Finding 376069 (2023-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-14

AI Summary

  • Core Issue: Management lacks an adequate internal control system to ensure compliance with federal Wage Rate Requirements for the Emergency Relief Fund.
  • Impacted Requirements: Non-compliance with 2 CFR Section 200.303 and 29 CFR Part 5 may lead to improper wage payments to laborers and mechanics.
  • Recommended Follow-Up: Management should establish and maintain effective internal controls to ensure compliance with federal statutes and document adherence to Wage Rate Requirements.

Finding Text

AL 84.425D – Elementary and Secondary School Emergency Relief Fund, U.S. Department of Education. Passed through New York State Education Department, Award Number 5891 Criteria: Requirements per 2 CFR Section 200.303 of the Uniform Guidance state that non-federal entities must establish and maintain effective internal control over federal awards to provide reasonable assurance that the nonfederal entity is managing the federal award in accordance with federal statutes, regulations, and terms and conditions of the awards received. Condition: Management had not established an adequate system of internal control over compliance with the relevant federal statutes, regulations, and terms and conditions of the federal awards as management’s internal control procedures did not cause the entity to comply with the Special Tests and Provisions related to Wage Rate Requirements under the Elementary and Secondary School Emergency Relief Fund. Cause: Management did not have adequate internal controls in place to identify and comply with Wage Rate Requirements established under 29 CFR Part 5. Effect or Potential Effect: Without appropriate internal controls over compliance, non-compliance could occur which the entity may not identify. Laborers and mechanics employed by contractors and subcontractors may not have been paid in accordance with local prevailing wage rates. We were not able to determine if the entity was in compliance with this compliance requirement as appropriate documentation was not requested from the applicable contractor. Questioned Costs: N/A Repeat Finding?: Yes, see finding 2022-001. Recommendation: Management should implement internal controls over Wage Rate Requirements to ensure compliance with applicable Federal statutes, regulations, and terms and conditions of the awards received. Views of Responsible Officials: We are in agreement with the finding. GCCS management will retain documentation to support proper operation of internal controls and compliance with applicable Federal statutes, regulations, Wage Rate Requirements, and other terms and conditions of awards received. Auditor’s Evaluation of the Views of Responsible Officials: Management’s response is appropriate to address the finding. If properly implemented, management’s response would include procedures to prevent reoccurrence in the future.

Corrective Action Plan

We are in agreement with the finding. GCCS management will retain documentation to support proper operation of internal controls and compliance with applicable Federal statutes, regulations, Wage Rate Requirements, and other terms and conditions of awards received. By the November 2023 board meeting, we will adopt an updated fiscal policy & procedures manual with more explicit language regarding procurement & expenditure requirements for federal funding of capital items.

Categories

Matching / Level of Effort / Earmarking Special Tests & Provisions

Other Findings in this Audit

  • 952511 2023-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $1.27M
84.365 English Language Acquisition State Grants $196,817
84.010 Title I Grants to Local Educational Agencies $193,180
10.553 School Breakfast Program $79,344
32.009 Emergency Connectivity Fund Program $38,676
84.367 Improving Teacher Quality State Grants $23,776
10.555 National School Lunch Program $23,576
10.559 Summer Food Service Program for Children $19,786
84.424 Student Support and Academic Enrichment Program $12,095