Finding 370612 (2022-005)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
$1
Year
2022
Accepted
2024-02-26

AI Summary

  • Core Issue: PSS is noncompliant with allowable costs/cost principles, leading to questioned costs of $246,285 due to improper payroll incentives and lack of documentation.
  • Impacted Requirements: Failure to reconcile payroll records and inadequate support for costs charged to the grant violate 2 CFR 200.403 and 2 CFR 200.439.
  • Recommended Follow-Up: PSS should establish regular reconciliations of payroll records and improve recordkeeping to ensure compliance and support for all costs charged to the grant.

Finding Text

Finding No. 2022-005 Federal Agency: U.S. Department of Education (ED) Assistance Listing No. and Title: COVID-19 84.425 Education Stabilization Fund ED Subprogram: 84.425A Education Stabilization Fund – State Educational Agency (Outlying Areas; 84.425X American Rescue Plan – State Agency Educational Agency (Outlying Areas) Federal Award No.: COVID-19 S425A200001, COVID-19 S425X210001 Area: Allowable Costs/Cost Principles Questioned Costs: $246,285 Criteria: The Schedule of Expenditures of Federal Awards (SEFA) must be supported by underlying accounting and other records used in preparing the financial statements. 2 CFR 200.403(a) provides that costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto. 2 CFR 200.403 (g) also provides that costs must be adequately documented. In an e-mail communication to PSS, U.S. Department of Education (ED) had stated that the proposed use of ESF funds for the purpose of paying a 10% retention incentive in response to the COVID-19 pandemic is allowable. 2 CFR 200.439(b) provides that capital expenditures for general purpose equipment, buildings, and land; special purpose equipment with a unit cost of $5,000 or more; and, improvements to land, buildings, or equipment which materially increase their value or useful life, are unallowable as direct charges, except with the prior written approval of the Federal awarding agency or pass-through entity. Condition: 1. For the year ended September 30, 2022, the total amount of payroll expense under ALN 84.027 determined from the journal entry details supporting the SEFA (or general ledger) was higher by $802,789 as compared to the total amount of payroll expense per labor cost summary (or subsidiary ledger). It was further noted that $404,198 out of this amount pertains to costs initially charged under ALN 84.027 but were later reclassified to ALN 84.425A through a general ledger entry only. No questioned costs are raised as the payroll costs that caused the variance were identified in detail. Condition, continued 2. For 2 (or 5%) of 40 payroll transactions tested, totaling $58,493 out of $32,152,897 in total gross wages incurred under the program, the employee was paid a retention incentive amounting to $3,000 instead of 10% of the employee’s annual salary, as provided by the retention incentive policy. We further noted that PSS provided fixed retention incentive payments amounting to $3,000 for employees whose annual salaries amounted to $30,000 and below, instead of using the rate of 10% as allowed by ED. No evidence was provided to justify the allowability of retention incentives in excess of the allowable amount for the aforementioned group of employees. Total known questioned costs for this condition amounted to $236,490 under ALN 84.425X. Below is a computation of the excess incentive amount for employees actively employed at fiscal year-end: See Schedule of Findings and Questioned Costs for chart/table. 3. For 1 (or 10%), no evidence of prior approval from the federal agency was provided for equipment acquisition PS-069896-US, which was acquired within fiscal year 2022 amounting to $9,795. Cause: PSS did not perform a reconciliation of the general ledger and subsidiary ledger for payroll costs. In addition, PSS failed to ensure that costs charged to the grant are adequately supported. Effect: PSS is in noncompliance with applicable allowable costs/cost principles requirements. Total known questioned costs of $246,285 are reported. Identification as a repeat finding: 2021-003 Recommendation: PSS should implement a regular reconciliation of its labor cost summary report with the general ledger journal entries and ensure that any discrepancies are resolved or validly supported. Further, PSS should strengthen recordkeeping procedures so that documents are readily available to substantiate costs charged to the grant. Views of responsible officials: The PSS Corrective Action Plan provides a detailed rationale for disagreement with the findings described in Conditions 1 and 2. Management agrees with Condition 3. Auditor response: Condition 1 – The finding does acknowledge that PSS reclassified the amount under ESF funds. Given the knowledge of the journal entry limitation, PSS failed to show evidence of effort to regularly reconcile the labor cost summary report with the general ledger. The condition remains. Condition 2 – A review of the communications between PSS and the U.S. Department of Education shows the latter’s approval to provide a retention incentive of 10% of annual salaries. There was no specific approval on the fixed amount of retention incentive provided for those employees with annual salaries not exceeding $30,000. The condition remains.

