Finding Text
Finding No.: 2025-008 – Cash Management 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 84.403 Consolidated Grants Federal Award No. H181A220008, H181A230008, H181A240008 S403A220002, S403A230002, S403A240002 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 vendors for federal expenditure are paid either on the same day or within 24 hours after funds had been received. Cause: The current Standard Operating Procedures (SOPs) do not clearly incorporate transitioned roles and responsibilities of the Third Party Fiduciary Agent (TPFA) for accountability to the specific conditions set by the US Department of Education. 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 and we have not identified internal controls to ensure compliance with applicable cash management requirements. 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 cash management requirements. View of Responsible Officials: GDOE does not agree with the finding and provides details in its Corrective Action Plan. Conclusion: The FY25 U.S. Department of Education carried forward the FY24 Specific Conditions dated June 24, 2024 which states that “Now that GDOE is managing its Department funds independently without TPFA oversight, GDOE must continue to fulfill the responsibilities that were previously performed by the TPFA.” The finding remains.