Finding 1241289 (2023-005)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2023
Accepted
2026-10-28
Audit: 415407
Organization: Little Wound School Board, Inc. (SD)
Auditor: BLUEARROW CPA

AI Summary

  • Core Issue: The School failed to execute subrecipient agreements on time, leading to non-compliance with federal monitoring requirements.
  • Impacted Requirements: Timely execution of agreements, availability of amendments, and retention of approved budgets were not met, hindering proper oversight of federal funds.
  • Recommended Follow-Up: Implement formal procedures to ensure timely execution of agreements, obtain and retain necessary documentation, and regularly compare expenditures to approved budgets.

Finding Text

Funding Agency U.S. Department of Health and Human Services Criteria: Title Substance Abuse and Mental Health Services Projects of Regional and National Significance Federal Assistance Listing Number: 93.243 Under 2 CFR § 200.332, a pass-through entity is required to clearly identify Federal awards to subrecipients at the time of the subaward and communicate all applicable Federal award information, terms, and conditions through the subaward agreement. The pass-through entity is also responsible for evaluating each subrecipient’s risk of noncompliance and monitoring subrecipient activities to ensure that Federal funds are used for authorized purposes, in compliance with applicable Federal statutes, regulations, and the terms and conditions of the subaward, and that program performance objectives are achieved. Accordingly, the pass-through entity should maintain adequate documentation supporting its subrecipient relationships, including properly executed subrecipient agreements, applicable amendments, approved budgets when required by the agreement, and other relevant monitoring documentation. Such documentation should be current, executed in a timely manner, and retained for the period during which Federal funds are provided to and administered by the subrecipient. Condition: During our testing of five subrecipients for the fiscal year ended June 30, 2023, we noted the following deficiencies:  Three of five subrecipient agreements were executed after the fiscal year end. Therefore, the agreements were not timely executed during the period in which the subrecipients were carrying out activities under the Federal awards.  For the remaining two of five subrecipients, amendments applicable to the current fiscal year were not available for audit examination. Accordingly, we were unable to verify the current-year terms, funding amounts, periods of performance, and other applicable provisions of the subaward arrangements.  Approved budgets required under the applicable subrecipient agreements were not provided for audit examination. As a result, we were unable to verify that subrecipient expenditures were incurred in accordance with the approved budgets and the terms and conditions of the respective agreements. As a result, the School did not maintain sufficient supporting documentation demonstrating that complete and current subaward agreements, amendments, and required approved budgets were in place and available for monitoring purposes during the fiscal year. Cause: The School did not have adequate procedures in place to ensure that subrecipient agreements and amendments were executed timely and that all required supporting documentation, including approved budgets, was obtained, retained, and available as part of the subrecipient monitoring process. Effect: The School is not in compliance with federal requirements related to subrecipient monitoring. Auditor's Recommendations: We recommend that the School establish and implement formal procedures to ensure that:  Subrecipient agreements are fully executed before subrecipients begin performing activities or incurring expenditures under the applicable Federal award;  Amendments are prepared and executed timely whenever funding amounts, periods of performance, budgets, or other terms of the agreement change;  Approved budgets required by the subrecipient agreements are obtained, formally approved, and retained for each applicable fiscal year;  Subrecipient expenditures are periodically compared to the approved budgets as part of the School's monitoring procedures; and  All executed agreements, amendments, approved budgets, and other monitoring documentation are centrally maintained and readily available for audit examination.

Corrective Action Plan

Management’s Response: We had one SAMSHA grant end on 09.30.2023 which was a Project Aware grant that had to sub-recipients. We did all of the purchasing of supplies for this program the only thing the sub-recipients were responsible for was Salaries, Fringe and phone costs. This was the main thing that we reimbursed those schools for. With the second Project Aware grant we had 3 sub-recipients and this grant started on 09/30/2021 and will end on 09/29/2026. With project we did put into place agreements that covered the duration of the grant. Each year the Project Director gave the sub-recipients that amounts of their budgets, but once again Little Wound School process all of the payments for supplies, materials, phones, travel, etc. The only things the sub-recipients had to cover was Salaries, Fringe, and utilities. Then they would submit a bill for reimbursement from Little Wound School. The Project Director and Co-Director would monitor the 3 sub-recipients to make sure they were staying in compliance with the grant.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1241271 2023-002
    Material Weakness Repeat
  • 1241272 2023-002
    Material Weakness Repeat
  • 1241273 2023-002
    Material Weakness Repeat
  • 1241274 2023-002
    Material Weakness Repeat
  • 1241275 2023-002
    Material Weakness Repeat
  • 1241276 2023-002
    Material Weakness Repeat
  • 1241277 2023-003
    Material Weakness Repeat
  • 1241278 2023-003
    Material Weakness Repeat
  • 1241279 2023-003
    Material Weakness Repeat
  • 1241280 2023-003
    Material Weakness Repeat
  • 1241281 2023-003
    Material Weakness Repeat
  • 1241282 2023-003
    Material Weakness Repeat
  • 1241283 2023-004
    Material Weakness Repeat
  • 1241284 2023-004
    Material Weakness Repeat
  • 1241285 2023-004
    Material Weakness Repeat
  • 1241286 2023-004
    Material Weakness Repeat
  • 1241287 2023-004
    Material Weakness Repeat
  • 1241288 2023-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.042 INDIAN SCHOOL EQUALIZATION $7.45M
84.425 EDUCATION STABILIZATION FUND $4.21M
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $3.60M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $2.31M
15.046 ADMINISTRATIVE COST GRANTS FOR INDIAN SCHOOLS $1.99M
84.027 SPECIAL EDUCATION GRANTS TO STATES $1.65M
15.044 INDIAN SCHOOLS STUDENT TRANSPORTATION $1.33M
15.047 INDIAN EDUCATION FACILITIES, OPERATIONS, AND MAINTENANCE $1.32M
93.665 EMERGENCY GRANTS TO ADDRESS MENTAL AND SUBSTANCE USE DISORDERS DURING COVID-19 $773,316
15.062 REPLACEMENT AND REPAIR OF INDIAN SCHOOLS $647,201
15.043 INDIAN CHILD AND FAMILY EDUCATION $372,349
10.555 NATIONAL SCHOOL LUNCH PROGRAM $272,349
84.299 INDIAN EDUCATION -- SPECIAL PROGRAMS FOR INDIAN CHILDREN $241,446
84.336 TEACHER QUALITY PARTNERSHIP GRANTS $203,600
84.299A Special Projects Demonstration Grants $150,166
15.149 FOCUS ON STUDENT ACHIEVEMENT $145,916
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $139,686
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $129,900
84.101 CAREER AND TECHNICAL EDUCATION - GRANTS TO NATIVE AMERICANS AND ALASKA NATIVES $126,147
10.553 SCHOOL BREAKFAST PROGRAM $93,584
84.415 INDIAN EDUCATION NATIONAL ACTIVITIES (STATE TRIBAL EDUCATION PARTNERSHIP (STEP) AND NATIVE AMERICAN LANGUAGE (NAL) $65,908
84.377 SCHOOL IMPROVEMENT GRANTS $29,895
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $24,931
10.575 FARM TO SCHOOL GRANT PROGRAM $22,341
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $19,166
10.558 CHILD AND ADULT CARE FOOD PROGRAM $17,086
84.358 RURAL EDUCATION $10,900
45.164 PROMOTION OF THE HUMANITIES PUBLIC PROGRAMS $5,122