Finding 1237749 (2023-009)

Material Weakness Repeat Finding
Requirement
A
Questioned Costs
-
Year
2023
Accepted
2026-09-28

AI Summary

  • Core Issue: The District lacks adequate documentation for payroll and expenditures related to Title I, ESSER, and Impact Aid grants, leading to unsupported costs.
  • Impacted Requirements: Compliance with Uniform Guidance requires all expenditures to be allowable, properly documented, and supported; this is currently not being met.
  • Recommended Follow-Up: Implement formal procedures for documentation and use a centralized electronic system to ensure all grant-related costs are adequately supported and retained.

Finding Text

Material Weakness 2023-009 Unsupported Expenditures - Title I, Impact Aid and ESSER Grants Federal Program and Award: Title I, Impact Aid and ESSER Grants The objective of the Title I Grants (Assistance Listing 84.010A) is to provide financial assistance to local educational agencies (LEAs) to ensure that all children, particularly those from low-income families, have a fair, equitable, and high-quality education and the opportunity to meet challenging state academic standards. The objective of the COVID-19 ESSER Grants (Assistance Listing 84.425D) is to provide emergency relief funding to state educational agencies (SEAs) and LEAs to address the impact of the Coronavirus Disease 2019 (COVID-19) pandemic on the elementary and secondary schools. The objective of the Impact Aid Program (Assitance Listing 84.041 A) is to provide financial assistance to LEAs that experience a loss of local revenue due to the presence of tax-exempt federal property of the enrollment of federally connected students, ensuring such districts can maintain adequate educational services. CFDA Numbers: 84.010A, 84.425D, and 84.041A Pass-Through Entity: Only the Title I grant , Passed through the State of Wyoming Department of Education. Subrecipient Information: None Criteria The Uniform Guidance (2 CFR Part 200), as applicable to federal prgrams including Title I Grants (Assistance Listing 84.010A), COVID-19 ESSER Grants (Assistance Listing 84.425D), and Impact Aid (Assistance Listing 84.041A), requires that expenditures charged to federal awards be allowable, properly documented, and adequately supported. Costs must be necessary, reasonable, and allocable to the respective program, and records sufficient to support the nature and purpose of each expenditure must be maintained. Type of Compliance Requirement: Allowable Costs Direct or Indirect: Direct and Indirect Condition The District recorded payroll costs to federal programs, including Title I, ESSER, and Impact Aid, through journal entries; however, sufficient documentation was not maintained to support the allowability of these costs. Specifically, the District could not provide support identifying the employees compensated, their job responsibilities, or the services performed. In many cases, supporting documentation for the journal entries charged to the grants was not available, including the methodology, supporting documentation for indirect costs charged to the federal programs was not available, including the methodology used to calculate and allocate such costs. We also noted instances where invoices and supporting documentation for certain equipment purchases could not be located, limiting the District's ability to demonstrate that these costs were allowable and properly supported. Cause The District did not have personnel with the necessary skills, knowledge, and experience to properly maintain accounting records and comply with federal grant requirements. As a result, adequate procedures were not in place to ensure that grant expenditures, including payroll and indirect cots, were properly supported and documented. In addition, there was insufficient communication and coordination between District personnel and external resources, limiting the District's ability to maintain adequate records and support for grant activity. Effect During the current year audit, a significant portion of the items tested lacked adequate supporting documentation limiting our ability to verify that expenditures were allowable and properly supported. This deficiency continues to represent a breakdown in internal controls over financial reporting and compliance with federal grant requirements. The business manager in place during the 2022 audit year has since been replaced as of the end of 2024. Questioned Costs $848,464 of expenditures tested lacked adequate supporting documentation; therefore, the allowability of these costs could not be determined for the Title I Grants. $1,099,212 of expenditures tested lacked adequate supporting documentation; therefore, the allowability of these costs could not be determined for the ESSER Grants. $219,179 of expenditures tested lacked adequate supporting documentation; therefore, the allowability of these costs could not be determined for the Impact Aid Grants. Prior Year Finding: Yes, Education Stabilization Fund Expenditures. Recomendation The District should strengthen its internal control system over federal expenditures by implementing formal prcedures to ensure all costs are adequately documented, supported, and retained in accordance with Uniform Guidance requirements. The District should utilize a centralized electronic document management system to maintain records in an organized and accessible manner. Mangagement should ensure that documentation is consistently retained and reviewed to support the allowability, accuracy, and completeness of all grant-related expenditures.

Corrective Action Plan

2023-009 Unsupported Expenditures - Title I, Impact Aid, and ESSER Grants - Repeat Finding Individual responsible: Business Manger and Federal Grants Director Anticipated completion date: FY 2026 Corrective action plan: The District acknowledges the deficiencies in documentation and reporting for federal grant expenditures. At this time, ESSER funds are no longer available; therefore, additional supporting documentation for those programs will not be developed. However, the District has implemented corrective actions to imporve processes over other federal programs going forward. Since fiscal year 2022, the District engaged an external accounting firm to assist with grant reporting and cash request processes. This firm implemented a process to request funds on a quarterly basis and assisted in organizing available grant information. Effective July 1, 2025, the District hired a Federal Grants Director to work in cordination with the Business Manager to complete the grant reconciliation process and implement formal procedures for tracking grant expenditures and cash requests. These procedures include maintaining documentation for each expenditure, tracking the timing and support for drawdowns, and ensuring that all activity is properly recorded and supported. Upon full implementation of these procedures, the Distirct will transition to submitting cash requests on a monthly basis and maintaining complete and accessible documentation to support all reported amounts. The District expects these improvements to resolve the finding for current and future federal programs.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Procurement, Suspension & Debarment Material Weakness Reporting

Other Findings in this Audit

  • 1237741 2023-009
    Material Weakness Repeat
  • 1237742 2023-010
    Material Weakness Repeat
  • 1237743 2023-009
    Material Weakness Repeat
  • 1237744 2023-010
    Material Weakness Repeat
  • 1237745 2023-009
    Material Weakness Repeat
  • 1237746 2023-010
    Material Weakness Repeat
  • 1237747 2023-009
    Material Weakness Repeat
  • 1237748 2023-010
    Material Weakness Repeat
  • 1237750 2023-010
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.041 IMPACT AID $5.40M
84.425 EDUCATION STABILIZATION FUND $1.35M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $735,469
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $150,131
10.555 NATIONAL SCHOOL LUNCH PROGRAM $148,131
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $141,756
10.553 SCHOOL BREAKFAST PROGRAM $59,990
84.027 SPECIAL EDUCATION GRANTS TO STATES $45,051
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $16,006
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $3,727