Finding 538258 (2024-004)

2024-004 Program Income CFDA Title: Twenty-First Community Learning Centers CFDA Number: 84.287 Federal Award Number: S287C2300026, 2024 Federal Agency: Department of Education Pass-through Entity: Montana Office of Public Instruction Condition: The District did not comply with the program income compliance requirement for the Twenty-First Century Community Learning Center Grant. Criteria: In the 2024 Compliance Supplement, under Part 4 Department of Education, page 187 for Program Income related to the Twenty-First Century Community Learning Center grant, it states that a recipient or subrecipient that earns program income must deduct the amount of program income from the amount of the Federal award unless it has received prior written approval from ED to add the amount of program income to the amount of the Federal award. If the recipient or subrecipient receives prior written approval to add the amount of program income to the Federal award, the program income must be used for the purposes and under the conditions of the Federal award. Context: As part of the federal compliance testing for the Twenty-First Century Community Learning Centers Grant, we tested to determine if the District charged fees associated with the program. Effect: The District was not incompliance with the program income requirement as they charged $88,465 in fees under the after school program without approval and did not deduct that amount from the amount requested for reimbursement under the grant. They were awarded $352,177 and were given the full $352,177 under requests for reimbursement. Cause: The District operates one after school program. There are kids that are free under the program and others that are charged. They keep two separate project reporter codes (PRCs) within their system. One PRC is for the Twenty-First Century Community Learning Centers Grant which the free kids and the other is for the kids that are charged. They have only one set of coordinators/aides/program directors that runs the overall program. They allocate costs for both payroll and other expenses between the two PRCs. The District thought if they kept two separate PRCs that they could charge. Recommendation: We recommend that the District ensure that either it gets preapproval from the granting agency prior to charging fees, or they deduct the amount charged for the federal grant and request reimbursement for that much less.