Finding 1240447 (2025-010)

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

AI Summary

  • Core Issue: Required Federal Program Officer approval was missing for 5% of tested nonpayroll transactions, indicating a gap in compliance.
  • Impacted Requirements: GDOE SOP 200-037 mandates that federally funded requisitions must be approved by the program manager and Federal Programs.
  • Recommended Follow-Up: Management should establish proper routing workflows for all new program account codes to ensure compliance with approval requirements.

Finding Text

Finding No.: 2025-010 – Allowable Costs/ Cost Principles Identification of the federal program: Federal Agency: U.S. Department of Education AL No. and Title: 84.403 Consolidated Grants Federal Award No: S403A240002 Criteria or specific requirement (including statutory, regulatory or other citation): GDOE SOP 200-037, Requisition Entry (Amended May 2024), states: “Federally funded requisitions are approved by the program manager and Federal Programs to ensure grant compliance.” Condition: Determination of Need (DON) document had no Federal Program Officer approval. Cause: Routing workflow for newly created project account codes for the program was not set up accordingly. Effect or potential effect: Federally funded requisitions under the newly created program account codes were not routed to the required approvers prior to purchase processing. Questioned costs: Not applicable. The finding relates solely to an internal control deficiency. Context: We identified 2,750 nonpayroll transactions subject to allowable costs/ cost principles compliance requirements during the year. We tested 60 nonpayroll transactions. The samples were statistically valid. For 3 (or 5%) nonpayroll transactions tested, the related DON document had no Federal Program Officer approval. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: Management should ensure routing workflow is setup accordingly for every newly created program account code. View of Responsible Officials: GDOE agrees with the finding and provides details in its Corrective Action Plan.

Corrective Action Plan

Finding No.: 2025-010 Federal Agency: U.S. Department of Education AL Program: 84.403 Consolidated Grants Federal Award No.: S403A240002 Area: Allowable Costs/Cost Principles Questioned Costs: $0 Views of Auditee and Corrective Actions GDOE agrees with the finding and acknowledges the need to strengthen internal controls governing the review and processing of Consolidated Grant funded requisitions. As identified in the finding, a random sample of requisitions associated with newly created project account codes did not route to the required Federal Programs reviewer because the applicable workflow had not been established properly. Plan of action and completion date: The Federal Programs Division, Financial Affairs, Procurement Office and FSAIS have coordinated together to address the identified routing deficiency. The Procurement Office is reviewing the system workflow for Consolidated Grant funded requisitions and identifying any requisitions that did not receive the required Federal Programs Division approval. For any such requisition, the Federal Programs Division conducts the required compliance review and provides written confirmation of its determination, which is then attached to the requisition record in MUNIS. Financial Affairs has also coordinated with FSAIS to review and correct the MUNIS workflow to ensure that requisitions generated and routed moving forward are directed to the appropriate Federal Programs Division reviewer before proceeding to the Procurement Office for processing. Plan to monitor and responsible officials: The Procurement Office, FSAIS and Federal Programs Division will periodically review federally funded requisition routing to ensure required workflow steps remain in place and processing does not proceed without the approvals required under GDOE procedures. Identified routing or approval deficiencies will be referred to the appropriate office for correction and follow-up. The Procurement Office will be responsible for ensuring required approvals are completed prior to processing requisitions, FSAIS for maintaining the appropriate system workflow and the Federal Programs Division will be responsible for continuing to conduct compliance reviews. Corrective actions to address the identified routing deficiency have been implemented as of September 2026. The Procurement Office and FSAIS have completed the initial workflow review and corrective measures, and the Federal Programs Division has begun reviewing and documenting affected requisitions as needed. Ongoing monitoring by the Procurement Office and periodic randomized reviews by the Federal Programs Division will continue as part of regular operations.

Categories

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Procurement, Suspension & Debarment

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
  • 1240445 2025-006
    Material Weakness Repeat
  • 1240446 2025-008
    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