Finding 400411 (2023-001)

FA 2023-001 Improve Controls over Schoolwide Consolidation Procedures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: 84.027 – Special Education Grants to States Federal Award Numbers: H027A210073 (Year: 2022), H027A220073 (Year: 2023) Questioned Costs: $47,432 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the Schoolwide Consolidation of Funds process. Background Information: A Title I schoolwide program is a comprehensive reform strategy designed to upgrade the entire educational program in a Title I school in order to improve the achievement of the lowest-achieving students. A local educational agency (LEA) may consolidate federal, state, and local funds to operate a schoolwide program. The Georgia Department of Education (GaDOE) allows approved LEAs to participate in the Consolidation of Funds Initiative. These LEAs must submit information to GaDOE, including a Consolidation of Funds budget that reflects the amounts that will be allocated by program and school and a budget for each participating federal program that reflects the amount to be contributed to the fund associated with the Schoolwide Consolidation of Funds. The Madison County Board of Education participates in the Consolidation of Funds Initiative and consolidates several different federal, state, and local fund sources, including those from the Special Education Grants to States (IDEA, Part B). While IDEA, Part B funding may be included in the Schoolwide Consolidation of Funds, there is a limit dictated by federal law, and GaDOE has incorporated the calculation for this limit into the Consolidation of Funds worksheet used to determine the school allocation percentages. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in Section 8203 of the Elementary and Secondary Education Act of 1965 (ESEA) state “… a local educational agency, with the approval of its State educational agency, may consolidate and use for the administration of one or more programs under this Act (or such other programs as the Secretary shall designate) not more than the percentage, established in each program, of the total available for the local educational agency under those programs… A State educational agency shall, in collaboration with local educational agencies in the State, establish procedures for responding to requests from local educational agencies to consolidate administrative funds… and for establishing limitations on the amount of funds under those programs that may be used for administration on a consolidated basis.” In addition, Title 34 CFR Section 200.29(c)(3) states “The school may consolidate funds received under Part B of the IDEA. However, the amount of funds consolidated may not exceed the amount received by the LEA under Part B of the IDEA for that fiscal year, divided by the number of children with disabilities in the jurisdiction of the LEA, and multiplied by the number of children with disabilities participating in the schoolwide program.” Condition: Auditors performed a review of journal entry activity associated with the Consolidation of Funds to determine if appropriate internal controls were implemented and applicable compliance requirements were met. This testing revealed that amounts in excess of those approved under the Consolidation of Funds budget were charged to the IDEA, Part B program. The School District was approved to utilize a total of $639,770 in IDEA, Part B program funds for the Consolidation of Funds. However, a total of $687,202 was expended for this purpose and resulted in an overexpenditure of $47,432. Additionally, the School District did not utilize the appropriate percentages to allocate consolidated expenditures to each participating school and program. Questioned Costs: Known questioned costs of $47,432 were identified for schoolwide expenditures that exceeded the amount approved by GaDOE. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: In discussing the deficiencies with management, they stated that internal control procedures related to consolidation of funds were not being followed appropriately. Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance, ED, and GaDOE guidance. Failure to accurately develop and amend budget information associated with the Consolidation of Funds and verify compliance with applicable policies and regulations prior to the expenditure of federal program funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unapproved and unallowable expenditures. Recommendation: The School District should review current internal control procedures related to the Consolidation of Funds. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that the appropriate amounts are allocated to each school and program. Furthermore, management should develop and implement a monitoring process to ensure that controls are operating appropriately. Views of Responsible Officials: We concur with this finding.