Finding Text
Significant Deficiency
2023-001. Procurement
United States Department of Education, passed through New York State Department of Education
Title I Grants to Local Educational Agencies ALN: 84.010
Special Education Cluster
Special Education Grants to States: IDEA, Part B ALN: 84.027A
Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X
Special Education Preschool Grants: IDEA Preschool ALN: 84.173A
Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X
Education Stabilization Fund (ESF)
COVID-19: Governor’s Emergency Education Relief Fund ALN: 84.425C
COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D
COVID-19: American Rescue Plan – Elementary and Secondary School
Emergency Relief (ARP ESSER) Fund ALN: 84.425U
United States Department of Agriculture, passed through New York State Department of Education
Child Nutrition Cluster
School Breakfast Program ALN: 10.553
National School Lunch Program ALN: 10.555
COVID-19: National School Lunch Program ALN: 10.555
COVID-19: Summer Food Service Program for Children ALN: 10.559
Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements.
Criteria: 2 CFR §200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Under the Uniform Guidance, federal awards recipients must maintain written documentation of internal control policies and procedures, such as procurement policies that adhere to state and local law, as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and, how to safeguard personally identifiable information.
Cause: Staffing constraints have limited the District’s ability to perform a timely review of its existing policies and written procedures.
Effect: Having insufficient or non-compliant written policies and procedures weaken internal controls over the federal awards received, increasing the risk of noncompliance with federal statutes and regulations.
Questioned Costs: None reported.
Identification of a Repeat Finding: This is a repeat finding from the previous audit referenced 2022-001.
Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance.
Views of Responsible Officials of Auditee: The District’s Assistant Superintendent for Business will work on updating all policies and procedures relating to U.S. Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.