Finding 1240444 (2025-009)

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

AI Summary

  • Core Issue: GDOE liquidated a federal award obligation after the approved deadline, violating compliance requirements.
  • Impacted Requirements: Noncompliance with 2 CFR 200.344(c) regarding timely liquidation of financial obligations.
  • Recommended Follow-Up: GDOE should create and enforce internal control policies to ensure obligations are liquidated within the required timeframe.

Finding Text

Finding No.: 2025-009 – Period of Performance Identification of the federal program: Federal Agency: U.S. Department of Education AL No. and Title: 84.181 Special Education - Grants for Infants and Families Federal Award No.: H181A220008 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.344(c) states: The recipient must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the conclusion of the period of performance. When justified, the Federal agency or pass-through entity may approve extensions for the recipient or subrecipient. Condition: GDOE liquidated an obligation of a federal award after the approved liquidation end date. Cause: GDOE lacks established internal control policies and procedures relating to timely liquidation of obligations. Effer of potential effect: GDOE is in noncompliance with applicable period of performance requirements. Questioned Costs: $32,733 Context: We identified 150 transactions recorded near the end of the period of performance totaling $364,749. We tested 36 transactions totaling $101,537. The samples were statistically valid. Of 36 transactions tested, one transaction (or 3%) was liquidated after the approved liquidation end date which relates to the only cost charged to grant year 2022 with POP end date of September 30, 2024 and liquidation end date of March 10, 2026. All other samples were for costs charged to grant year 2023 with POP end date of September 30, 2025 and liquidation end date January 30, 2026. The exception is an isolated instance. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: GDOE should establish and implement internal control policies and procedures over compliance with applicable period of performance requirements, specifically, ensuring liquidation of obligations occur within the allowable time period. View of Responsible Officials: GDOE agrees with the condition, however, does not agree with the cause and provides details in its Corrective Action Plan. Conclusion: GDOE’s existing procedures are not suitably designed to ensure that liquidation of the obligation occurs within the allowable time period. The cause of the finding remains.

Corrective Action Plan

Finding No.: 2025-009 Federal Agency: U.S. Department of Education AL Program: 84.181 Special Education – Grants for Infants and Families Federal Award No.: H181A220008 Area: Period of Performance Questioned Costs: $32,733 Views of Auditee and Corrective Actions GDOE agrees with the condition but does not agree with the cause. Management notes that the exception represented one of 36 transactions selected for testing and was identified as an isolated instance. The 2022 grant was approved for a late liquidation and was only opened for a short period of time. Nevertheless, GDOE recognizes that all federal expenditures must be liquidated within the applicable timeframe and that adequate controls should be maintained to identify and resolve outstanding obligations before the expiration of the liquidation period. Management will strengthen its grant closeout monitoring procedures to reduce the risk of outstanding obligations remaining unresolved beyond applicable federal liquidation deadlines. Plan of action and completion date: GDOE will strengthen controls over the monitoring and timely liquidation of federal award obligations. GDOE will: 1. Perform periodic reviews of outstanding obligations and unpaid expenditures in advance of applicable liquidation deadlines. 2. Coordinate among Federal Programs Division, applicable program personnel, Procurement, receiving personnel, Accounts Payable, Financial Affairs and office in-charge of the drawdown to identify and resolve outstanding transactions before the liquidation deadline. 3. Establish escalation procedures for obligations that remain outstanding as the liquidation deadline approaches so that responsible personnel and management can take timely corrective action. 4. Evaluate the need for an extension request when circumstances prevent timely liquidation and an extension is permitted under applicable federal requirements. 5. Document the resolution of outstanding obligations and retain supporting documentation demonstrating that expenditures were liquidated within the applicable timeframe. 6. Periodically review grant closeout activity to identify recurring processing delays and implement additional corrective measures when necessary. Plan to monitor and responsible officials: The Federal Programs Division, applicable program management, and Financial Affairs Accounts Payable will be responsible for monitoring the implementation of corrective actions. Corrective actions will be initiated with the FY2026 grant closeout cycle, with ongoing monitoring thereafter.

Categories

Subrecipient Monitoring Period of Performance

Other Findings in this Audit

  • 1240437 2025-003
    Material Weakness Repeat
  • 1240438 2025-004
    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
  • 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