Categories

Questioned Costs Allowable Costs / Cost Principles Reporting

Other Findings in this Audit

  • 370608 2022-003
    Significant Deficiency
  • 370609 2022-003
    Significant Deficiency
  • 370610 2022-004
    Material Weakness
  • 370611 2022-005
    Material Weakness Repeat
  • 370613 2022-006
    Significant Deficiency
  • 370614 2022-006
    Significant Deficiency
  • 370615 2022-006
    Significant Deficiency
  • 370616 2022-007
    Significant Deficiency
  • 370617 2022-007
    Significant Deficiency
  • 370618 2022-007
    Significant Deficiency
  • 370619 2022-008
    Significant Deficiency
  • 370620 2022-008
    Significant Deficiency
  • 370621 2022-009
    Significant Deficiency Repeat
  • 370622 2022-010
    Significant Deficiency Repeat
  • 370623 2022-010
    Significant Deficiency Repeat
  • 370624 2022-011
    Significant Deficiency
  • 370625 2022-011
    Significant Deficiency
  • 370626 2022-011
    Significant Deficiency
  • 370627 2022-012
    Material Weakness
  • 370628 2022-013
    Material Weakness
  • 370629 2022-013
    Material Weakness
  • 370630 2022-014
    Material Weakness
  • 947050 2022-003
    Significant Deficiency
  • 947051 2022-003
    Significant Deficiency
  • 947052 2022-004
    Material Weakness
  • 947053 2022-005
    Material Weakness Repeat
  • 947054 2022-005
    Material Weakness Repeat
  • 947055 2022-006
    Significant Deficiency
  • 947056 2022-006
    Significant Deficiency
  • 947057 2022-006
    Significant Deficiency
  • 947058 2022-007
    Significant Deficiency
  • 947059 2022-007
    Significant Deficiency
  • 947060 2022-007
    Significant Deficiency
  • 947061 2022-008
    Significant Deficiency
  • 947062 2022-008
    Significant Deficiency
  • 947063 2022-009
    Significant Deficiency Repeat
  • 947064 2022-010
    Significant Deficiency Repeat
  • 947065 2022-010
    Significant Deficiency Repeat
  • 947066 2022-011
    Significant Deficiency
  • 947067 2022-011
    Significant Deficiency
  • 947068 2022-011
    Significant Deficiency
  • 947069 2022-012
    Material Weakness
  • 947070 2022-013
    Material Weakness
  • 947071 2022-013
    Material Weakness
  • 947072 2022-014
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Covid-19 Education Stabilization Fund $24.39M
84.403 Consolidated Grant to the Outlying Areas $18.54M
10.555 National School Lunch Program $14.81M
84.027 Special Education_grants to States $5.37M
93.600 Head Start $3.66M
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $1.68M
10.766 Community Facilities Loans and Grants $1.20M
93.356 Head Start Disaster Recovery $599,528
84.938 Disaster Recovery Assistance for Education $571,249
10.568 Emergency Food Assistance Program (administrative Costs) $522,910
84.181 Special Education-Grants for Infants and Families $520,925
84.027 Covid-19 Special Education_grants to States $504,054
84.372 Statewide Longitudinal Data Systems $443,117
93.600 Covid-19 Head Start $412,081
12.U01 Army Jrotc Eft District $384,793
93.982 Mental Health Disaster Assistance and Emergency Mental Health $317,256
94.006 Americorps $289,920
93.060 Competitive Abstinence Education (cae) $240,365
84.371 Striving Readers $212,126
93.092 Affordable Care Act (aca) Personal Responsibility Education Program $182,732
84.184 Safe and Drug-Free Schools and Communities_national Programs $175,543
93.612 Native American Programs $153,914
93.587 Promote the Survival and Continuing Vitality of Native American Languages $115,002
10.579 Child Nutrition Discretionary Grants Limited Availability $55,787
15.875 Economic, Social, and Political Development of the Territories $34,450