Finding Text
Allowable Activities and Costs/Cost Principles – U.S. Department of Education, COVID-19
Elementary and Secondary School Emergency Relief Fund (ESSER) (AL 84.425D) Pass-through from the
South Carolina Department of Education
Criteria: In accordance with the terms of the Education Stabilization Fund (ESF) and Title 2 U.S. Code of Federal
Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards (Uniform Guidance), charges to federal awards must, among other things: (1) be supported by a
system of internal control which provides reasonable assurance that the charges are accurate, allowable, and
properly allocated; and (2) comply with the established accounting policies and practices of the non-federal entity.
Condition and Context: For the fiscal year ended June 30, 2021, the District was not able to provide a list of
employees and the amounts charged to the ESSER program. Management was also not properly approving
expenditures and there were also missing invoices related to costs charged to the District’s federal award programs
and non-federal award programs.
We noted in our ESSER sample of payroll disbursements for testing of internal controls over compliance that the
District was unable to provide a list of employees and the amounts for each employee that was charged to the
program.
We also noted in our District-wide sample disbursements for testing of internal controls over compliance that the
majority of the checks in our sample had no approval for payment, purchase order, and that numerous invoices were
unable to be located.
Effects or possible effects: The District’s system of internal control did not identify the issue noted above and as a
result, the District did not comply with established policies required by the Uniform Guidance and the SCDOE for
charging costs to the federal program.
Cause: A lack of oversight by personnel in the Federal Programs Department led to noncompliance with the
requirements of the Uniform Guidance in relation to charging of costs to a federal grant.
Questioned Costs: $1,401,094
Recommendation: We recommend authorized purchase requisitions and purchase orders be required where
appropriate and completed prior to any encumbrance being placed on the District. Any invoice or similar document
submitted for payment should be approved by someone other than the AP clerk, with documentation that the goods
were received when applicable. We also recommend the District maintain a list of employees and amounts of each
employee charged to the program.
View of Responsible Officials and Planned Corrective Action: Management concurs with the finding.
Management will take the necessary steps in the future to ensure that all invoices are properly approved before
payment is rendered.