Finding Text
Significant Deficiency
2024-001. Equipment and Real Property Management
United States Department of Education, Passed Through New York State, Department of Education:
Education Stabilization Fund
COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D
COVID-19: American Rescue Plan - Elementary and Secondary
School Emergency Relief Fund ALN: 84.425U
Criteria: Education Stabilization Fund (ESF) grant awards authorized under the federal Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act and American Rescue Plan Act of 2021 (ARP) may be used for equipment purchases and capital expenditures, consistent with federal regulations 2 CFR §200.313 and 2 CFR §200.439. In accordance with 2 CFR §200.313, non-federal entities receiving federal awards are required to have procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a federal award, until disposition takes place. This includes maintaining property records that include a description of the property, a serial number or other identification number, the source of funding for the property, including the Federal Award Identification Number (FAIN), and who holds title. In addition, it requires non-federal entities to track the acquisition date and cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. A physical inventory of the property acquired with federal awards must also be taken and the results reconciled with the property inventory records at least once every two years.
Condition: The District did not include capital expenditures paid with CRRSA and ARP grant funds in its capital assets inventory records.
Cause: The District uses specific expenditure codes in its special aid fund to identify and track capital expenditures incurred that are reimbursable under the CRRSA and ARP grant awards; those capital expenditure codes are different from the District’s standard object code (.200) for equipment purchases. Due to a clerical oversight, those capital expenditures recorded in the special aid fund were inadvertently left off the District’s end-of-year list of annual capital assets additions that would be used to update its capital assets inventory records.
Effect: Not including and differentiating capital assets acquired with federal awards in the District’s capital assets inventory records could lead to improper or non-compliant procedures for the disposal of those capital assets.
Questioned Costs: None reported.
Context: The District upgraded the HVAC systems at its buildings using CRRSA and ARP grant awards during the 2023-2024 fiscal year. Before the CRRSA and ARP grants, the District had never used grant awards to pay for capital improvement projects and thus, District personnel was not accustomed to reviewing expenditure codes in the special aid fund other than the equipment purchases expenditure codes when compiling the listing of equipment and capital expenditures during the year for the District’s third-party capital assets management company to update its capital assets inventory record.
Identification of a Repeat Finding: This is not a repeat finding from the immediately prior audit.
Recommendation: The District should revise its existing procedures for compiling annual capital assets additions information to ensure equipment and capital expenditures recorded in all of the District’s governmental funds are considered and evaluated for inclusion in the District’s annual capital assets inventory records.
Views of Responsible Officials of Auditee: Management agrees with the finding and will ensure that equipment and capital expenditures paid with federal funds are identified and included in the District’s fixed assets inventory records as part of the annual fixed assets reconciliation process.