Finding Text
Reporting – Noncompliance and Material Weakness
Finding Number: 2024-003
Assistance Listing Number and Title: AL #21.027 COVID-19 State and Local Fiscal Recovery Funds K-12 School Safety Grant
Federal Award Identification Number / Year: OFCC-SS3-34180
Federal Agency: U.S. Department of Treasury
Compliance Requirement: Reporting
Pass-Through Entity: Ohio Office of Budget and Management
Repeat Finding from Prior Audit? No
2 CFR 1000.10 gives regulatory effect to the U.S. Department of Treasury for 2 CFR 200.332 which states, in part, pass-through entities must ensure every subaward includes requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. The District’s major federal program, COVID-19 State and Local Fiscal Recovery Funds K-12 School Safety Grant Program’s pass-through entity is the Ohio Office of Budget and Management (OBM). The Frequently Asked Questions relating to this program requires recipient schools to complete quarterly financial status reports via the OBM grants portal until they have spent all funds and completed their projects. Additionally, all recipients in the reporting portal are required to separate out expenditures by capitalized or non-capitalized based on the State of Ohio’s capitalization thresholds.
The District did not have proper internal controls in place to ensure the accurate completion and submission of the quarterly financial status reports. The District failed to maintain supporting documentation for all quarterly financial reports. Additionally, we noted the following individual errors:
• The District failed to maintain documentation of when the reports were submitted, therefore we were unable to determine if the reports were submitted by the required due date;
• The reported current period expenditures did not agree to District records for four of the five reports selected for testing (or 80%);
• The reported current period obligations encumbered did not agree to District records for one of the five reports selected for testing (or 20%);
• The District did not follow the applicable State of Ohio capitalization threshold, therefore expenditures totaling $275,019 were improperly reported as capitalized rather than non-capitalized.
Failure to have the proper controls in place to ensure the accurate submission of the quarterly financial status reports could result in the OBM or Treasury taking action against the District for failure to comply with programmatic requirements.
The District should implement controls to ensure supporting documentation is maintained for the quarterly expenditure reports in addition to being completed accurately and submitted timely.