Finding 4028 (2023-005)

Significant Deficiency
Requirement
H
Questioned Costs
-
Year
2023
Accepted
2023-12-13

AI Summary

  • Core Issue: Costs were charged to the grant outside the approved budget period, violating federal regulations.
  • Impacted Requirements: Non-compliance with 2 CFR 200.308, 2 CFR 200.309, and 2 CFR 200.403(h) regarding allowable costs.
  • Recommended Follow-up: Review all grant agreements to understand the period of performance and adjust internal controls to ensure compliance.

Finding Text

2023-005 – PERIOD OF PERFORMANCE Type: Significant Deficiency in Internal Control / Non-compliance Program: ALN 84.425 Education Stabilization Fund, COVID-19 - ESSER II – Credit Recovery Criteria: As detailed by 2 CFR 200.308, 2 CFR 200.309, and 2 CFR 200 403(h), A non-federal entity may only charge allowable costs incurred 1) during the approved budget period, or 2) before the approved budget period if authorized by the federal awarding agency or pass-through entity. Condition: During testing of amounts charged to the grants, it was noted that an amount charged to the grant was incurred outside the approved budget period of performance. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200. Recommendation: We recommend that the District review all grant agreements to gain a thorough understanding of the period of performance for each grant and then establish/modify internal controls to assure that only costs incurred within the approved budget period of performance are charged to the grant. View of Responsible Official: Management is in agreement with this recommendation

Corrective Action Plan

Finding Number 2023-005 — Significant Deficiency in Internal Control/Non-Compliance — Appropriate Expense Period of Covid 19-ESSER II 23b — Credit Recovery Condition: During expense testing of ESSER funds, a journal entry that reclassed the cost of Edmentum, program licenses for Plato courses, had expensed the entire annual license fee. The period for eligible expenditures did not begin until October 1, 2022. This journal entry expensed the full cost of the invoice, $11,914.50, and the district did not prorate the costs to include only those expenses from October 1, 2022 through June 30, 2023. The District did not adhere to the proper period for expenditures. Responsible Person: Carl Seiter, Director of Business Services Implementation Date: December 31, 2023 Corrective Action: Develop a summary of all federal grants. This summary will detail the fiscal year it is associated with but more importantly, it will provide the proper period of eligible expenditures for each federal funding source. This summary may be used and readily available at the time approvals are granted for expenditures. If an expense does not fall within the eligible time period, the expense can be rejected by the approver. This summary will be shared with all administrators and staff. In addition, the process for reclass journal entries will also include a pause to check that each invoice associated with a federal grant, is falling within the proper period of expenditures. Sincerely, Carl Seiter Director of Business Services Shepherd Public Schools

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 4022 2023-003
    Material Weakness Repeat
  • 4023 2023-003
    Material Weakness Repeat
  • 4024 2023-003
    Material Weakness Repeat
  • 4025 2023-003
    Material Weakness Repeat
  • 4026 2023-004
    Significant Deficiency
  • 4027 2023-006
    Significant Deficiency
  • 4029 2023-006
    Significant Deficiency
  • 580464 2023-003
    Material Weakness Repeat
  • 580465 2023-003
    Material Weakness Repeat
  • 580466 2023-003
    Material Weakness Repeat
  • 580467 2023-003
    Material Weakness Repeat
  • 580468 2023-004
    Significant Deficiency
  • 580469 2023-006
    Significant Deficiency
  • 580470 2023-005
    Significant Deficiency
  • 580471 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $431,967
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $379,121
84.010 Title I Grants to Local Educational Agencies $257,786
10.553 School Breakfast Program $126,934
93.778 Medical Assistance Program $41,381
84.424 Student Support and Academic Enrichment Program $15,474
84.367 Improving Teacher Quality State Grants $4,475
10.555 National School Lunch Program $3,557
10.649 Pandemic Ebt Administrative Costs $628