Finding Text
2022-001 Equipment and Real Property Management Education Stabilization Fund (ESSER) ? ALN 84.425 Criteria: Pursuant to 2 CFR part 200 section 439, capital expenditures for equipment and other capital expenditures are allowable as direct costs, provided that items with a unit cost of the lessor of $5,000 or the entity?s capitalization threshold have the prior written approval of the Federal awarding agency or pass-through entity. Furthermore, section 313(d)(1) specifies that property records must be maintained that include a description of the property, a serial or identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property. Condition: During testing it was noted the District performed building improvements over the capitalization threshold using ESSER funds without receiving prior approval from the Pennsylvania Department of Education. This asset also not included in the District?s property records. Cause: Due to staff oversight, the District did not consider all capital expenditures when obtaining prior approval from the Pennsylvania Department of Education. Effect: Internal controls are not functioning as designed and the District is not in compliance with equipment and real property management requirements of the program. Questioned Costs: None Recommendation: The District should establish procedures to ensure all capital expenditures with grant funding is appropriately approved prior to purchase and property records are maintained in sufficient detail to allow for the adequate tracking of all equipment purchased with grant funds. Management?s Response: There was confusion on the District?s part of what the threshold was for Capital Expenditures. Often times grants filing dates were due prior to all instructions being received. While the District unintentionally did not seek prior written approval for this purchase, it did clearly identify this purchase in the budget overview section in the E-Grant application for which it was approved. The District will subsequently identify and correctly maintain these assets to comply with federal property records. Now that the District is fully aware of the capital expenditure threshold, this should not occur again.