Finding 1227833 (2023-015)

Material Weakness Repeat Finding
Requirement
G
Questioned Costs
-
Year
2023
Accepted
2026-08-25

AI Summary

  • Core Issue: PSS failed to provide adequate documentation to show compliance with ARP-OA earmarking requirements for federal funds.
  • Impacted Requirements: Internal controls over financial documentation are lacking, leading to noncompliance with 2 CFR Section 200.303 and grant agreement terms.
  • Recommended Follow-Up: PSS should establish formal procedures to ensure earmarking allocations are clearly identified and that supporting documentation is organized and available for audits.

Finding Text

Finding No. 2023-015 Federal Agency: U.S. Department of Education AL Program: COVID-19 84.425A/84.425X Education Stabilization Fund Federal Award No.: S425A210001 and S425X210001 Area: Matching, Level of Effort, Earmarking Questioned Costs: Undeterminable Criteria: In accordance with 2 CFR Section 200.303, non-federal entities receiving federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with the terms and conditions in the Grant Agreement, the State Educational Agencies (SEA) will use (a) not less than twenty percent of its ARP-OA SEA allocation to carry out, directly or through subgrants or contracts, activities to address the academic impact of lost instructional time by supporting the implementation of evidence-based interventions; (b) a portion of their ARP-OA SEA allocation to carry out, directly or through subgrants to Local Educational Agencies (LEAs) or through contracts, the implementation of evidence-based summer enrichment programs; (c) and a portion of their ARP-OA SEA allocation to carry out, directly or through subgrants to LEAs or through contracts, the implementation of evidence-based comprehensive afterschool programs. Condition: PSS did not maintain or provide adequate supporting documentation to demonstrate compliance with the ARP-OA earmarking requirements. Specifically, PSS did not provide budgetary documentation evidencing that the required portions of ARP-OA funds were allocated and expended for allowable evidence-based interventions, summer enrichment programs and comprehensive afterschool programs. Questioned costs are undetermined as we are unable to quantify the extent of noncompliance. Cause: PSS does not have an effective internal control over financial documentation related to earmarked ARP-OA funds. PSS lacks established procedures to ensure that budget allocations and supporting record related to earmarking requirements are properly prepared, retained and readily available for audit and compliance reporting purposes. Effect or potential effect: PSS is in noncompliance with the earmarking requirements for the ARP-OA program. Questioned costs are undeterminable as we are unable to quantify the extent of noncompliance. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: PSS should strengthen internal controls over ARP‑OA earmarking compliance by establishing and implementing formal procedures to ensure that: 1. Required earmarking allocations are clearly identified in budgets; and 2. Supporting documentation is retained, organized, and readily available for audit and compliance review purposes. Views of Auditee and Corrective Action Plan: PSS does not agree with the finding. PSS has allocated and expended more than 20% on evidence-based interventions to address learning loss. Specifically, projects listed under the ARP expense report are mapped directly to learning loss categories (e.g. expenses for summer school, extended learning opportunities, high dosage tutors, etc.). Refer to PSS’ Corrective Action Plan for additional information. Auditor Response: The supporting documentation provided, including the ARPA-OA budget that was resubmitted, did not clearly identify the required earmarking allocations and related expenditures for evidence-based interventions, summer enrichment programs and comprehensive afterschool programs. Recalculation or verification of compliance with the earmarking requirements of the ARP-OA program could not be performed. The finding remains.

Corrective Action Plan

Finding No.: 2023-015 AL Program: COVID-19 84.425A/84.425X Education Stabilization Fund Area: Matching, Level of Effort, Earmarking Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management does not agree with the finding. PSS has allocated and expended more than 20% on evidence-based interventions to address learning loss. Specifically, projects listed under the ARP expense report are mapped directly to learning loss categories (e.g. expenses for summer school, extended learning opportunities, high dosage tutors, etc.). Based on this documentation, we request that the audit finding be revised to reflect compliance. Proposed Completion Date: Resolution in progress and on track for completion by August 2026. Name of Contact Person and Title: Contact: Jacqueline Che, Federal Programs Officer Email Address: jacqueline.che@cnmipss.org

Categories

Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1227814 2023-003
    Material Weakness Repeat
  • 1227815 2023-004
    Material Weakness Repeat
  • 1227816 2023-005
    Material Weakness Repeat
  • 1227817 2023-006
    Material Weakness Repeat
  • 1227818 2023-006
    Material Weakness Repeat
  • 1227819 2023-007
    Material Weakness Repeat
  • 1227820 2023-007
    Material Weakness Repeat
  • 1227821 2023-008
    Material Weakness Repeat
  • 1227822 2023-008
    Material Weakness Repeat
  • 1227823 2023-009
    Material Weakness Repeat
  • 1227824 2023-009
    Material Weakness Repeat
  • 1227825 2023-010
    Material Weakness Repeat
  • 1227826 2023-011
    Material Weakness Repeat
  • 1227827 2023-012
    Material Weakness Repeat
  • 1227828 2023-013
    Material Weakness Repeat
  • 1227829 2023-013
    Material Weakness Repeat
  • 1227830 2023-014
    Material Weakness Repeat
  • 1227831 2023-014
    Material Weakness Repeat
  • 1227832 2023-015
    Material Weakness Repeat
  • 1227834 2023-016
    Material Weakness Repeat
  • 1227835 2023-016
    Material Weakness Repeat
  • 1227836 2023-017
    Material Weakness Repeat
  • 1227837 2023-017
    Material Weakness Repeat
  • 1227838 2023-018
    Material Weakness Repeat
  • 1227839 2023-019
    Material Weakness Repeat
  • 1227840 2023-020
    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