Finding Text
8. Criteria or specific requirement (including statutory, regulatory, or other citation): The compliance requirements for B. Allowability of Costs pursuant to § 200.403 state that “costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…”. Further, LEA personnel must also provide program-specific assurances related to the ESSER program when completing the grant application. These assurances are reflected in the Uniform Guidance, § 200.415 – Required Certifications, and include provisions that require LEAs “to assure that expenditures are proper and in accordance with the terms and conditions of the Federal award and approved project budgets…”. 9. Condition: A sample of 118 payroll-related expenditures were randomly selected for testing using a random sampling approach, of which included a total of 37 district employees paid & claimed under this grant. These payroll-related expenditures were reviewed to determine if appropriate internal controls were implemented and applicable compliance requirements were met. Upon completing this testing, we noted the following discrepancies:
-There were 4 employee salary & benefits claimed that were not included in the 22-4998-E3 grant budget detail. The budget specified teachers & paraprofessionals, and support staff were not included, resulting in known questioned costs of $4,857.50.
-There were 11 employees where a portion of the claimed payroll & benefits were deemed allowable per the budget but $8,947.88 was deemed not allowable, resulting in known questioned costs of $8,947.88.
-Additionally, there were $6,686.25 of the employee salary & benefits that was not deemed allowable per the budget as the pay period dates did not align with “loss of learning” related pay dates or other approved activities. 10. Questioned Costs: $20,492 of known questioned costs (based on testing 30.49% of population). $67,209 of projected questioned costs (estimate based on 100% of population). 11. Context: Upon testing a sample of $200,352.23 of payroll-related expenditures, known questioned costs of $20,491.63 were identified. Using the total salary & benefits claimed at 6/30/23 population of $722,722, we project the likely questioned costs to be approximately $67,209.45. 12. Effect: The District’s was not in compliance with the Uniform Guidance related to the ESSER program. Failure to accurately develop and amend budget information throughout the application process and verify compliance with applicable policies and regulations prior to the expenditure of federal program funds may expose the District to unnecessary financial strains and shortages as ISBE may require the District to return funds associated with unapproved and unallowable expenditures. 13. Cause: The District did not establish appropriate internal control procedures, such as a review by appropriate personnel to ensure compliance with the approved ESSER 22-4998-E3 Budget prior to the expenditure of federal funds. Additionally, the existence of multiple ESSER programs and lack of understanding of the related grant application led to the District’s failure to establish appropriate internal control procedures to ensure the expenditure was properly claimed per the approved itemized budget that funded the expenditure. 14. Recommendation: The District should develop and/or modify its policies and procedures to ensure that potential expenditures are approved are deemed to be allowable before spending federal funds. In addition, management should develop and implement a monitoring process to ensure that control procedures are being followed. 15. Management's response: The District has agreed with the findings and recommendations as presented. See Corrective Action Plan provided by the District.