Finding 1222921 (2023-020)

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

AI Summary

  • Core Issue: PSS failed to provide adequate documentation to show compliance with key level management requirements for the federal award.
  • Impacted Requirements: Internal controls must align with federal standards, and PSS must document the required level of effort from key management personnel.
  • Recommended Follow-Up: PSS should improve documentation practices, including maintaining NOPA forms and time certification, to ensure compliance moving forward.

Finding Text

Finding No. 2023-020 Federal Agency: U.S. Department of Education AL Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award No.: 6H79SM086344-01M001 and 6H79SM086344-01M002 Area: Special Tests and Provisions - Key Level Management Questioned Costs: Undeterminable Criteria: In accordance with 2 CFR 200.303(a), the 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. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Further, in accordance with the grant agreement, PSS key level management are required to provide level of effort as follows: Condition For all six (or 100%) key level management personnel required to provide level of effort, PSS did not provide adequate evidence to substantiate that the required level of effort to the program were complied with. Cause: PSS did not provide documentation evidencing the level of effort of key level management personnel. Effect or potential effect: PSS is in noncompliance with applicable key level management requirements. No questioned costs result as we are unable to determine the extent of noncompliance. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: PSS should maintain documentation for its compliance with the key level management requirement, such as Notice of Personnel Action (NOPA) forms, certification of time worked under federal programs and payroll registers, among others. 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.: 2023-020 AL Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Area: Special Tests and Provisions - Key Level Management Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the findings. Financial and Grants Management processes were promulgated in a SOP on September 18, 2024. The SOPs are under review by an external consultant and recommendations made to improve documentation of time and effort allocable under federal awards. (See also 2023-004, 2023-0009) Corrective Action Plan: I. Establishment of Time and Effort SOPs: PSS will finalize and implement a dedicated Time and Effort Reporting SOP. This policy will explicitly define the key management Level of Effort (LOE) requirements by position and mandate the collection of specific supporting records, including Notice of Personnel Action (NOPA) forms, payroll registers, and certified timesheets. The SOP will feature robust internal controls and supervisory review procedures designed to prevent improper payments and ensure accurate labor distribution. II. Standardization of Key Management Records: PSS will obtain and systematically retain NOPA forms or equivalent documentation for all six positions identified in the grant agreement. This documentation will serve as the primary evidence to demonstrate compliance. III. Labor Distribution Monitoring Controls: PSS is implementing ongoing monitoring controls to ensure continued compliance. This includes a periodic internal review of payroll registers against the original grant agreements to verify that the labor costs charged to the award remain consistent with the approved personnel budget and documented effort. Proposed Completion Date: August 2026 Name of Contact Person and Title: Contact: Jacqueline Che, Federal Programs Officer Email Address: jacqueline.che@cnmipss.org

Categories

Special Tests & Provisions Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

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
  • 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

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