Finding Text
2024-009 – TITLE I –INADEQUATE SUPPORTING DOCUMENTATION – ALN 84.010 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE FINDING TYPE: MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Finding 2024-009 Federal Program: Title I – Grants to LEA’s ALN: 84.010 Federal Award Number(s) and Year(s): S010A240034, 2024 Federal Agency: U.S. Department of Education Pass Through Agency: North Dakota Department of Public Instruction Questioned Cost: $136,372 Condition Williston Basin Public School District No. 7 was unable to provide supporting documentation for expenses charged to the Title I program. 54 of the 60 expenditures we sampled did not have any support, leaving them with known questioned costs of $136,372. Effect Williston Basin Public School District No. 7 may have charged unallowable expenditures to the grant program. Cause Williston Basin Public School District No. 7 did not maintain support documentation for all expenditures charged to the Title I grant. In addition, there was no evidence of approval for these transactions. Criteria 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).” 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. Context Williston Basin Public School District No. 7 had total Title I expenditures of $1,527,887 in fiscal year 2024. Projected questioned costs identified during testing totaled $1,463,906. Repeat Finding Yes. See finding 2023-014. Finding 2022-007 was reported in previous years. 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