Finding No.: 2024-018 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Cluster (IDEA) Federal Award No.: H027A220011-22A, H027A220011-23A, H027A220011-24A Area: Activities Allowed or Unallowed Area: Allowable Costs/Cost Principles Questioned Costs: $338,289 Criteria: Federal program expenditures should be necessary and reasonable for the performance of the Federal award, in accordance with activities allowed or unallowed and allowable cost/cost principles requirements, and be directly related to, and in accordance with, program intent and objectives. 34 CFR §300.202(a)(2) states that a Local Educational Agency (LEA) must use IDEA Part B funds only to pay the excess costs of providing special education and related services for children with disabilities. Excess costs are those costs for the education of an elementary school or secondary school student with a disability that are in excess of the average annual per student expenditure in an LEA during the preceding school year. Appendix A to 34 CFR Part 300 provides detailed guidance for calculating the average per pupil expenditures and the minimum average amounts that the LEA must spend before using IDEA funds. Furthermore, 2 CFR §200.303(a) states that a recipient of a Federal award 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. These internal controls should align with the 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). Condition 1: Of the 51 payroll transactions tested, aggregating $26,011 of $1,575,769 in total payroll program expenditures we noted the following: 1. For 35 (or 69%) representing 26 employees, the employment contracts were not available for examination. As a result, we were unable to determine whether the salaries charged to the grant during the year were allowable and necessary. Section 19 of the employment contracts available for examination states that the Republic of the Marshall Islands is not obligated to provide continued employment after the current contract term ends. Item # Employee # Expenditure Amount Questioned Cost 1 4203689 $ 1,245 $ 1,245 2 4234191 8,179 8,179 3 4204796 15,378 15,378 4 4253491 12,912 12,912 5 4241920 15,105 15,105 6 4210451 14,288 14,288 7 4232073 7,868 7,868 Item # Employee # Expenditure Amount Questioned Cost 8 4234362 8,120 8,120 9 4245585 15,664 15,664 10 4207667 29,874 29,874 11 4242073 7,933 7,933 12 4222746 7,868 7,868 13 4223509 17,676 17,676 14 4220351 8,292 8,292 15 4218541 9,031 9,031 16 4238120 7,934 7,934 17 4209657 24,132 24,132 18 4241470 7,934 7,934 19 4207438 16,219 16,219 20 4234035 15,105 15,105 21 4249967 4,354 4,354 22 4241373 3,183 3,183 23 4219227 25,142 25,142 24 4235558 6,734 6,734 25 4216083 22,023 22,023 26 4200409 25,674 25,674 $ 337,867 $ 337,867 2. For 4 (or 8%), leave hours were not supported by an approved leave form: Item # Employee # PPE Leave Hours Expenditure Amount Questioned Cost 1 4239915 12/30/2023 48 $ 157 $ 157 2 4248388 01/13/2024 32 154 154 3 4239915 05/04/2024 8 26 26 4 4062594 09/07/2024 8 85 85 $ 422 $ 422 Condition 2: Excess cost requirements under IDEA Part B are not met, as the entity did not perform or document the required excess cost calculation prior to charging expenditures to the program. Cause: RepMar did not effectively maintain documentation to support expenditures charged to federal programs and did not effectively monitor the validity and allowability of expenditures, including obtaining and retaining sufficient documentation to support payroll transactions. In addition, Public School System (PSS) did not establish and implement effective internal controls to facilitate compliance with IDEA Part B program‑specific requirements. Specifically, program personnel were not aware of the excess cost requirement under Appendix A to 34 CFR Part 300 and, as a result, did not perform or document the required excess cost calculation prior to charging expenditures to the program. Effect or Potential Effect: RepMar is in noncompliance with activities allowed or unallowed and allowable cost/cost principles requirements. The reportable questioned cost is $338,289. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: Responsible personnel should strengthen monitoring controls so that expenditures are verified for validity and allowability. In addition, PSS management should establish and implement procedures to facilitate compliance with IDEA Part B requirements, including the preparation and documentation of the excess cost calculation in accordance with Appendix A to 34 CFR Part 300 prior to charging expenditures to the program. Views of Responsible Officials: Condition 1-1. Due to structural damages to the Payroll office, files were transferred from there to the warehouse for storage. After numerous attempts to recover the files, the payroll staff were not able to do so within the given time period. Effective October 2025, the Payroll team has been attaching new employee contracts to the payslips in Bisan. PSC's HRMIS already stored the scanned PAFs of employees. The PSS has now acquired the Orange Human Resource Management System, which will also make contracts available electronically. Condition 1-2. PSS Response: PSS Management acknowledges the finding. While leave requests were generally submitted and recorded, we recognize that approved leave forms were not consistently maintained to support all leave hours charged during the audit period. To address this finding, beginning in FY2027, PSS will implement the Orange Human Resource Management System, which will transition the leave request process from a paper-based system to an electronic system. This will create a complete electronic audit trail for all leave requests submitted by PSS employees on islands with internet access. As internet connectivity continues to expand through solar power and Starlink installations, additional schools and offices will transition to the electronic system, with full implementation across all PSS locations targeted by the end of FY2028. In addition, the Finance and Audit Compliance Specialist will conduct periodic compliance reviews to verify that leave requests are properly approved, documented, and retained in accordance with PSS policies and applicable grant requirements. Any deficiencies identified during these reviews will be communicated promptly to management so that corrective action can be taken. MOF response: Additionally, effective FY2025, the Ministry of Finance requires all ministries to submit leave forms for all annual and sick leave taken, regardless of the number of hours & days. The Ministry of Finance issued a clarifying memorandum on July 29, 2025. Condition 2. These costs were incurred to cover the retirees' annual leave lump-sum payments. Related cost calculation of the excess will be submitted to the grantor for approval moving forward.