Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Special Education Cluster (IDEA)
Assistance Listing Number: 84.027 and 84.173
Pass-Through Agency: Colorado Department of Education
Pass-Through Numbers: 4027, 4173, 6027, and 6173
Award Period: July 1, 2022 through June 30, 2023
Compliance Requirement: Allowable Costs and Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance, Other Matters
Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with allowable costs and activities. Cherry Creek School District No. 5 (the District) should have internal controls designed to ensure compliance with those provisions.
Condition: During our testing, we noted the District did not perform the time and effort certifications for the grant period related to personnel costs charged. In addition, we noted 18 of 40 selections sampled that should not have been charged to the grant. The original personnel costs charged were removed and replaced with allowable personnel costs under the grant for the fiscal year ended June 30, 2023. The final population of personnel costs expended for the grant included supportable allowable costs. The District completed after-the-fact required time and effort certifications to support the final population of personnel costs charged to the grant for the year.
Questioned costs: None.
Context: During the year, teachers outside of the approved list of teachers per the Colorado Department of Education were charged to the grant. There was no additional review of individuals charged to the grant throughout the year. The District identified the teachers that should have been charged to the grant and replaced the costs for the fiscal year. These teachers were approved as being allowable under the grant.
Cause: The District did not follow their policy surrounding time and effort certifications and review of allowable teachers charged to the grant.
Effect: We noted an instance of noncompliance with their time and effort policy as well as their procedures surrounding review of teachers charged to the grant. The District did not identify unallowable teachers until after year end and completed the required time and effort certifications for the final population of allowable teacher personnel costs after the year ended.
Repeat Finding: No.
Recommendation: We recommend the District review their controls and procedures surrounding time and effort certifications and reviewing individuals charged to the grant to ensure allowability under the grant.
Views of responsible officials: There is no disagreement with the audit finding.