Finding 1240757 (2025-003)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2025
Accepted
2026-10-21
Audit: 415155
Organization: City of Warwick, Rhode Island (RI)

AI Summary

  • Core Issue: The school department lacks adequate time and effort documentation for payroll costs charged to the Title I program.
  • Impacted Requirements: Compliance with federal regulations (2 CFR §200.430(i)) regarding accurate and allowable salary charges is at risk.
  • Recommended Follow-Up: Implement and document procedures for time and effort tracking, conduct regular management reviews, and train staff on federal documentation requirements.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Name: Title I Assistance Listing Number: 84.010 Federal Award Identification Number and Year: Unknown Pass-Through Agency: RI Department of Education Pass-Through Number(s): 2725-11702-501 Award Period: July 1, 2024 – September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200), specifically 2 CFR §200.430(i), charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Additionally, the non-Federal entity is required to have written procedures and a system of internal controls to ensure that charges for compensation are accurate, allowable, and properly allocated to each applicable cost objective. Condition: The school department did not maintain adequate time and effort documentation to support payroll costs charged to the program. Questioned costs: None Context: During testing of payroll expenditures, it was identified that the school department was not able to provide the time and effort documentation required for all tested payroll expenditures. Cause: School department procedures for monitoring and retaining time and effort documentation were not consistently implemented. In addition, management oversight procedures did not ensure that required certifications were completed timely, reviewed for accuracy, and retained in accordance with federal requirements. Effect: This condition increases the risk that federal funds may have been charged for costs not properly supported or not benefiting the program, resulting in noncompliance with federal grant requirements. Recommendation: Establish and formally document procedures to ensure time and effort documentation is completed in accordance with federal requirements. Require periodic review of procedures by management to verify accuracy and completeness. Ensure all time and effort documentation is properly retained and readily available for audit purposes. Provide training to applicable staff on federal time and effort documentation requirements. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Warwick Public Schools has implemented several procedures to strengthen grant management, improve the accuracy and timeliness of required reporting, and ensure appropriate coordination between the Grants and Business Offices. 1. Grants Management Calendar: A shared Grants Management Calendar has been created and is actively used by the Grants and Business Offices to monitor reporting deadlines and ensure required reports are completed and submitted on time. The calendar identifies the individual responsible for each reporting requirement and is managed by the Director of Federal Programs & Grants, Paul Heatherton. 2. Grant Tracker: A centralized Grant Tracker has been implemented to document key grant information, including the Grant Award Notification (GAN), approved budget, grant-funded positions, and grant end dates. This tracker is shared with the Grants and Business Offices and, when applicable, Human Resources. It supports coordination across departments, particularly for positions funded through grants with defined end dates, such as the Coronavirus State and Local Fiscal Recovery Funds. This process helps the district identify upcoming grant expirations and plan for the continuation or transition of funding for grant-funded positions. 3. Annual Grant Position and Funding Notifications: The Grants Office has established an annual process for providing Human Resources with a transaction notice identifying grant-funded positions and their associated grant fund numbers. This procedure strengthens communication regarding grant-funded staffing and helps ensure that positions are accurately associated with the appropriate funding sources. 4. Federal Grants Management Procedural Guide: Warwick Public Schools intends to develop a Warwick Public Schools Federal Grants Management – Procedural Guide by April 2027. This working guide will include both programmatic and financial procedures to promote consistent grant administration and ensure compliance with applicable federal, state, and grant-specific requirements. The guide will establish clear expectations for grant oversight, reporting deadlines, financial documentation, expenditure monitoring, and coordination among the Grants Office, Business Office, and other relevant departments. It will serve as a reference for staff responsible for administering and monitoring grant-funded programs and expenditures. The Grants Management Calendar, Grant Tracker, and annual grant position and funding notification procedures were implemented as of September 30, 2026. Completion of the Federal Grants Management Procedural Guide by April 2027 will serve as an additional step toward strengthening internal controls, standardizing grant administration, and supporting ongoing compliance.

Categories

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1240756 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $11.68M
84.027 SPECIAL EDUCATION GRANTS TO STATES $3.36M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $2.15M
97.083 STAFFING FOR ADEQUATE FIRE AND EMERGENCY RESPONSE (SAFER) $1.91M
66.202 CONGRESSIONALLY MANDATED PROJECTS $1.45M
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $1.35M
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $1.30M
97.044 ASSISTANCE TO FIREFIGHTERS GRANT $739,042
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $456,193
20.616 NATIONAL PRIORITY SAFETY PROGRAMS $303,660
10.553 SCHOOL BREAKFAST PROGRAM $242,215
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $176,730
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $171,847
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $152,257
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $110,345
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $108,283
97.067 HOMELAND SECURITY GRANT PROGRAM $102,155
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $93,049
97.052 EMERGENCY OPERATIONS CENTER $90,659
10.555 NATIONAL SCHOOL LUNCH PROGRAM $71,059
84.196 EDUCATION FOR HOMELESS CHILDREN AND YOUTH $67,875
16.U02 DEA Reimbursement $53,812
84.425 EDUCATION STABILIZATION FUND $45,829
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $44,083
10.558 CHILD AND ADULT CARE FOOD PROGRAM $40,711
84.371 COMPREHENSIVE LITERACY DEVELOPMENT $36,292
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $28,525
16.U01 CBP/ICE Grant $20,419
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $20,379
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $19,456
84.411 EDUCATION INNOVATION AND RESEARCH (FORMERLY INVESTING IN INNOVATION (I3) FUND) $17,650
16.U03 FBI-CETF $17,556
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $16,542
10.579 CHILD NUTRITION DISCRETIONARY GRANTS LIMITED AVAILABILITY $9,759
16.609 PROJECT SAFE NEIGHBORHOODS $8,500
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $2,069