Finding 1223216 (2023-013)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2023
Accepted
2026-07-08

AI Summary

  • Core Issue: Williston Basin Public School District No. 7 failed to provide necessary documentation for $6,391,442 in payroll reallocations to the Education Stabilization Fund.
  • Impacted Requirements: This finding indicates a lack of compliance with Uniform Guidance and internal control standards, increasing risks of errors and fraud.
  • Recommended Follow-Up: The district should implement stronger internal controls and policies to ensure proper documentation for all federal grants.

Finding Text

2023-013 – EDUCATION STABILIZATION FUND - LACK OF SUPPORT OVER ESSER FUNDS – ALN 84.425 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE FINDING TYPE: MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Finding 2023-013 Federal Program: Education Stabilization Fund ALN: 84.425 Federal Award Number(s) and Year(s): S425U210007, 2023 Federal Agency: U.S. Department of Education Pass Through Agency: North Dakota Department of Public Instruction Questioned Cost: $6,391,442 Condition Williston Basin Public School District No. 7 was unable to provide supporting documentation for journal entries that were done to reallocate payroll. There were 3 journal entries totaling $6,391,442 that were completed at year end to move salaries into the Education Stabilization Fund program that did not have documentation to support the salary expenditures. Effect By not having the correct supporting documentation, the School District may be subject to an increased risk of error, fraudulent financial reporting, asset misappropriation, and corruption. Cause Williston Basin Public School District No. 7 does not have sufficient procedures in place to ensure that support documentation for federal grants is maintained. Criteria Uniform Guidance 2 CFR 200.403(g) requires costs to be adequately documented. "Standards for Internal Control in the Federal Government" (Green Book) requires management to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. Management is to design appropriate types of control activities for the entity's internal control system. Control activities help management fulfill responsibilities and address identified risk responses in the internal control system. Uniform Guidance 2 CFR 200.303(a) states “The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with 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).” Context The Williston Basin Public School District No.7 was unable to provide supporting documentation for 3 of the 5 ISI amounts totaling $6,391,442. All ISI items were selected for testing. Due to this, there is no projected error only a known error of $6,391,442 as all errors are related to these items. Repeat Finding No. Recommendation We recommend that Williston Basin Public School District No. 7 establishes proper internal controls and policies to ensure they are maintaining proper support documentation for all federal grants. Williston Basin Public School District No. 7’s Response See Corrective Action Plan.

Corrective Action Plan

2023-013 – EDUCATION STABILIZATION FUND - LACK OF SUPPORT OVER ESSER FUNDS – ALN 84.425 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 was unable to provide supporting documentation for journal entries that were done to reallocate payroll. There were 3 journal entries totaling $6,391,442 that were completed at year end to move salaries into the Education Stabilization Fund program that did not have documentation to support the salary expenditures. Management’s Response: We agree. WBSD#7 created a new Grants Coordinator position in July 2023 with one of the specific responsibilities for that position being oversight of all Federal programs. This oversight responsibility includes monitoring expenditures to ensure all expenditures are allowable within the parameters of each program and also that proper documentation for those expenditures has been maintained. It has taken the district some time to get this area cleaned up. Anticipated Completion Date: FY 2025

Categories

Allowable Costs / Cost Principles Material Weakness Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1223215 2023-012
    Material Weakness Repeat
  • 1223217 2023-014
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 AMERICAN RESCUE PLAN - ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF (ARP ESSER) $6.81M
84.425 ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF (ESSER) FUND $2.20M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $1.44M
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $433,633
16.071 SCHOOL VIOLENCE PREVENTION PROGRAM $335,021
84.371 COMPREHENSIVE LITERACY DEVELOPMENT $261,610
10.555 NATIONAL SCHOOL LUNCH PROGRAM $242,266
10.553 SCHOOL BREAKFAST PROGRAM $215,714
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $212,825
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $158,625
84.425 AMERICAN RESCUE PLAN - ELEMENTARY AND SECONDARY SCHOOL EMERGENCY RELIEF - HOMELESS CHILDREN AND YOUTH $84,345
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $77,385
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $18,270
10.560 STATE ADMINISTRATIVE EXPENSES FOR CHILD NUTRITION $10,222
84.369 GRANTS FOR STATE ASSESSMENTS AND RELATED ACTIVITIES $9,106
10.579 CHILD NUTRITION DISCRETIONARY GRANTS LIMITED AVAILABILITY $5,454