Finding 392109 (2023-002)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-04-02

AI Summary

  • Core Issue: The Final Expenditure Report for the 2023 grant incorrectly included expenses from the 2022 grant, leading to an overstatement of expenditures.
  • Impacted Requirements: Compliance with reporting requirements under 2 CFR § 3474.1 and accurate submission of the Final Expenditure Report by the December 1 deadline.
  • Recommended Follow-Up: The School District should implement a review process for the Final Expenditure Report to ensure accuracy before submission.

Finding Text

1. Final Expenditure Report Finding Number: 2023-002 Assistance Listing Number and Title: AL #84.425 COVID-19 – Education Stabilization Fund Federal Award Identification Number / Year: 2023 Federal Agency: Department of Education Compliance Requirement: Reporting Pass-Through Entity: Ohio Department of Education and Workforce Repeat Finding from Prior Audit? No Noncompliance and Material Weakness 2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200, except for 2 CFR § 200.102(a) and 2 CFR § 200.207(a). Thus, this part gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE. As documented by the Ohio Department of Education and Workforce Office of Federal and State Grants Management, the Ohio Department of Education and Workforce requires school districts to submit the American Rescue Plan Elementary and Secondary School Emergency Relief 2023 grant Final Expenditure Report (FER) by December 1, 2023. School Districts must complete the FER at the end of each fiscal year for the prior state fiscal year’s Elementary and Secondary School Emergency Relief expenditures. All expenses reported on the FER should be paid. There should be no encumbered amounts. The Treasurer and Superintendent approved and submitted the Final Expenditure Report for the American Rescue Plan Elementary and Secondary School Emergency Relief 2023 grant on September 26, 2023. However, the expenditures in this submission included the American Rescue Plan Elementary and Secondary School Emergency Relief 2022 grant expenditures as well as the 2023 grant. In an attempt to correct this, the Treasurer posted adjustments to the American Rescue Plan Elementary and Secondary School Emergency Relief Fund on November 28, 2023 totaling $50,798 and on January 23, 2024 totaling $242,907. However, the amounts adjusted by the Treasurer in November 2023 and January 2024 would not be considered federal expenditures until the time management made the decision to allocate those allowable costs to the program. As such, those adjusted expenditures could appear on the fiscal year 2024 Final Expenditure Report but not fiscal year 2023. Therefore, the American Rescue Plan Elementary and Secondary School Emergency Relief 2023 grant Final Expenditure Report submitted to the Ohio Department of Education and Workforce overstated object codes 100 by $174,529, 200 by $81,982, 400 by $29,536, and 500 by $7,689. The School District should review the Final Expenditure Report before submission to help ensure all required amounts are included.

Corrective Action Plan

Finding Number: 2023-002 Planned Corrective Action: We are confident that our ESSER expenditures align with the allowable purposes and intents of the grant application that was submitted in the CCIP. We also stand by the integrity of our identification of expenses in total in the American Rescue Plan ESSER Federal Grant Program despite differences identified between grant years. The FER process and the reallocation of funds by grant year was confusing. However, as in the response above, we recognize the responsibility to adhere to the strict timelines was our responsibility. All ESSER funds have now been expended and we are confident they are allowable expenses per the guidelines provided. The Treasurer, Superintendent, and Federal Funds Coordinator agree to work more collaboratively to ensure our expenditures are within the grant timeframes prior to FER submissions. Anticipated Completion Date: 03/08/2024 Responsible Contact Person: Lance A. Erlwein, Treasurer

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness Reporting

Other Findings in this Audit

  • 392110 2023-002
    Material Weakness
  • 968551 2023-002
    Material Weakness
  • 968552 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $795,708
84.010 Title I Grants to Local Educational Agencies $376,685
10.555 National School Lunch Program $280,014
84.287 Twenty-First Century Community Learning Centers $239,576
10.553 School Breakfast Program $152,058
21.027 Coronavirus State and Local Fiscal Recovery Funds $96,345
84.367 Improving Teacher Quality State Grants $83,154
84.027 Special Education_grants to States $52,609
84.173 Special Education_preschool Grants $3,896
84.358 Rural Education $1,459
10.649 Pandemic Ebt Administrative Costs $628