Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Special Education Cluster
Assistance Listing Number: 84.027/84.173
Federal Award Identification Number and Year: 21026803 (7/1/20-9/30/22); 22015301 (10/1/20-9/30/22); 21110501 (10/1/20-9/30/22); 21110503 (7/1/20-9/30/22); 22051102 ( 7/1/21-9/30/22); 20028602 ( 7/1/21-9/30/22);
Award Period: July 1, 2020 through September 30, 2022
Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters
Criteria or specific requirement:
Compliance – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency.
Further, the Uniform Guidance in 2 CFR 200.344(b), states that unless the Federal awarding agency or pass-through entity authorized an extension, a non-Federal entity must liquidate all financial obligations incurred under the Federal award no later than 90 calendar days after the end date of the period of performance as specified in the terms and conditions of the Federal award.
Control – Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition:
The Department of Education charged costs to the program that were incurred outside of the grant award’s period of performance.
Questioned costs:
The total of expenditures charged to the program that were incurred outside of the grant’s period of performance were $63,518.
Context:
Two of Five expenditure transactions selected for testing, totaling $ 63,518.50, were incurred after the award end date of September 30, 2022.
Cause:
Accounting staff identified and charged program costs to the incorrect grant. The Program’s review process did not detect the errors nor take timely corrective action.
Effect:
The Department was not compliant with the grant’s period of performance which could result in the grantor’s disallowance of the costs.
Recommendation: We recommend that the Department review its procedures to ensure that expenditures charged to the program are incurred within the grant’s period of performance.
Views of responsible officials:
There is no disagreement with the audit finding.