Finding 1227529 (2025-006)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-08-21

AI Summary

  • Issue: A BABA waiver was not obtained before funding was received for a project using materials that require it.
  • Requirements Impacted: Compliance with BABA domestic sourcing rules as mandated by the IIJA.
  • Follow-up: Implement procedures to ensure all compliance requirements are met before drawing down funds for future projects.

Finding Text

Finding Number: 2025-006 Federal Agency: U.S. Department of Housing and Urban Development Cluster/Program(s): Community Project Funding Assistance Listing Number(s): 14.251 Compliance Requirement: Special Tests and Provisions Type of Finding: Significant Deficiency – Internal Control over Compliance Compliance Finding Statement of Condition: A Build America, Buy America (BABA) waiver was not received prior to receiving project funding, despite the project involving materials subject to BABA domestic content requirements. Criteria: The Infrastructure Investment and Jobs Act (IIJA) and implementing federal guidance require that all covered infrastructure projects comply with BABA domestic sourcing requirements, unless a formal waiver is approved by the applicable federal awarding agency prior to obligation of funds. Cause: Grant funds were drawn prior to the final approval of the BABA waiver. Effect: Failure to obtain the BABA waiver could result in the loss of future federal funding. Known Questioned Costs: None Likely Questioned Costs: None Recommendations: We recommend that the School Unit implement procedures to ensure all requirements are met on future projects/grants prior to drawdowns being submitted.

Corrective Action Plan

Management Response/Corrective Action Plan: The District was awarded funding with the Congressional funds with all parties aware the project would be substantially completed before funding would be finalized. Much of the wait was due to the review and approval of the Build America, Buy America (BABA) waiver. Unfortunately, the agency that trained MSAD54 staff on the process recommended for the request of funds to be made. Subsequent all funding requests were approved by HUD representatives prior to receiving the BABA waiver. The Superintendent recognized the potential error and contacted HUD who worked with the District to correct their mistake and return funds. The waiver has since been approved, and all funds have been drawn down.

Categories

Special Tests & Provisions Cash Management Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1227515 2025-002
    Material Weakness Repeat
  • 1227516 2025-002
    Material Weakness Repeat
  • 1227517 2025-002
    Material Weakness Repeat
  • 1227518 2025-003
    Material Weakness Repeat
  • 1227519 2025-003
    Material Weakness Repeat
  • 1227520 2025-003
    Material Weakness Repeat
  • 1227521 2025-003
    Material Weakness Repeat
  • 1227522 2025-003
    Material Weakness Repeat
  • 1227523 2025-004
    Material Weakness Repeat
  • 1227524 2025-004
    Material Weakness Repeat
  • 1227525 2025-004
    Material Weakness Repeat
  • 1227526 2025-004
    Material Weakness Repeat
  • 1227527 2025-004
    Material Weakness Repeat
  • 1227528 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.251 Community Project Funding $1.94M
84.010 Title IA Disadvantaged $1.77M
10.555 National School Lunch Program $802,802
84.027 Local Entitlement $700,575
84.425 Elementary & Secondary School Emergency Relief Fund III - COVID 19 $437,484
10.553 School Breakfast Program $304,721
84.287 After School Learning Centers $295,170
84.184 School Safely National Activities $272,229
84.425 Literacy Grant - COVID 19 $263,917
10.558 Child and Adult Care Food Program $181,600
10.555 National School Lunch Program - Donated Commodities $137,791
84.048 Carl Perkins - Secondary $111,234
84.002 Adult Basic Education $107,228
84.367 Title IIA - Supporting Effective Instruction $102,835
10.582 Fresh Fruit and Vegetable Program $100,605
21.027 CTE Personnel Infrastructure and Equipment - COVID 19 $99,670
21.027 Maine Jobs and Recovery Plan - COVID 19 $80,586
84.425 ARP Summer Learning and Enrichment - COVID 19 $73,780
84.010 Title IA - Summer School $66,655
10.559 Summer Food Service Program $64,680
84.425 Maine Outdoor Learning Intiative - COVID 19 $39,405
21.027 Pre-k Expansion - COVID 19 $33,000
84.010 Title IA Disadvantage - CIPS $31,641
10.579 Child Nutrition Discretionary Grants Limited Availability $19,804
84.048 Carl Perkins - CTE $14,814
84.173 Preschool $11,591