FA 2022-001 Improve Controls over Equipment
Compliance Requirement: Equipment and Real Property Management
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Agriculture
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: 10.553 – School Breakfast Program
10.555 – National School Lunch Program
Federal Award Number: 225GA324N1199
Federal Awarding Agency: U.S. Department of Education
Pass-Through Entity: Georgia Department of Education
AL Numbers and Titles: COVID-19 – 84.425D – Elementary and Secondary School Emergency Relief Fund
COVID-19 – 84.425U – American Rescue Plan Elementary and Secondary School Emergency Relief Fund
COVID-19 – 84.425W – American Rescue Plan Elementary and Secondary School Emergency Relief Fund – Homeless Children and Youth
Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021)
S425U210012 (Year: 2021), S425W210011 (Year: 2021)
Questioned Costs: None Identified
Repeat of Prior Year Finding: FA 2021-001, FA 2020-001, FA 2019-003, FA 2018-002, FA 2017-004
Description:
The policies and procedures of the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Child Nutrition Cluster and Elementary and Secondary School Emergency Relief Fund programs.
Background:
The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential child care institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities.
On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation.
CNC and ESSER funding was granted to the Georgia Department of Education (GDOE) by the U.S. Department of Agriculture and U.S. Department of Education (ED), respectively. GDOE is responsible for distributing funds to LEAs and overseeing the programs. CNC funds totaling $1,113,376.14 and ESSER funds totaling $3,586,443.78 were expended and reported on the Dooly County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022.
Criteria:
As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls.
Provisions included in the Uniform Guidance, Section 200.313(d)(1) state, "Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property." In addition, the Uniform Guidance, Section 200.313(d)(2) states, "A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years."
Condition:
The following deficiencies were noted when reviewing the CNC and ESSER equipment listings and physically locating equipment items:
• Property records did not include the following required components for CNC equipment items: (1) Percentage of Federal participation in the project costs for the Federal award under which the property was acquired, (2) the source of funding for the property (including the FAIN), and (3) who holds title.
• Property records did not include the following required components for Elementary and Secondary School Emergency Relief Fund equipment items: (1) Percentage of Federal participation in the project costs for the Federal award under which the property was acquired, (2) who holds title, and (3) use and condition of the property.
• An equipment item totaling $501,596.61 purchased using ESSER funds was included on the financial statement capital asset listing but was excluded from the program equipment listing.
Cause:
In discussing this deficiency with the School District, they stated these issues were a result of turnover
within the Central Office. In addition, the ESSER equipment item was overlooked when preparing the program equipment listing.
Effect:
Failure to maintain a complete and accurate equipment listing and reconcile results of the physical inventory performed to the property records exposes the School District to unnecessary risk of error and misuse of equipment and/or Federal funds. Additionally, the School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance.
Recommendation:
The School District should develop and maintain equipment listings that reflect all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of Federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment. In addition, management should implement controls to ensure that a complete physical inventory of equipment is performed for every Federal program, and the results are reconciled back to the equipment listings at least once every two years.
Views of Responsible Officials:
We concur with this finding.