Finding 388289 (2023-002)

Significant Deficiency
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2024-03-28
Audit: 300075
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The County improperly charged $15,184 in unallowable indirect costs to the ESSER III Fund for Learning Loss.
  • Impacted Requirements: Indirect costs are not allowed under the ESSER III program, as per federal guidelines.
  • Recommended Follow-Up: Establish a review process for indirect costs, ensuring compliance with grant agreements and federal regulations.

Finding Text

50000 – COVID-19 - Elementary and Secondary School Emergency Relief III (ESSER III) Fund: Learning Loss (Significant Deficiency) Federal Program Affected Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education Program Name: COVID-19 - Elementary and Secondary School Emergency Relief III (ESSER III) Fund: Learning Loss Assistance Listing Number: 84.425U Compliance Requirements: B (Allowable Costs/Cost Principles) Criteria or Specific Requirements The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to establish indirect cost rates for California local education agencies (LEAs). The CDE has been delegated authority to calculate and approve indirect cost rates annually for LEAs. For the Education Stabilization Fund (ESF) Program in fiscal year 2022-2023, Education Code Section 38101(c) limits County Office of Education indirect costs to the County’s individual CDE approved indirect cost rat; however, COVID-19 - Elementary and Secondary School Emergency Relief III (ESSER III) Fund: Learning Loss, indirect costs are not allowable. Condition The County charged unallowable indirect costs totaling $15,184 to the COVID-19 - Elementary and Secondary School Emergency Relief III (ESSER III) Fund: Learning Loss portion of the ESF Program. Questioned Costs There were no direct questioned costs associated with the condition identified. Context The condition was identified through recalculation of the indirect costs charged to the federal programs. Effect The County has charged unallowable expenditures to the federal programs. Cause The condition identified appears to be due to the County not being familiar with the indirect cost requirements for each of the federal programs. Repeat Finding No. Recommendation It is recommended that the County implements a review process for indirect costs, which should include review of relevant grant agreements and relevant federal guidance.

Corrective Action Plan

This error was the result of inadvertent oversight. Initially, this resource allowed indirect costs and the validation tables from CDE allowed the account component combination. Information was subsequently changed by CDE to issue guidance to charge the indirect cost for the learning loss component to the ESSER III Fund. CDE's website was updated on October 16, 2023, with this guidance well after the year end close was complete. Staff will implement additional processes to ensure valid application of indirect cost charges to grant programs.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 388290 2023-001
    Significant Deficiency
  • 388291 2023-001
    Significant Deficiency
  • 388292 2023-001
    Significant Deficiency
  • 964731 2023-002
    Significant Deficiency
  • 964732 2023-001
    Significant Deficiency
  • 964733 2023-001
    Significant Deficiency
  • 964734 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.489 Child Care Disaster Relief (a) $1.98M
10.665 Schools and Roads - Grants to States $792,823
84.287 Twenty-First Century Community Learning Centers $271,931
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $258,015
84.010 Title I Grants to Local Educational Agencies $160,604
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $150,058
93.658 Foster Care_title IV-E $128,493
93.575 Child Care and Development Block Grant $126,425
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $106,598
84.173 Special Education_preschool Grants $87,169
84.196 Education for Homeless Children and Youth $75,568
84.181 Special Education-Grants for Infants and Families $53,991
10.558 Child and Adult Care Food Program $35,799
10.649 Pandemic Ebt Administrative Costs $32,000
84.424 Student Support and Academic Enrichment Program $11,702
84.027 Special Education_grants to States $11,134
84.425 Education Stabilization Fund $5,834
84.367 Improving Teacher Quality State Grants $4,851