be provided. PSS central office staff participated in live training in October 2025. Refresher training on cost principles will be required annually for staff making allowability determinations. Proposed Completion Date: PSS is currently in the process of implementing these corrective actions with full implementation by August 2026. Name of Contact Person and Title: Contact: Jacqueline Che, Federal Programs Officer Email Address: jacqueline.che@cnmipss.org

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1222895 2023-003
    Material Weakness Repeat
  • 1222896 2023-004
    Material Weakness Repeat
  • 1222897 2023-005
    Material Weakness Repeat
  • 1222898 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