Finding 374348 (2022-001)

-
Requirement
AB
Questioned Costs
$1
Year
2022
Accepted
2024-03-07

AI Summary

  • Core Issue: An expenditure of $239,173 from the ARP ESSER Fund was deemed unallowable under federal guidelines.
  • Impacted Requirements: Costs must be necessary and reasonable for the Federal award, as outlined in 2 CFR § 200.403 (a) and consistent with the ESF's purpose.
  • Recommended Follow-Up: The District should establish stronger procedures to ensure all future expenditures comply with grant guidelines to avoid potential funding reductions or repayment obligations.

Finding Text

2 CFR § 3474.1 gives regulatory effect to the U.S. Department of Education for 2 CFR § 200.403 (a), which requires, except where otherwise authorized by statute, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Costs incurred under the Education Stabilization Fund (ESF) must be consistent with the purpose of the ESF which is to prevent, prepare for, and respond to COVID-19. For fiscal year 2022, one of the 64 tested expenditures paid out of the #84.425U – American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund totaling $239,173 was determined to not be allowable based on the ESF grant's guidelines and 2 CFR § 200.403 (a). This expenditures was: Pursuant to ORC §3302.10, districts are subject to an academic distress commission after receiving an overall grade of F or an overall rating of less than two stars on the Ohio School Report Cards for three consecutive years. Youngstown met these criteria in FY 2016. The District’s academic distress commission appointed a chief executive officer with complete operational, managerial, and instructional control of the district. Among other duties, this included contracting for services and modifying policies and procedures previously established. Under his authority, the CEO approved the unallowable expenditure noted above. The noncompliance has resulted in a questioned cost in the amount of $239,173. The District should implement additional procedures to help ensure expenditures charged to the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund are necessary and reasonable for the grant program in accordance with 2 CFR § 200.403 (a) and allowable under the grant guidelines. Failure to do so could result in reduced future federal funding or the requirement to repay the Ohio Department of Education.

Corrective Action Plan

The Board of Education has now regained control of the District and moving forward, the District will closely monitor grant funded expenditures. The District utilizes its Grants Council to review grant awards and develop plans for expenditures. This includes ensuring the expenditures are necessary and reasonable for the grant program in accordance with 2 CFR § 200.403(a) and allowable under the grant guidelines.

Categories

Questioned Costs Allowable Costs / Cost Principles

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.010 Title I Grants to Local Educational Agencies $8.48M
10.553 School Breakfast Program $1.03M
84.424 Student Support and Academic Enrichment Program $794,977
84.425 Education Stabilization Fund $664,721
84.367 Improving Teacher Quality State Grants $617,421
84.048 Career and Technical Education -- Basic Grants to States $507,364
84.371 Striving Readers $362,330
84.287 Twenty-First Century Community Learning Centers $258,658
84.027 Special Education_grants to States $247,756
84.063 Federal Pell Grant Program $202,336
10.558 Child and Adult Care Food Program $115,291
84.365 English Language Acquisition State Grants $80,505
12.000 Junior Reserve Officer Training Corp. $71,914
84.377 School Improvement Grants $71,317
84.268 Federal Direct Student Loans $37,707
21.019 Coronavirus Relief Fund $27,915
84.173 Special Education_preschool Grants $26,444
10.555 National School Lunch Program $25,982
84.196 Education for Homeless Children and Youth $11,175
10.649 Pandemic Ebt Administrative Costs $3,063