Finding 1225535 (2024-003)

Material Weakness Repeat Finding
Requirement
F
Questioned Costs
-
Year
2024
Accepted
2026-08-03

AI Summary

  • Core Issue: The School purchased fixed assets exceeding the approved capitalization threshold without prior approval and failed to conduct required inventory checks.
  • Impacted Requirements: Non-compliance with 2 CFR part 200 regarding capital expenditures and property record maintenance.
  • Recommended Follow-Up: Implement procedures for obtaining necessary approvals for capital expenditures and establish a compliant inventory schedule.

Finding Text

Equipment and Real Property Management and Allowable Cost (Significant Deficiency) Federal Program: COVID-19 Education Stabilization Fund (ARP ESSER) – 84.425U Criteria: Pursuant to 2 CFR part 200 section 439, capital expenditures for equipment and other capital expenditures are allowable as direct cost, provided that items with a unit cost of $5,000 or the entity’s capitalization threshold have the prior written approval of the Federal awarding agency or pass-through entity. Furthermore, section 313(d)(1) specifies that property records must be maintained that include a description of the property, a serial or identification number, the source of funding for the property, who holds the title, the acquisition date, and cost of the property. An inventory of the property is required to be taken every two years. Condition: During testing it was noted the School purchased fixed assets over the capitalization threshold using ARP ESSER funds for assets which differed from the ones previously approved. No revised budgets were submitted to receive approval for these fixed assets. Additionally, an inventory of the fixed assets was not taken. Cause: There was confusion on the School’s part on needing to submit revised budgets and new pre-approvals for purchasing specific fixed assets that differed from what they were originally approved for. Also, the School was unaware of the inventory requirements. Effect or Potential Effect: Internal controls are not functioning as designed and the School is not in compliance with the equipment and real property management and allowable cost requirements of the program. Questioned Cost: $0 Context: The School was originally approved for specific fixed assets for ARP ESSER capital expenditures. The School then expended the funds on different capital assets which were not previously approved by the Pennsylvania Department of Education. This amounted to ARP ESSER capital expenditures of $89,359.72. An inventory of the fixed assets was not performed. Repeat Finding: This is not a repeat finding. Recommendation: The School should establish procedures to ensure all capital expenditures with grant funding is appropriately approved prior to purchase and property records are maintained in sufficient detail to allow for the adequate tracking of all equipment purchased with grant funds. The School should establish an inventory schedule in compliance with the Equipment and Real Property Management compliance requirements. View of Responsible Officials and Planned Corrective Action: There was confusion on the School’s part of needing revised budgets and new approvals for the change in planned capital expenditures. Often times grant filings were due prior to all instructions being received. Now that the School is fully aware of the capital expenditures requirements this should not occur again. The School was unaware of the required inventory tracking. This should not occur again.

Corrective Action Plan

Description of Finding: During testing it was noted the School purchased fixed assets over the capitalization threshold using ARP ES-SER funds for assets which differed from the ones previously approved. No revised budgets were submitted to receive approval for these fixed assets. Statement of Concurrence or Nonconcurrence: The School acknowledges the findings related to equipment purchases funded with ARP ESSER funds and recognizes the importance of complying with federal procurement, prior approval, inventory, and reporting requirements for equipment and capita lexpenditures. The School understands that capital expensitures for equipment require proper review and, when applicable, prior written approval from the federal awarding agency or pass-thorugh entity before purchase. Corrective Action: To address the finding, the School, with assistance from its contracted accounting and management firm, will strenghen procedures for identifying equipment and capital assests purchases funded with federal funds. The contracted accounting and management firm has a process in place for identifying equipment purhcases funded with federal awards and will assist the School in applying this process to federal grant purchases. Because the contracted accounting and management firm assists the School with the management of its federal grants, the firm will also assist the School with procurement, inventory, and reporting requirements related to federally funded equipment purchases. This sup-port will include reviewing proposed equipment purchases before purchase, identifying whether the purchase is included in an approved grant budget, determining whether budget revisions or prior approvals are required, and helping ensure that required approvals are obtained and documented before the purchase is made. The School will maintain property records for equipment purchased with federal funds. The School will also implement procedures to ensure that a physical inventory of federally funded equipment is performed at least once eve-ry two years, or more frequently if required by the applicable grant or School policy. The results of the inventory will be compared to the property records, and any discrepancies will be researched and resolved in a timely manner. For future federally funded equipment purchases, the School and the contracted accounting and management firm will review the approved grant budget and supporting grant documentation before the purchase is made. If the proposed equipment differs from the items previously approved, the School will submit any required budget revision or request for prior approval to the applicable pass-through entity before proceeding with the purchase.

Categories

Equipment & Real Property Management

Other Findings in this Audit

  • 1225523 2024-002
    Material Weakness Repeat
  • 1225524 2024-004
    Material Weakness Repeat
  • 1225525 2024-005
    Material Weakness Repeat
  • 1225526 2024-002
    Material Weakness Repeat
  • 1225527 2024-003
    Material Weakness Repeat
  • 1225528 2024-004
    Material Weakness Repeat
  • 1225529 2024-005
    Material Weakness Repeat
  • 1225530 2024-002
    Material Weakness Repeat
  • 1225531 2024-003
    Material Weakness Repeat
  • 1225532 2024-004
    Material Weakness Repeat
  • 1225533 2024-005
    Material Weakness Repeat
  • 1225534 2024-002
    Material Weakness Repeat
  • 1225536 2024-004
    Material Weakness Repeat
  • 1225537 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $149,847
84.027 SPECIAL EDUCATION GRANTS TO STATES $55,140
10.553 SCHOOL BREAKFAST PROGRAM $28,238
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $13,754
10.555 NATIONAL SCHOOL LUNCH PROGRAM $12,400
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $12,308
84.425 EDUCATION STABILIZATION FUND $3,615
10.649 PANDEMIC EBT ADMINISTRATIVE COSTS $653