Finding 1240445 (2025-006)

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 lacks effective internal controls to ensure obligations are liquidated within the required time frame.
  • Impacted Requirements: This finding violates 2 CFR 200.303, which mandates proper management of federal awards.
  • Recommended Follow-Up: GDOE should develop and implement new internal control procedures to comply with period of performance requirements.

Finding Text

Finding No.: 2025-006 – Period of Performance Identification of the federal program: Federal Agency: U.S. Department of Education AL No. and Title: 84.027 Special Education Cluster (IDEA) 84.181 Special Education - Grants for Infants and Families 84.403 Consolidated Grants Federal Award No. H027A230013 H181A220008, H181A230008 S403A220002, S403A230002 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR 200.303 states: The recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient 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: GDOE does not have internal controls to ensure that liquidation of the obligation occurs within the allowable time period. Cause: GDOE’s internal control policies and procedures in place are not suitably designed to ensure that liquidation of the obligation occurs within the allowable time period. Effect or potential effect: GDOE did not comply with the requirements of 2 CFR 200.303. Questioned Costs: Not applicable. The finding relates solely to an internal control deficiency. Context: We performed inquiries and walkthrough of GDOE’s process for complying with the period of performance requirements. Based on procedures performed, we have not identified internal controls addressing the timely liquidation of obligations required by the compliance requirement. 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 disagrees with the condition of the finding, however, acknowledges the need to update its SOP and has provided 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 finding remains.

Corrective Action Plan

Finding No.: 2025-006 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Cluster (IDEA) 84.181 Special Education – Grants for Infants and Families 84.403 Consolidated Grants Federal Award No.: H027A230013 H181A220008, H181A230008 S403A220002, S403A230002 Area: Period of Performance Questioned Costs: $0 Views of Auditee and Corrective Actions GDOE does not agree with the condition that “GDOE does not have internal control to ensure that liquidation of the obligation occurs within the allowable period of time”. GDOE has existing procedures which includes bi-weekly / weekly monitoring meeting of the program team and financial affairs. The meeting agenda would always include the expiration and liquidation dates of the grants. However, GDOE acknowledges the need to include the controls and procedures addressing liquidation deadlines in the Standard Operating Procedure (SOP) 200-034 for Accounts Payable and Cash Disbursement Procedures. Plan of action and completion date: SOP 200-034 will be updated to include the controls and procedures addressing liquidation deadlines. Federal Programs, program managers, Accounts Payable, and Financial Affairs will maintain a grant closeout schedule identifying each awards period of performance end date, liquidation deadline and outstanding obligations. Periodic review will be performed before liquidation deadlines, with aging items escalated for resolution. Closeout procedures will document required coordination among program, procurement, receiving, accounts payable, and Financial Affairs. Plan to monitor and responsible officials: Federal Programs Division and Financial Affairs/Accounts Payable, with applicable program managers. Additionally, the Internal Audit Office will monitor federal grant statuses and identify associated risks to include period of performance and report any deficiencies to respective divisions and GDOE leadership.

Categories

Internal Control / Segregation of Duties 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
  • 1240444 2025-009
    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