Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Assessment and Evaluation Language Resource Center
Assistance Listing Number: 84.229A
Federal Award Identification Number and Year: 7773322/GR205913
Award Period: 08/15/2018- 08/14/2023
Type of Finding:
Significant Deficiency in Internal Control over Compliance
Criteria or specific requirement: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance.
Period of performance means the time during which the non-Federal entity may incur new obligations to carry out the work authorized under the Federal award. The Federal awarding agency or pass-through entity must include start and end dates of the period of performance in the Federal award (see §§200.210 Information contained in a Federal award paragraph (a)(5) and 200.331 Requirements for pass-through entities, paragraph (a)(1)(iv)).
CAL should have internal controls designed to ensure compliance with these provisions.
Condition: We noted CAL recorded expenses to an award after the contract’s period of performance ended in August 2023. The expenses were for an event that occurred in November of 2023. CAL did not identify and properly record the timing difference.
Questioned costs: None
Context: One of the three invoices we examined were not properly reflected within the financial statements and improperly allocated to an award outside of the period of performance. Management did provide an adjustment to the financial statements and Schedule of Expenditures of Federal Awards.
Cause: The policies and procedures surrounding review of invoices and the dates costs were incurred were not consistently followed as designed.
Effect: CLA noted no instances of noncompliance with the provisions of period of performance; however, the lack of effective internal controls over compliance requirements provides an opportunity for noncompliance.
Repeat Finding: N/A
Recommendation: We recommend CAL ensure consistent application review of the dates invoice were incurred and the proper reflection within the financial statements and allocation to awards.
Views of responsible officials and planned corrective action: There is no disagreement with the audit finding. As of January 2, 2024 CAL, hired a staff account (Melanie Richards) to ensure all expenses are recorded in compliance with performance periods. The Associate Director of Finance will review all postings monthly and consult with the Vice President of Finance on any corrections or recommendations.