Finding 519157 (2024-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-01-14

AI Summary

  • Core Issue: Antonia Pantoja Charter School submitted two required quarterly reports late, violating compliance with federal reporting requirements.
  • Impacted Requirements: The school failed to meet the standards set by 2 CFR 200 for timely reporting, which could jeopardize future federal funding.
  • Recommended Follow-Up: Management should enhance procedures for preparing and submitting reports to ensure compliance and maintain cash flow.

Finding Text

2024-001 Entity: Antonia Pantoja Charter School Federal agency: U.S. Department of Education Federal program: COVID-19 Education Stabilization Fund: American Rescue Plan - Elementary and Secondary Schools Emergency Relief Funds Assistance Listing Number: 84.425U ESSER Federal Award Identification Number and Year: S425U210028, 2021 ESSER Pass-Through Agencies: Pennsylvania Department of Education Pass-Through Number: 223-21-1073 ESSER and 225-21-1073 ESSER Award Period: 03/13/2020 - 09/30/2024 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 five Reconciliation of Cash on Hand – Quarterly Reports required for ESSER due to be filed during the fiscal year. Two of the reports submitted were filed late to the Pennsylvania Department of Education. Questioned Cost: None Cause: One report was late for a month as a result of the extensive reconciliations and expense reclassifications needed to ensure the compliance of eligible grant expenses. The other report was late due to the change of the portal and the process the PA Department of Education managed for the grant Final Expenditure Report. The portal availability was well after the deadline. Effect: Noncompliance with 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 to 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 procedures 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.

Corrective Action Plan

Title funds reporting responsibilities and timeline Meeting attendants: Cynthia Marrero[grant coordinator], Janira Gonzalez[accounting supervisor], Parth Patel [senior accountant], and Xin Yi [CFO] Date: 11/19/2024 Below the clarification regarding Title Funds grant reporting:  In May, PDE issues a preliminary award for the following school year  In the first week of July, Grant Coordinator submits consolidated application with grant budget o Grant Budget (eGrants) prepared by Grant Coordinator needs to match with school-wide plan (FRCPP) by Principals o Grant coordinator will request salaries and benefits information from Payroll Director and vendor information based on plans o THe positions listed in the plan and budget need to meet twice a year. The school principals need to document it. The Grant Coordinator will communicate it. o Grant Coordinator needs to provide the award letter and the consolidated application/agreement to the Accounting Department as soon as it’s approved.  In July, Senior Accountant needs to accrue the revenues based on the preliminary allocation o The Senior Accountant needs to update the AR workpaper to reflect the allocation.  Starting in January during the school year, the Senior Accountant needs to file the quarterly cash on hand report (three reports) based on estimated expenses. The report is due by the 10th of the month following the conclusion of each quarter. o When grant expenses need to be reconciled and reclassified between Grant Coordinator and Accounting Supervisor monthly. The Accounting Supervisor sets up the recurring calendar invite. o Accounting Supervisor needs to review and confirm o The Accounting Supervisor sets up a calendar reminder for the Senior Accountant to prepare the quarterly cash on hand report and another one for the due date.  In January, Grant Coordinator will collect time and efforts certificates for positions included in the plan and budget from July (or whenever the grant period starts) to December  In February, PDE issues the revised allocation. The Grant Coordinator needs to forward those revised award letters to the Accounting Department as soon as they’re received.  In March, Senior Accountant needs to reconcile and accrue revenues based on revised allocation. If needed, a retroactive adjustment is made for year to date revenues o Senior Accountant needs to update AR work paper to reflect the revised allocation  By April, Grant Coordinator needs to submit the revised application along with the budget to match the school wide plan o The Grant Coordinator needs to send a copy of the revised consolidated agreement to the accounting department as soon as they’re approved.  In July, Grant Coordinator needs to compile the expenses for final expenditure report (FER) and submit the reports o A copy of the FER needs to be provided to the accounting department.  In July, Grant Coordinator will collect time and efforts certificates for positions included in the plan and budget from January to June  In August, the AR workpaper needs to reconciled to be audit ready in both cash receipts and revenue accrual

Categories

Allowable Costs / Cost Principles Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 519158 2024-001
    Significant Deficiency
  • 519159 2024-001
    Significant Deficiency
  • 519160 2024-001
    Significant Deficiency
  • 519161 2024-001
    Significant Deficiency
  • 519162 2024-001
    Significant Deficiency
  • 1095599 2024-001
    Significant Deficiency
  • 1095600 2024-001
    Significant Deficiency
  • 1095601 2024-001
    Significant Deficiency
  • 1095602 2024-001
    Significant Deficiency
  • 1095603 2024-001
    Significant Deficiency
  • 1095604 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.010 Title I Grants to Local Educational Agencies $754,466
84.027 Special Education Grants to States $213,129
10.553 School Breakfast Program $149,547
84.424 Student Support and Academic Enrichment Program $51,367
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $44,730
84.425 Education Stabilization Fund $22,538
84.365 English Language Acquisition State Grants $16,506
10.555 National School Lunch Program $12,006
10.649 Pandemic Ebt Administrative Costs $653
93.778 Medical Assistance Program $643