Finding Text
Significant Deficiency
Other Noncompliance
Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster
Assistance Listing 84.010A - Title I Grants To Local Educational Agencies
Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA)
Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund
(ESSER II)
Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund
(ARP ESSER)
Repeat Finding: Yes
Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal
control over a federal award that provides reasonable assurance that the non-federal entity is
managing the federal award in compliance with federal statues, regulations, and the terms and
conditions of the federal award.
2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from
the date of submission of their final financial report. For awards that are renewed quarterly or
annually, the recipient and subrecipient must retain records for three years from the date of
submission of their quarterly or annual financial report, respectively. Records to be retained
include but are not limited to financial records, supporting documentation, and statistical
records. Federal agencies or pass-through entities may not impose any other record retention
requirements except records must be retained until all litigation, claims, or audit findings
involving the records have been resolved and final action taken if any litigation, claim, or audit
is started before the expiration of the three-year period.
Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the
District’s grant expenditures from major programs, we observed the following instances where
information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200
as follows was not obtained by the District or was otherwise unavailable for our examination:
Sixteen instances where there was no documentation to determine the District obtained the
required information to ensure that the vendor was not suspended or debarred.
One instance where there was no invoice or credit memo to support the transaction.
Numerous instances where an invoice was not included in the paid invoice. These invoices
were made available to us for our examination on our fourth request
Context/
Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash
disbursements charged to major programs of the District.
Effect: Failure to follow the federal and state requirements could affect future eligibility for federal
award programs or could result in a loss or misappropriation of public assets.
Questioned Costs: None
Recommendation: We recommend that the District implement additional internal controls as necessary to ensure
that proper records are maintained to adequately document its expenditures charged to federal
grant programs.
Views of
Responsible
Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.