Finding 1240438 (2025-004)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-10-14
Audit: 414946
Organization: Guam Department of Education (GU)

AI Summary

  • Core Issue: GDOE failed to report accurate expenditures in the FNS-777 Financial Status Reports, leading to significant variances from accounting records.
  • Impacted Requirements: Noncompliance with 7 CFR 226.7(d) for timely and accurate financial reporting and with the Transparency Act for subaward reporting.
  • Recommended Follow-Up: Implement stronger controls to ensure compliance with reporting requirements for both FNS-777 and subawards to avoid future discrepancies.

Finding Text

Finding No.: 2025-004 – Reporting Identification of the federal program: Federal Agency: U.S. Department of Agriculture AL No. and Title: 10.555 Child Nutrition Cluster Federal Award No.: 7GU300GUB Criteria or specific requirement (including statutory, regulatory or other citation): 7 CFR 226.7(d) states: Each State agency shall also submit to FNS a quarterly Financial Status Report (FNS-777) on the use of Program funds. Such reports shall be postmarked and/or submitted no later than 30 days after the end of each fiscal year quarter. Obligations shall be reported only for the fiscal year in which they occur. A final Financial Status Report for each fiscal year shall be postmarked and/or submitted to FNS within 120 days after the end of the fiscal year. FNS shall not be responsible for reimbursing unpaid Program obligations reported later than 120 days after the close of the fiscal year in which they were incurred. Further, financial reports should be traceable to accounting records that support the audited financial statements and the Schedule of Expenditures of Federal Awards. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). 2 CFR Appendix-A-to-Part-170(a)(1) states: (1) Applicability. Unless the recipient is exempt as provided in paragraph (d) of this award term, the recipient must report each subaward that equals or exceeds $30,000 in Federal funds for a subaward to an entity or Federal agency. The recipient must also report a subaward if a modification increases the Federal funding to an amount that equals or exceeds $30,000. All reported subawards should reflect the total amount of the subaward. Conditions: 1. We noted variances between the expenditures reported in Financial Status Report FNS 777 Quarter 1 Report against the underlying accounting records as summarized below: FY25 QTR 1 (10/01/24 - 12/30/24) Total per Expenditure Details Over (Under) Reported variance STATUS OF FUNDS PROGRAMS/FUNCTIONS/ACTIVITIES Total outlays this report period $2,344,464 $5,350,607 ($3,006,143) Less: Program income credits - - - Net outlays this report period (Line b minus line c) 2,344,464 5,350,607 ( 3,006,143) Net outlays to date (Line a plus line d) 2,344,464 5,350,607 (3,006,143) Less: Non-Federal Share of outlays - - - Total Federal share of outlays (Line e minus line f) 2,344,464 5,350,607 (3,006,143) Total unliquidated obligations 3,107,529 1,669,399 1,438,130 Less: Non-Federal Share of unliquidated obligations shown on line h - - - Federal share of unliquidated obligations 3,107,529 1,669,399 1,438,130 Total Federal share of outlays and unliquidated obligations 5,451,993 7,020,006 (1,568,013) Total cumulative amount of Federal fund authorized 3,967,521 3,950,885 16,636 Unobligated balance of Federal funds ($1,484,472) ($3,069,121) $ 1,584,649 2. We noted variances between the expenditures reported in Financial Status Report FNS 777 Quarter 3 Report against the underlying accounting records as summarized below: FY25 QTR 3 (04/01/25 - 06/30/25) Total per Expenditure Details Over (Under) Reported variance STATUS OF FUNDS PROGRAMS/FUNCTIONS/ACTIVITIES Net outlays previously reported $ 9,643,180 $11,537,658 ($1,894,478) Total outlays this report period 1,510,303 3,264,946 ( 1,754,643) Less: Program income credits - - - Net outlays this report period (Line b minus line c) 1,510,303 3,264,946 ( 1,754,643) Net outlays to date (Line a plus line d) 11,153,483 14,802,604 ( 3,649,121) Less: Non-Federal Share of outlays - - - Total Federal share of outlays (Line e minus line f) 11,153,483 14,802,604 ( 3,649,121) Total unliquidated obligations 3,459,149 3,277,821 181,328 Less: Non-Federal Share of unliquidated obligations shown on line h - - - Federal share of unliquidated obligations 3,459,149 3,277,821 181,328 Conditions, continued: FY25 QTR 3 (04/01/25 - 06/30/25) Total per Expenditure Details Over (Under) Reported variance Total Federal share of outlays and unliquidated obligations 14,612,632 18,080,425 (3,467,793) Total cumulative amount of Federal fund authorized 15,910,166 15,871,080 39,086 Unobligated balance of Federal funds $ 1,297,534 ($ 2,209,345) $ 3,506,879 3. Subawards are not reported in FSRS, as follows: Transactions Tested Subaward Not Reported Dollar Amount of Tested Transactions Subaward Not Reported 3 3 $744,643 $744,643 Cause: GDOE did not enforce controls over compliance with the applicable reporting requirement relative to Financial Status Report FNS 777. Moreover, GDOE lacks controls over compliance with applicable reporting requirements relative to Federal Funding Accountability and Transparency Act. Effect or Potential Effect: GDOE is in noncompliance with applicable reporting requirements. Questioned Costs: Not applicable. No questioned cost is presented as the non-compliance was related to reporting requirements. Context: We identified four quarterly FNS-777 Financial Status Reports required to be submitted during the year. We tested two quarterly reports. The samples were statistically valid. Variances between the expenditures reported and underlying accounting records were noted for all two quarterly reports tested. Moreover, for all 3 (or 100%) subawards tested, subawards are not reported in FSRS. Identification as a repeat finding, if applicable: 2024-004 Recommendation: Responsible personnel should implement controls over compliance with applicable reporting requirements relative to submitting accurate reporting of FNS-777. Moreover, GDOE should establish controls over compliance with applicable reporting requirements relative to Federal Funding Accountability and Transparency Act. Views of Responsible Officials: GDOE agrees with the finding and provides details in its Corrective Action Plan.

