Finding Text
2022-02 Entity: KIPP Philadelphia Charter School Federal agency: U.S. Department of Education Federal program: Education Stabilization Fund: Elementary and Secondary School Emergency Relief (ESSER) Fund Governor?s Emergency Education Relief (GEER) Fund Assistance Listing Number: 84.425C GEER and 84.425D ESSER Federal Award Identification Number and Year: S425C200013, 2020 GEER S425D210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 254-20-0669 GEER and 200-21-0669 ESSER Award Period: 03/13/2020 - 09/30/2021 GEER and 03/13/2020 - 09/30/2023 ESSER Type of Finding: ? Other Matter ? Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200, Cost Principles for Nonprofit Organizations requires compliance with the provisions of reporting. 2 CFR 200.303 states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Organization is responsible for having internal controls designed to ensure compliance with this provision. The Reconciliation of Cash on Hand ? Quarterly Report is a required filing for projects that received payments in a previous quarter. The report must be filed no later than the 10th working day following the quarter just ended. Condition: During our testing of reporting submissions through the Pennsylvania Department of Education?s Financial Accounting Information website, we noted there were two Reconciliation of Cash on Hand ? Quarterly Reports required for ESSER and three Reconciliation of Cash on Hand ? Quarterly Reports for GEER due to be filed during the fiscal year. All reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: Prior to the pandemic, the finance team consisted of three roles ? a Managing Director of Finance, a Director of Financial Planning and Analysis, and an Accounting Manager. Additionally, the operational accounting work was outsourced to a third-party vendor, EdOps. With the significant influx of ESSER dollars and the corresponding spending, the team did not have the capacity to meet the additional grant tracking and reporting deadlines. Effect: Noncompliance to the reporting requirements as described in both the grant awards and 2 CFR 200, Subpart E, Cost Principles for Nonprofit Organizations could ultimately lead to the scheduled monthly payments be suspended due to the delinquent submission of the Reconciliation of Cash on Hand ? Quarterly Report. Recommendation: To ensure accountability with the required reporting to the Pennsylvania Department of Education, we recommend management review and update to procedure to establish consistent preparation, review, and submission of all program reports to ensure reporting requirements are being met. Such controls would ensure timely and accurate reporting being produced and optimum cash flow management. Views of Responsible Officials: Management agrees with the finding.