FAC Explorer

Finding 21414 (2022-005)

Significant Deficiency
Requirement
H
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 18333
Organization: School District of the City of St. Louis (MO)
Auditor: Rubinbrown LLP

AI Summary

  • Core Issue: Reimbursement requests were submitted late, violating the 60-day requirement after the last service date.
  • Impacted Requirements: Compliance with federal program rules and effective internal controls are necessary to avoid noncompliance risks.
  • Recommended Follow-Up: Management should enhance processes and controls to ensure timely submission of reimbursement requests for federal grants.

Finding Text

Finding 2022-005 Significant Deficiency: Period of Performance ? Control and Compliance Finding ALN 32.009 ? Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: The compliance provisions of the federal program require that final expense reimbursements take place within 60 days of the last service date. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program related to special tests and provision requirements. Condition: Reimbursement request was not prepared and submitted until December 2022, even though 60 days after the last service date was August 2022. Cause: Management did not have an internal control process in place to ensure timely submission of the reimbursement request. Effect: The possibility exists that noncompliance with federal requirements could go undetected, and the federal agency could deny the request for reimbursement, without proper controls over compliance. Questioned Costs: Not applicable. Context: Reimbursement request was submitted in December 2022 and the federal agency funded the request in December 2022. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The Information Technology Department will provide all necessary grant paperwork to the Finance Office to ensure that all applicable deadlines are met, and that reimbursement happens in the allotted time period.

Corrective Action Plan

Finding 2022-005 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: The Information Technology Department will schedule a call with the ECF consultant, the Financial Management Office, and the Fiscal Control Office by July 15, 2023 to discuss all necessary paperwork that will be submitted to the Financial Management and Fiscal Control Offices 30 days prior to the final submission deadline to ensure that all payment requests can be submitted in the allotted time period, and give the Finance Offices understanding of what the reimbursement amount will be. The ECF consultant will copy the Chief Financial Officer, Finance Director, Grants Manager, and Fiscal Control Director on his/her submission.

Categories

Special Tests & Provisions Subrecipient Monitoring Cash Management Period of Performance Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 21409 2022-002
    Significant Deficiency Repeat
  • 21410 2022-002
    Significant Deficiency Repeat
  • 21411 2022-002
    Significant Deficiency Repeat
  • 21412 2022-003
    Significant Deficiency
  • 21413 2022-004
    Significant Deficiency
  • 597851 2022-002
    Significant Deficiency Repeat
  • 597852 2022-002
    Significant Deficiency Repeat
  • 597853 2022-002
    Significant Deficiency Repeat
  • 597854 2022-003
    Significant Deficiency
  • 597855 2022-004
    Significant Deficiency
  • 597856 2022-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.553 School Breakfast Program $4.30M
32.009 Covid-19: Emergency Connectivity Fund Program $2.36M
10.555 National School Lunch Program $1.41M
10.558 Child and Adult Care Food Program $1.02M
84.424 Student Support and Academic Enrichment Program $989,098
84.002 Adult Education - Basic Grants to States $969,421
84.367 Improving Teacher Quality State Grants $850,777
84.425 Covid-19: Education Stabilization Fund $725,947
84.048 Career and Technical Education -- Basic Grants to States $626,546
21.027 Covid-19: Coronavirus State and Local Fiscal Recovery Funds $560,670
10.582 Fresh Fruit and Vegetable Program $477,723
10.559 Summer Food Service Program for Children $454,663
84.027 Special Education_grants to States $333,567
84.365 English Language Acquisition State Grants $327,904
93.566 Refugee and Entrant Assistance_state Administered Programs $234,407
12.000 Air Force Rotc $223,046
84.173 Special Education_preschool Grants $204,389
12.000 Army Rotc $99,587
84.377 School Improvement Grants $75,971
12.000 Naval Rotc $52,761
16.839 Stop School Violence $44,618
84.010 Title I Grants to Local Educational Agencies $40,582
10.575 Farm to School Grant Program $34,513
12.000 Marines Rotc $33,399