Finding 1222903 (2023-008)

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

AI Summary

  • Core Issue: PSS did not maintain the required level of State financial support for special education, leading to questioned costs of $345,823.
  • Impacted Requirements: Noncompliance with IDEA maintenance of effort regulations and lack of proper internal controls over expenditures.
  • Recommended Follow-Up: PSS should implement policies for monitoring and reconciling State expenditures to ensure compliance with federal regulations.

Finding Text

Finding No. 2023-008 Federal Agency: U.S. Department of Education AL Program: COVID-19 84.027 Special Education Cluster - Grants to States (IDEA, Part B) Federal Award No.: H027A220106, H027A230106, H027X210106 Area: Matching, Level of Effort, and Earmarking Questioned Costs: $345,823 Criteria: In accordance with IDEA §612(a)(18) as part of the IDEA Part B Application, states may meet the maintenance of State financial support (MFS), on either a total or per capita basis. Additionally, 34 CFR §300.163(a) says a State must not reduce the amount of State financial support for special education and related services for children with disabilities or otherwise made available because of the excess costs of educating those children, below the amount of support for the preceding fiscal year. Condition: 1. Based on the comparison of State expenditures recorded under Business Unit (BU) 111133 against the amount indicated on the Part B Application for MFS, we noted that PSS failed to maintain the required level of State financial support for special education and related services in FY2023. In addition, PSS included open encumbrances as part of its calculation for maintenance of effort. However, PSS was unable to substantiate these encumbrances or provide adequate documentation to support the inclusion of these encumbrances. As a result, questioned costs were determined based on the actual expenditures incurred in FY2023. 2. Per our walkthrough procedures over internal control, evidence of review and approval by the Director of Finance over the local expenditures recorded under business unit 111133 was not provided. Cause: PSS failed to adhere to the maintenance of effort requirements under IDEA §612(a)(18), 34 CFR §300.163 and applicable grant award requirements. Additionally, PSS lacks proper monitoring, review and approval controls over State expenditures recorded under business unit 111133 to ensure compliance with maintenance of effort requirements. Effect or potential effect: PSS is in noncompliance with applicable maintenance of effort regulations and questioned costs of $345,823 result. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: 1. PSS should ensure compliance with maintenance of effort requirements in accordance with applicable federal regulations and grant award terms. 2. PSS should establish and implement policies and procedures for monitoring, reviewing and reconciling State expenditures to accurately compare prior year and current year levels of State financial support for special education and related services. Views of Auditee and Corrective Action Plan: PSS concurs with the finding. Refer to PSS’ Corrective Action Plan for additional information.

Corrective Action Plan

Finding No.: 2023-008 AL Program: COVID-19 84.027 Special Education Cluster - Grants to States (IDEA, Part B) Area: Matching, Level of Effort, and Earmarking Questioned Costs: $345,823 Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the finding regarding the Maintenance of Financial Support (MFS) for IDEA Part B. We recognize that the inclusion of unverified encumbrances in the MFS calculation led to an inadvertent shortfall in actual expenditures compared to the required support levels. Corrective Action Plan: To ensure future compliance with IDEA §612(a)(18) and 34 CFR §300.163(a), PSS is implementing the following measures: I. Establishment of an MFS Monitoring Framework: The Finance Department, in coordination with the Special Education Program, will develop a formal MFS Tracking Ledger. This tool will track actual expenditures on a quarterly basis to ensure spending is on pace to meet or exceed the preceding fiscal year’s support levels. II. Verification of Encumbrances: PSS policy has been clarified to ensure that only "liquidated expenditures" (actual costs incurred) are used for MFS compliance reporting. Any encumbrances included in preliminary projections must be supported by valid contracts or purchase orders and must be reconciled against actual payments prior to final federal reporting. III. Enhanced Supervisory Review: PSS will develop an "MFS Certification" process. The Director of Finance will review and sign off on the expenditure reports at mid-year and year-end. This review will include a side-by-side comparison of current-year spending against the Part B Application requirements to identify potential shortfalls early. Proposed Completion Date: September 2026 Name of Contact Person and Title: Contact: Jonathan Aguon, Director of Finance Email Address: jonathan.aguon@cnmipss.org

Categories

Matching / Level of Effort / Earmarking

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
  • 1222899 2023-006
    Material Weakness Repeat
  • 1222900 2023-007
    Material Weakness Repeat
  • 1222901 2023-007
    Material Weakness Repeat
  • 1222902 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