Finding 1240850 (2024-003)

Material Weakness Repeat Finding
Requirement
P
Questioned Costs
-
Year
2024
Accepted
2026-10-21
Audit: 415177
Organization: State of Kosrae (FM)
Auditor: BCM LLC

AI Summary

  • Core Issue: 20% of tested educators lacked proper documentation to verify college degree completion, violating grant requirements.
  • Impacted Requirements: Grant terms prohibit compensation for educators without degrees; incomplete records hinder compliance verification.
  • Recommended Follow-Up: Strengthen record-keeping by obtaining necessary documentation, ensuring complete records, and conducting regular reviews to prevent future issues.

Finding Text

Finding No.: 2024-003 Federal Agency: U.S. Department of the Interior, Office of Insular Affairs Federal Program: Economic, Social, and Political Development of the Territories – Compact of Free Association, as Amended, Compact Sector Grants Assistance Listing: 15.875 Compliance Requirement: Activities Allowed or Unallowed – Educator Qualification Requirements Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: The Compact Grant’s Education Sector terms and conditions, consistent with the FSM Policy on Teacher Certification and JEMCO Resolutions 2009-9 and MT 2011-1, prohibit grantfunded compensation for teachers, tutors, and teacher aides without college degrees. The provision also prohibits payment of culture teachers from the grant. Condition: We tested 82 educators whose compensation was charged to the Education Sector Grant and were unable to verify degree completion for 16, or approximately 20%, of the items tested. The sample was not statistically selected. Although transcripts were available, the documentation provided for these 16 educators did not demonstrate that degrees had been conferred. Diplomas or other evidence confirming degree completion were not provided for the following samples: 2, 14, 16, 17, 19, 22, 35, 40, 45, 48, 49, 53, 56, 58, 61, and 64. As a result, we could not verify satisfaction of the college degree requirement for the identified educators subject to that requirement. Cause: The process for maintaining and reviewing educator qualification records did not ensure that documentation establishing degree completion was retained and available to support verification of compliance with the grant requirement. Management indicated that its practice permits official transcripts in lieu of diplomas when the transcripts clearly confirm that the required degrees were awarded. However, the documentation provided for the remaining exceptions did not establish degree conferral. Effect: Incomplete qualification records limit Yap State Government’s ability to demonstrate compliance with the grant’s educator qualification requirements and increase the risk that compensation for individuals who do not meet those requirements could be charged to the grant. The absence of documentation does not, by itself, establish that the educators lacked college degrees or that their compensation was unallowable. Questioned Costs: Undetermined Recommendation: We recommend that Yap State Government strengthen its procedures for verifying and maintaining educator qualification records by: Obtaining documentation confirming degree completion for the identified educators subject to the grant requirement, such as diplomas, official transcripts showing degree conferral, or written confirmation from the issuing institutions. Maintaining complete and accessible qualification records for educators whose compensation is charged to the grant. Requiring documented verification of applicable educator qualifications before charging compensation to the grant. Performing periodic supervisory reviews to identify and resolve missing or incomplete qualification documentation. Identification as a Repeat Finding: No. Views of Responsible Officials: See the corrective action plan.

Corrective Action Plan

We partially agree with this Finding which cited certain teachers who had only official transcripts on file and no diplomas. Before the JEMCO resolution came out, we were not required to file diplomas in our personnel files, so most of our teachers do not have diplomas on file. We had sought concurrence from our grant manager on whether we could use official transcripts in lieu of proof of degrees for existing teachers without degrees and for new hires to get them on board sooner. Our pool of personnel to select teachers from is limited, and it is challenging to get quality teachers with degrees. He concurred that we use transcripts as long as they are the official ones from the institutions and clearly state that the students have been awarded the required degrees and that the students’ names are written clearly on them. In the meantime, each student/teacher will continue to provide a copy of the required degree so we can have it on file. I think this is the process we are still using and if it is not correct, please let us know.

Categories

Allowable Costs / Cost Principles Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1240849 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $23.28M
93.224 HEALTH CENTER PROGRAM $2.16M
84.027 SPECIAL EDUCATION GRANTS TO STATES $523,863
10.664 COOPERATIVE FORESTRY ASSISTANCE $140,695
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $129,886
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $83,371
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $54,567
59.006 8(A) BUSINESS DEVELOPMENT PROGRAM $52,334
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $51,853
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $50,655
15.904 HISTORIC PRESERVATION FUND GRANTS-IN-AID $41,434
93.527 GRANTS FOR NEW AND EXPANDED SERVICES UNDER THE HEALTH CENTER PROGRAM $40,236
93.092 AFFORDABLE CARE ACT (ACA) PERSONAL RESPONSIBILITY EDUCATION PROGRAM $35,465
93.377 PREVENTION AND CONTROL OF CHRONIC DISEASE AND ASSOCIATED RISK FACTORS IN THE U.S. AFFILIATED PACIFIC ISLANDS, U.S. VIRGIN ISLANDS, AND P. R. $26,790
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $24,304
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $23,381
93.217 FAMILY PLANNING SERVICES $16,121
93.104 COMPREHENSIVE COMMUNITY MENTAL HEALTH SERVICES FOR CHILDREN WITH SERIOUS EMOTIONAL DISTURBANCES (SED) $5,959
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $3,495
93.788 OPIOID STR $3,020
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $-910