FAC Explorer

Finding 388346 (2023-004)

- Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-03-28
Audit: 300126
Organization: Department of Education, State of Hawaii (HI)
Auditor: Accuity LLP

AI Summary

  • Core Issue: A student was allowed to enroll in programs without meeting eligibility criteria, indicating a control deficiency.
  • Impacted Requirements: This violates federal regulations under Title 2 U.S. CFR Part 200, which require consistent adherence to eligibility policies.
  • Recommended Follow-Up: Ensure program personnel receive training and clear written procedures on eligibility criteria to prevent future errors.

Finding Text

Questioned Costs $- Finding No. 2023‐004: Student Eligibility (Control Deficiency) Federal Agency: U.S. Department of Education Assistance Listing Number and Title: 84.002A – Adult Education – Basic Grants to States Condition During our audit, we noted one instance in which a student was permitted to enroll in Workplace Literacy and Adult Basic Education programs without meeting the eligibility criteria for those programs. Criteria Section 200.403 – Factors affecting allowability of costs of Title 2 U.S. Code of Federal Regulations (“CFR”) Part 200, states “(c) – in order for costs to be allowable under Federal awards it must be consistent with policies and procedures that apply uniformly to both federally‐financed and other activities of non‐Federal entity.” Cause The inaccurate eligibility determinations may be attributed to general oversight by the program personnel. Effect Failure to adhere to the program’s eligibility requirements exposes the Department to an undue risk of noncompliance with the requirements of Title 2 U.S. CFR Part 200. Context A sample of 25 individuals were selected for audit from a population of 3,627 individuals eligible to participate in Workplace Literacy and Adult Basic Education programs. Our test found that one individual was improperly deemed as being eligible to participate in Workplace Literacy and Adult Basic Education programs. Our sample was a statistically valid sample. Repeat Finding This is a repeat of prior audit Finding No. 2022‐03. Recommendation We recommend that program personnel ensure that the appropriate eligibility criteria are followed when determining an individual’s ability to enroll in Workplace Literacy and Adult Basic Education programs. Cause and View of Responsible Officials The local service provider was unaware of the eligibility requirements for basic skills deficient individuals and did not thoroughly understand workplace adult education and literacy activities as defined in United States Code, Title 29, Chapter 32 Workforce Innovation and Opportunity Act §3272. The Office of Curriculum and Instructional Design Community Education Specialist will ensure the local service provider is informed through written eligibility procedures and training

Corrective Action Plan

2023-004 Student Eligibility – Control Deficiency View of Responsible Officials Management agrees with the finding and provides more context regarding the finding. Participant eligibility procedures are based on USC §3272 and §3102 were created for Adult Education Family Literacy Act (AEFLA)-funded adult schools. The procedures were distributed, and training was provided on March 31, 2023 to address prior audit Finding No. 2022-03. The enrollment record that did not meet the criteria for eligibility in the Single Audit Fiscal Year Ending 06/30/23 had an intake date of September 15, 2022, approximately six months before the procedures were distributed and training provided. A corrective action has already taken place through the March 31, 2023 procedures distribution and training. The AEFLA-funded adult schools are aware that all participants reported in the AEFLA reporting system, known as the National Reporting System, including participants in workplace adult education and literacy activities as defined in United States Code, Title 29, Chapter 32 Workforce Innovation and Opportunity Act §3272, must meet AEFLA eligibility requirements. Corrective Action Plan Participant eligibility procedures for AEFLA-funded adult schools based on USC §3272 and §3102 will be reviewed annually with AEFLA-funded adult schools through a technical assistance session. The procedures inform the staff of the AEFLA-funded adult school of the following: • The Workforce Innovation and Opportunity Act • The Adult Education and Family Literacy Act • The relevant US Code and Code of Federal Regulations • A definition of AEFLA-eligible individuals • Categories of funding and their purpose • The role of the US DOE Office of Career Technical and Adult Education • The role of the Hawaii state director for adult education • The role of the AEFLA-funded local service providers Contact Person: Dan Miyamoto, TA Community Education Specialist Curriculum Innovation Branch Office of Curriculum and Instructional Design Anticipated Completion Date: August 31, 2024

Categories

Internal Control / Segregation of Duties Eligibility

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $50.00M
84.010 Title I Grants to Local Educational Agencies $48.49M
84.371 Striving Readers $11.46M
84.367 Improving Teacher Quality State Grants $9.02M
84.424 Student Support and Academic Enrichment Program $6.79M
84.287 Twenty-First Century Community Learning Centers $6.40M
84.027 Special Education_grants to States $5.36M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $5.33M
15.875 Economic, Social, and Political Development of the Territories $4.53M
10.555 National School Lunch Program $4.46M
93.558 Temporary Assistance for Needy Families $4.03M
84.365 English Language Acquisition State Grants $3.73M
84.041 Impact Aid $3.70M
84.002 Adult Education - Basic Grants to States $3.20M
84.048 Career and Technical Education -- Basic Grants to States $2.77M
45.310 Grants to States $2.31M
84.011 Migrant Education_state Grant Program $2.09M
12.558 Department of Defense Impact Aid (supplement, Cwsd, Brac) $1.89M
84.369 Grants for State Assessments and Related Activities $1.63M
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $1.58M
10.582 Fresh Fruit and Vegetable Program $1.27M
84.425 Education Stabilization Fund $1.16M
10.560 State Administrative Expenses for Child Nutrition $871,179
12.556 Competitive Grants: Promoting K-12 Student Achievement at Military-Connected Schools $824,788
10.558 Child and Adult Care Food Program $694,366
84.372 Statewide Longitudinal Data Systems $625,241
84.184 Safe and Drug-Free Schools and Communities_national Programs $476,839
84.196 Education for Homeless Children and Youth $373,480
84.259 Native Hawaiian Career and Technical Education $283,634
12.600 Community Investment $221,906
84.362 Native Hawaiian Education $166,796
84.173 Special Education_preschool Grants $115,885
93.600 Head Start $108,990
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $101,574
10.574 Team Nutrition Grants $94,051
84.424 Trauma Recovery Demonstration Grant Program $91,685
84.144 Migrant Education_coordination Program $84,339
10.541 Child Nutrition-Technology Innovation Grant $66,027
84.013 Title I State Agency Program for Neglected and Delinquent Children and Youth $62,221
84.368 Grants for Enhanced Assessment Instruments $60,993
10.579 Child Nutrition Discretionary Grants Limited Availability $57,926
10.559 Summer Food Service Program for Children $53,822
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $25,000
84.365 Asian American and Pacific Islander Data Disaggregation Initiative $20,110
10.645 Farm to School State Formula Grant $15,674
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $3,799