Finding 1222912 (2023-014)

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

AI Summary

  • Core Issue: PSS is not compliant with federal requirements for managing equipment and property, leading to incomplete records and inadequate safeguarding measures.
  • Impacted Requirements: Key criteria from 2 CFR 200.313 regarding property records, maintenance procedures, and internal controls are not being met.
  • Recommended Follow-Up: PSS should update asset records, strengthen management policies, and implement standardized safeguarding procedures across all locations.

Finding Text

Finding No. 2023-014 Federal Agency: U.S. Department of Education AL Program: COVID-19 84.425A/84.425X Education Stabilization Fund Federal Award No.: S425A210001 and S425X210001 Area: Equipment and Real Property Management Questioned Costs: Undeterminable Criteria: In accordance with 2 CFR 200.313(b), a state must use, manage, and dispose of equipment acquired under a federal award in accordance with state laws and regulations. In accordance with 2 CFR 200.313(d)(1), property records must include a description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use and condition of the property, and any disposition data including the date of disposal and sale price of the property. The recipient and subrecipient are responsible for maintaining and updating property records when there is a change in the status of the property. Further, in accordance with 2 CFR 200.313 (3), a control system must be developed to ensure adequate safeguards to prevent loss, damage or theft of the property. Lastly, 2 CFR 200.313(d)(4) requires that adequate maintenance procedures must be developed to keep the property in good condition. Condition: 1. The capital assets listing maintained by PSS is incomplete and does not include all information for equipment and real property required under 2 CFR 200.313(d)(1), such as the federal participation percentage and the condition of the asset. No questioned costs are presented as we are not able to quantify the extent of noncompliance. 2. PSS lacks standardized and consistently implemented internal controls over safeguarding and maintenance of equipment across schools and offices. For twenty-six (or 96%) of the twenty-seven locations selected for testing, no maintenance procedures and safeguarding measures for equipment were documented. Cause: 1. PSS policies and procedures over capital assets management have not been fully updated to align with federal requirements under 2 CFR § 200.313 (d) (1), resulting in incomplete capital asset records. 2. PSS does not have a centralized and standardized system for safeguarding and maintaining equipment across all schools and offices for each type of equipment. Effect or potential effect: PSS is in noncompliance with applicable Equipment and Real Property Management requirements. Incomplete asset records and inconsistent safeguarding and maintenance practices increase the risk of loss, misuse, theft, or deterioration of federally funded property. Questioned costs are undetermined as we are unable to quantify the extent of noncompliance. Identification as Repeat Finding: Finding No. 2022-010 Recommendation: 1. PSS should update the structure and contents of their current capital asset listing to ensure all information required by 2 CFR 200.313(d)(1) is fully captured, maintained, and kept current for all equipment and real property acquired with federal funds. 2. PSS should revise and strengthen policies and procedures related to capital asset management to ensure alignment with federal requirements, including recordkeeping, inventory, safeguarding, and maintenance. 3. PSS should establish and implement centralized or standardized safeguarding and maintenance controls which should serve as minimum required procedures for all schools and offices regardless of equipment type. 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.: 2023-014 AL Program: COVID-19 84.425A/84.425X Education Stabilization Fund Area: Equipment and Real Property Management Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the audit findings and recognizes the systemic nature of the deficiencies in equipment management. We acknowledge that the current decentralized approach to safeguarding and maintenance is insufficient to meet the standards of 2 CFR §200.313. PSS is committed to implementing a district-wide, standardized asset management framework to protect federally funded property. 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. Payment procedures are being addressed in a separate SOP. Corrective Action Plan: To remediate these findings and ensure consistent compliance across all 27+ locations, PSS will implement the following: I. Capital Asset Listing Enhancement: PSS will immediately update the master inventory database to include all data fields required by 2 CFR 200.313(d)(1). A system-wide data validation will be conducted semi-annually or greater to ensure these fields are populated for all existing federal assets. II. Uniform Safeguarding and Maintenance Guidance: PSS will develop and issue a mandatory guidance on Uniform Safeguarding and Maintenance. This will provide standardized maintenance schedules and safeguarding protocols (e.g., specific tagging requirements and secure storage standards) that must be adopted by every school and office. This eliminates the "lack of standardized controls" across different locations. III. Standardized Maintenance Logs: PSS will require all locations to utilize a standard "Equipment Maintenance Log." This log will serve as the primary documented evidence that maintenance procedures are being performed. IV. Standard Operating Procedures and Policies: PSS will finalize SOPs and policies internal controls and specifically allowability determinations and vendor payments 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 regarding allowability of costs. Refresher training on cost principles will be required annually for staff making allowability determinations. Payment processes will be added to this training. Proposed Completion Date: September 2026 Name of Contact Person and Title: Contact: Michael Jason A. Babauta, Chief Procurement & Supply Officer Email Address: michael.jason.babauta@cnmipss.org

Categories

Equipment & Real Property Management

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
  • 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
  • 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