Finding Text
Controls Over Allowable Cost/Activities Allowed U.S. Department of Education Education Stabilization Fund ALN 84.425 Title I ALN 84.010 Criteria: Uniform Guidance (2 CFR Part 200) requires that costs charged to federal awards be allowable, reasonable, and properly authorized, and that nonfederal entities establish effective internal controls over federal awards to provide reasonable assurance of compliance with federal requirements. Costs charged to Education Stabilization Fund (ESSER) and Title I grants should be supported by appropriate documentation and approved to ensure the activities performed are allowable under the respective grant programs. Condition: During our testing of internal controls over allowable costs and activities related to expenses charged to ESSER and Title I grants, we noted that controls over the approval were not operating effectively. Specifically, charges to these grant programs were not consistently supported by documented supervisory approval verifying that the employees’ activities and services performed or good provided were allowable and aligned with the objectives of the respective grants. Cause: This condition was caused by the lack of formalized approval procedures over grant-funded costs and insufficient documentation requirements to demonstrate management’s review of allowability and programmatic alignment. Effect: Without adequate approval controls over costs charged to ESSER and Title I grants, the School Board is exposed to an increased risk that unallowable or unsupported costs could be charged to federal programs. This may result in questioned costs, required repayment of grant funds, or increased oversight by federal or state granting agencies. Recommendation: We recommend that management implement formal approval and documentation procedures for all costs charged to ESSER and Title I grants. Such procedures should include documented supervisory review verifying that charges are allowable, reasonable, and directly related to approved grant activities prior to charging costs to the grant. Repeat Finding: Yes. 2024-020 View of Responsible Officials: Beginning with FY2026, a new Federal Programs Supervisor/Director was hired by the Board, and a Fiscal Administrator was appointed on August 27, 2025. These new designees will ensure that all federal programs operate within their allowable costs, activities, procurement, suspension and debarment guidelines. Approved budgets will be reviewed and complied with as purchases are made and reviewed monthly thereafter.