Finding Text
2023‐004 Unallowable Costs
Federal Program, Assistance Listing # and Year, Federal Agency, Pass‐Through Entity:
Title I Grants to Local Educational Agencies, Assistance Listing #84.010, 2023, U.S. Department of
Education, Louisiana Department of Education.
21st Century Community Learning Center Cohort, Assistance Listing #84.287, 2023, U.S. Department of
Education, Louisiana Department of Education.
Education Stabilization Fund, Assistance Listing #84.425DUW, 2021, U.S. Department of Education,
Louisiana Department of Education.
Criteria or Specific Requirement: 2 CFR 200.303 requires the entity to establish and maintain effective
internal controls over compliance with respect to federal awards and Section 1111(b)(2)(A) of the ESEA
for compliance accountability. Proper internal controls require supporting documentation to be
retained as evidence for effectiveness of the controls in place.
Condition: During our testwork, we were made aware of the following instances of internal control
related matters and instances of noncompliance related to one employee:
The employee was paid through the 21st Century Community Learning Center Cohort program
for 80 hours in the month of July 2022 without authorization from the Human Resources
department in order to shadow train for the program director position. Five of the hours paid
for was during the 4th of July holiday.
The employee did not become employed as the program director for the 21st Century
Community Learning Center Cohort program and decided not to return to work.
The employee was docked 14 days sick leave, which was subsequent reinstated by the former
superintendent adding back to the employee’s sick leave bank.
The employee went on undocumented sick and extended sick leave where the employee’s
wages and benefits were coded to the Title I program. These expenses were then improperly
included in the reimbursement requests for the Title I program.
The employee received a $1,000 COVID‐19 supplement paid through the Education Stabilization
Fund grants during the year.
Effect: The School Board charged expenditures and requested reimbursement for
unallowable/unauthorized costs.
Questioned Cost: The total questioned cost expended by the School Board was $88,072 broken down
as follows:
Title I ‐ $83,800
21st Century Learning Center Cohort ‐ $3,024
Education Stabilization Fund ‐ $1,248
Cause: Lack of internal controls related to review of costs and management override of controls.
Recommendation: We recommend the School Board implement policies and procedures to ensure
costs are appropriately charged to programs.
Views of responsible officials and corrective action plan: The School District concurs with the findings
reported not dispute the details reported. The findings identify charging of unallowable costs that
involved federal funds received by the School District. It was noted that the unallowable costs involved
payment of employment compensation to an employee on multiple dates, during times and for reasons
that were suspect and unauthorized. The School District concurs with the guidance provided. Corrective
actions are already being taken, and training has already begun. The School Board will adopt
appropriate policies to ensure appropriate oversight over the manner in which funding is expended for
employee compensation, including situations when the sources of funding involve federal awards that
obligate the School District to meet specific federal compliance control requirements.