Finding Text
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.