Finding Text
2022-001. Internal Control Over Compliance United States Department of Education, passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain 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. Under the Uniform Guidance federal awards recipients must maintain updated written documentation of internal control policies and procedures, which include but are not limited to procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not yet completed updating its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: The development of a policy was delayed due to the turnover in key Business Office positions. Effect: Not having implemented the updated written policies and procedures weaken the internal controls over the federal award and could increase the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Context: During inquiries of District personnel regarding procedures, it was noted that District policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. The lack of updated policies did not result in any questioned costs or improper reimbursements. Identification of a Repeat Finding: This was part of a finding from the previous audit referenced as 2019-001 and 2020-001, related to the Child Nutrition Cluster. That same finding is related to the major programs or awards identified above, the Special Education Cluster and the Education Stabilization Fund. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District adopted a Federal Fund Procedural Manual on January 24, 2023.