Finding Text
SIGNIFICANT DEFICIENCYFinding Number: 2022-001Prior Year Finding Number: N/ACompliance Requirement: Cash ManagementProgram: Teacher and School Leader Incentive ProgramFederal Assistance Listing Number: 84.374AAward #: S374A200044Award Year: 7/1/2021 ? 6/30/2022Governing Department/Agency: United States Department of EducationCriteria: The Uniform Guidance in 2 CFR section 200.305(b)(3) requires that program costs must be paid by non-federal entity funds before submitting a payment request for reimbursement.Condition: Based on testing performed over cash management, we noted that for all twelve months during the year, management requested funds for an amount that was different and often more than actual expenditures for the given month. Specifically, during November 2021, the grant team noted that the budgeted fringe rates differed from actuals. This was brought to the attention of the finance department who was unable to explain the discrepancy. Rather than requesting reimbursement based on actual expenditures, the team kept track of the discrepancy and requested reimbursement based on the budgeted amounts. Upon investigating further, it was deemed that the difference was due to the grant team miscalculating the fringe benefit due to pre-tax contributions, and therefore, the Organization requested reimbursement for an amount more than what was actually expended.Cause: Although program management has controls in place for the grant analyst to perform a reconciliation between the budgeted amounts and actual expenditures each month prior to requesting for reimbursement, discrepancies noted are not fully investigated prior to requesting funds for reimbursement. In addition, the error occurred during the period of time when the Organization?s CFO had resigned. Once a new CFO was in place, the error was identified and resolved.Effect: Without adequate controls in place to ensure that discrepancies between budget to actual expenditures are being fully investigated and resolved prior to requests for reimbursements being made, non-compliance with cash management requirements could occur and not be detected by management.Questioned Costs ? Known: $7,793.78Related Noncompliance ? NoncomplianceRecommendation: Management should strengthen the Organization?s internal controls to ensure that program staff are timely investigating and resolving all differences noted in the monthly reconciliation and only requesting reimbursement for those costs that have been expended during the month.