Corrective Action Plan

Finding No.: 2025-004 Federal Agency: U.S. Department of Agriculture AL Program: 10.555 Child Nutrition Cluster Federal Award No.: 7GU300GUB Area: Reporting Questioned Costs: $0 Views of Auditee and Corrective Actions GDOE acknowledges the finding. The corrective action addresses the variances in the first and third quarter FY 2025 FNS-777 reports, related accounting records and reconciliations, and the subawards that were not reported as required by the Federal Funding Accountability and Transparency Act. Plan of action and completion date: The GDOE Business Office will reconcile applicable MUNIS expenditures against CNP claim and reimbursement records, draw requests, ASAP draw confirmations, bank receipts, MUNIS revenue entries, accounts receivable and other applicable receivable records, and documented adjustments. Differences among amounts requested, drawn, received, and recorded in MUNIS will be documented and resolved. Each quarterly FNS-777 will be supported by a line-by-line workpaper prepared by the GDOE Business Office and provided to GDOE FNSMD CNP, identifying the authoritative source for prior-period amounts, current period outlays, valid unliquidated obligations, federal funds authorized, adjustments, and the unobligated balance. An ASAP draw alone will not determine whether an amount is reported as an outlay or an unliquidated obligation. An earned reimbursement that has not yet been drawn may be recorded as a receivable for reconciliation purposes but will not automatically be reported as an unliquidated obligation. Separately, the GDOE Business Office will establish its controls under 2 CFR part 170 to identify and timely report each CNP subaward of $30,000 or more in the applicable federal system (FSRS). In coordination with GDOE FNSMD CNP, the GDOE Business Office review the FY 2025 subawards, submit any permitted late or corrective reports, and retain evidence of submission or final disposition. Plan to monitor and responsible officials: GDOE FNSMD CNP will conduct monthly follow-ups with the GDOE Business Office to monitor progress and ensure that activities remain on track for completion within the established timelines. Reconciliations will be performed quarterly to ensure that all financial transactions for the quarter are accurately recorded, supported, and ready for required reporting. The GDOE FNSMD CNP Administrator, Anthony S. Monforte and CNP Program Coordinator, Franklin J. Cruz will oversee the reconciliation and reporting controls. The Controller or designated GDOE Business Office official will be responsible for ASAP draws, MUNIS records, cash receipts, receivables, draw confirmations, federal subaward reporting, and supervisory review. The corrective actions will be implemented by October 1, 2026, and first applied to the FY 2027 first quarter reporting cycle. For each quarterly filing, GDOE FNSMD CNP will retain the completed reconciliation, preparer and reviewer sign-offs, and evidence of supervisory review, including supporting documentation provided by the GDOE Business Office, as applicable. The responsible officials will also document an annual review of the control process.

Categories

Reporting Subrecipient Monitoring School Nutrition Programs Matching / Level of Effort / Earmarking Program Income

Other Findings in this Audit

  • 1240437 2025-003
    Material Weakness Repeat
  • 1240439 2025-005
    Material Weakness Repeat
  • 1240440 2025-006
    Material Weakness Repeat
  • 1240441 2025-007
    Material Weakness Repeat
  • 1240442 2025-006
    Material Weakness Repeat
  • 1240443 2025-008
    Material Weakness Repeat
  • 1240444 2025-009
    Material Weakness Repeat
  • 1240445 2025-006
    Material Weakness Repeat
  • 1240446 2025-008
    Material Weakness Repeat
  • 1240447 2025-010
    Material Weakness Repeat
  • 1240448 2025-011
    Material Weakness Repeat
  • 1240449 2025-012
    Material Weakness Repeat
  • 1240450 2025-013
    Material Weakness Repeat
  • 1240451 2025-016
    Material Weakness Repeat
  • 1240452 2025-014
    Material Weakness Repeat
  • 1240453 2025-015
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 EDUCATION STABILIZATION FUND $104.55M
84.403 CONSOLIDATED GRANT TO THE OUTLYING AREAS $31.97M
10.555 NATIONAL SCHOOL LUNCH PROGRAM $18.92M
84.027 SPECIAL EDUCATION GRANTS TO STATES $17.63M
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $1.32M
84.372 STATEWIDE LONGITUDINAL DATA SYSTEMS $829,750
10.558 CHILD AND ADULT CARE FOOD PROGRAM $729,155
10.560 STATE ADMINISTRATIVE EXPENSES FOR CHILD NUTRITION $422,772
84.371 COMPREHENSIVE LITERACY DEVELOPMENT $413,244
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $399,417
12.U01 ARMY JROTC $383,083
93.092 AFFORDABLE CARE ACT (ACA) PERSONAL RESPONSIBILITY EDUCATION PROGRAM $318,367
12.U02 AIR FORCE JROTC $283,717
93.600 HEAD START $254,036
84.323 SPECIAL EDUCATION - STATE PERSONNEL DEVELOPMENT $224,613
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $164,642
12.U03 MARINE JROTC $153,980
10.541 CHILD NUTRITION-TECHNOLOGY INNOVATION GRANT $146,754
10.579 CHILD NUTRITION DISCRETIONARY GRANTS LIMITED AVAILABILITY $101,212
10.645 FARM TO SCHOOL STATE FORMULA GRANT $68,969
10.574 TEAM NUTRITION GRANTS $59,033
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $43,322