Finding 398057 (2023-002)

2 CFR 3474.1 gives regulatory effect to the Department of Education for 2 CFR §200.313(d) which requires procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, at a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. The United States Department of Education (USDE) clarified in the 2023 Office of Management and Budget (OMB) Compliance Supplement, "Any purchases with Education Stabilization Fund money in this category [minor remodeling] are subject to applicable inventory control, log maintenance, and disposition requirements consistent with Part 3, Section F, “Equipment/Real Property Management” of the Compliance Supplement." Due to the lack of an internal control(s) over inventory management for equipment and real property purchased from Federal grants, a school building renovation project for the School Based Health Center, in the amount of $374,154 paid from the COVID- 19 Education Stabilization Fund - AL #84.425C Governor’s Emergency Education Relief (GEER) funding was not added to the capital asset records of the School District. Noncompliance with the requirements of Federal grants may result in the loss of current or future federal funding and possible questioned costs in future audits. The School District should establish an internal control(s) over equipment and real property paid for from Federal grants to ensure that such assets with an acquisition cost which equals or exceeds the lesser of the School District’s capitalization threshold or $5,000, are added and maintained in the capital asset records until disposition.