FAC Explorer

Finding 522347 (2024-004)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-02-07
Audit: 341604
Organization: Region One Education Service Center (TX)
Auditor: Burton McCumber & Longoria LLP

AI Summary

  • Core Issue: The Center is not using formal subaward agreements with subrecipients, leading to noncompliance with federal requirements.
  • Impacted Requirements: The lack of agreements violates 2 CFR section 200.332(b)(1) and the newly amended 34 CFR 75.127 through 75.129.
  • Recommended Follow-Up: Management should implement the new guidance and ensure formal agreements are established with all subrecipients to meet compliance standards.

Finding Text

Reference Number 2024-004 Subaward Agreements Federal Awards: GEAR UP (ALN 84.334A) Criteria and Condition: A pass-through entity must clearly identify to the subrecipient; (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(b)(1); (2) all requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award; and (3) any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility for the federal award. We noted a formal subaward agreement outlining all the required information is not prepared and executed by the Center (pass-through entity) and its subrecipients. Amended guidance was communicated to the Center as 34 CFR 75.127 through 75.129 was amended on August 29, 2024. Under this new guidance, an agreement that details the activities that each member of the group plans to perform, and binds each member of the group to every statement and assurance made by the application will be required on an ongoing basis. The Center intends to comply with this requirement on an ongoing basis. Cause and Effect: The Center provides separate documents to its subrecipients such as the District/Campus Commitment Form that outlines some of the applicable compliance requirements and a Program Budget Award Worksheet. A formal subaward agreement executed by both parties containing all the information required by 200.332(b)(1) is not in place. This results in noncompliance with subrecipient monitoring requirements. Repeat Finding from Prior Year(s): N/A Questioned Costs: $0 Recommendation: As 34 CFR 75.127 through 75.129 was amended on August 29, 2024, we recommend management implement this guidance and maintain formal agreements between the Center and the subrecipients/partners in the program. Views of Responsible Officials: See management’s corrective action plan.

Corrective Action Plan

2024-004 Subaward Agreements The Center is the recipient of GEAR UP awards based on prior grant applications submitted with its related program partners which include local educational agencies and other partners. While the audit revealed that no formal agreement was in place during the audit year, the Center did have documentation in place with each partner that included a detailed budget, program operating procedures manual, partner commitment form signed by each partner’s superintendent of schools, program monthly meetings, onsite visits, and other activities stipulated in the grant. A new program requirement was published on August 29, 2024, as amended in 34 CFR 75.127 through 75.129 for future Partnership Grants Application and includes language related to a binding agreement. The Center will ensure all future grant applications comply with this new requirement. Proposed Completion Date: February 1, 2025 Name of contact person: Rumalda Ruiz, Deputy Director - Business, Operations, & School Finance Support Contact: (956) 984-6290

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 522334 2024-002
    Significant Deficiency
  • 522335 2024-002
    Significant Deficiency
  • 522336 2024-002
    Significant Deficiency
  • 522337 2024-002
    Significant Deficiency
  • 522338 2024-002
    Significant Deficiency
  • 522339 2024-002
    Significant Deficiency
  • 522340 2024-002
    Significant Deficiency
  • 522341 2024-002
    Significant Deficiency
  • 522342 2024-002
    Significant Deficiency
  • 522343 2024-002
    Significant Deficiency
  • 522344 2024-003
    Significant Deficiency
  • 522345 2024-003
    Significant Deficiency
  • 522346 2024-003
    Significant Deficiency
  • 522348 2024-004
    Significant Deficiency
  • 522349 2024-004
    Significant Deficiency
  • 1098776 2024-002
    Significant Deficiency
  • 1098777 2024-002
    Significant Deficiency
  • 1098778 2024-002
    Significant Deficiency
  • 1098779 2024-002
    Significant Deficiency
  • 1098780 2024-002
    Significant Deficiency
  • 1098781 2024-002
    Significant Deficiency
  • 1098782 2024-002
    Significant Deficiency
  • 1098783 2024-002
    Significant Deficiency
  • 1098784 2024-002
    Significant Deficiency
  • 1098785 2024-002
    Significant Deficiency
  • 1098786 2024-003
    Significant Deficiency
  • 1098787 2024-003
    Significant Deficiency
  • 1098788 2024-003
    Significant Deficiency
  • 1098789 2024-004
    Significant Deficiency
  • 1098790 2024-004
    Significant Deficiency
  • 1098791 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $5.60M
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $1.18M
84.184 School Safely National Activities $1.08M
84.181 Special Education-Grants for Infants and Families $878,233
10.560 State Administrative Expenses for Child Nutrition $713,091
84.422 American History and Civics Education $601,722
84.215 Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Directed Spending for Elementary and Secondary Education Community Projects $496,682
93.327 Demonstration Grants for Domestic Victims of Human Trafficking $475,828
93.778 Medical Assistance Program $378,480
84.051 Career and Technical Education -- National Programs $310,263
84.047 Trio Upward Bound $292,316
84.425 Education Stabilization Fund $283,925
84.066 Trio Educational Opportunity Centers $281,021
84.411 Education Innovation and Research (formerly Investing in Innovation (i3) Fund) $261,143
84.011 Migrant Education State Grant Program $225,302
84.002 Adult Education - Basic Grants to States $208,859
84.010 Title I Grants to Local Educational Agencies $162,042
84.027 Special Education Grants to States $144,443
93.434 Every Student Succeeds Act/preschool Development Grants $111,887
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $95,973
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $80,913
93.558 Temporary Assistance for Needy Families $72,344
84.196 Education for Homeless Children and Youth $69,009
84.048 Career and Technical Education -- Basic Grants to States $45,716
84.999 Esc Essa Basic Services - 6000 $42,111
84.424 Student Support and Academic Enrichment Program $17,980
84.365 English Language Acquisition State Grants $7,163
84.173 Special Education Preschool Grants $4,169
93.575 Child Care and Development Block Grant $1,365
84.144 Migrant Education Coordination Program $265