Finding Text
CRITERIA/SPECIFIC REQUIREMENT:
The grant award agreement between the U.S. Department of Justice and South Cook Intermediate Service Center #4 requires the South Cook Intermediate Service Center #4 to complete and submit federal financial reports quarterly and progress reports semi-annually. The quarterly financial reports are due 30 calendar days after the end of the reporting quarter while the semi-annual progress reports are due 30 calendar days after the reporting semi-annual period.
Additionally, the grant award agreement between the Regional Office of Education No. 56 and South Cook Intermediate Service Center #4 requires the South Cook Intermediate Service Center #4 to submit quarterly expenditure and GATA reports. These reports will be submitted no later than the 10 days after the end of each quarter. Also, one of the core services and required state activities is to create a Community Advisory Group.
Finally, the Code of Federal Regulations (Code) (2 CFR. §200.303 (a)) requires the South Cook Intermediate Service Center #4 to establish and maintain effective internal control over the federal award to provide reasonable assurance the South Cook Intermediate Service Center #4 is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures to ensure compliance with grant requirements.
CONDITION:
The South Cook Intermediate Service Center #4 had inadequate controls over grant compliance to ensure all grant reports during the fiscal year were timely reported and grant requirements were met. During testing of the South Cook Intermediate Service Center #4’s compliance with the grant requirements, we noted the following:
For Public Safety Partnership and Community Policing Grants -
• One of 2 (50%) quarterly federal financial reports were submitted 36 days late.
• One of 1 (100%) semi-annual performance report was submitted 47 days late.
For McKinney-Vento Education for Homeless Children and Youth -
• Four of 4 (100%) quarterly expenditure reports and the Grant Accountability and Transparency Act (GATA) reports were submitted but the South Cook Intermediate Service Center #4 was unable to provide proof of submission; therefore, we were unable to determine if the required reports were submitted timely or at all.
• South Cook Intermediate Service Center #4 did not formally establish a Community Advisory Group.
QUESTIONED COSTS:
None.
CONTEXT:
South Cook Intermediate Service Center #4 did not comply with grant requirements, as several reports were submitted late or lacked proof of submission, and a required Community Advisory Group was not established.
EFFECT:
Failure to meet grant reporting requirements is noncompliance with the related grant agreement and could result in loss of grant funding in future years. Additionally, failure to formally establish the Community Advisory Group could hinder the program's effectiveness, affect its alignment with the goals stipulated in the grant agreement, and limit the necessary support for program success and community involvement.
CAUSE:
Management indicated that the issues were due to a combination of website technical difficulties, changes in administrative access to the grant reporting system, and management oversight.
RECOMMENDATION:
We recommend the South Cook Intermediate Service Center #4 implement procedures to ensure adherence to the grant reporting requirements. In addition, we recommend that South Cook Intermediate Service Center #4 establish the advisory group as stipulated in the grant agreement.
MANAGEMENT’S RESPONSE:
The South Cook Intermediate Service Center #4 agrees with the finding. Management is in the process of developing more formal and comprehensive grant monitoring procedures that will include a checklist for all the necessary reporting and compliance requirements. Specifically for the Mc-Kinney Vento grant, formal documentation of the Community Advisory Group will be obtained in consultation with the grantor.