Finding Text
Criteria or specific requirement (including statutory, regulatory, or other citation) - Per 2 CFR Subpart E- Cost Principles Part 200.403 (g) states that except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards "(g) Be adequately documented." Per Part 200.413 (a) Direct costs are those costs that can be identified specifically with a particular final cost objective. Condition - The Special Education District prepared, and the cognizant agency approved, a grant budget that included $637,216 of salaries for learning loss, summer enrichment and after school programs (run by member districts). The Special Education District claimed grant expenditures for payments to member districts as salaries. Questioned Costs - Unknown. Context - The Special Education District budgeted and claimed salaries on grant expenditure reports however these expenditures were not salaries incurred directly by the Special Education District, but rather payments to member districts. The grant agreement stipulated that "no subcontracts or sub-grants are allowed without prior written approval of the State Superintendent of Education. If subcontracts or sub-grants are allowed, then all project responsibilities are to be retained by the grantee to ensure compliance with the terms and conditions of the grant. All subcontracts and sub-grants must be documented and must have the prior written approval of the State Superintendent of Education. Approval of subcontracts and sub-grants shall be subject to the same criteria as are applied to the original proposal/application. " Effect - Grant expenditures claimed as salaries on the expenditure reports were payments to member districts which no invoice, representations, or documented by the member districts to the Special Education District as to how the funds were used. Cause - The Special Education District disbursed funds, without documentation, to member districts. Recommendation - We recommend that in the future the Special Education District prepare grant budgets that align with the expected grant expenditures and that expenditures be adequately documented as to the use of funds. Management's response - Management does not agree with this finding. Management reached out to the cognizant agency which provided the following response - "The ESSER III Cooperative grant was state set-aside funds that were originally awarded to ISBE. ISBE determined that to meet the stipulations of Learning Loss-Summer Enrichment-After School Program reservations, the most efficient way to reach the maximum number of students would be through the cooperatives providing for their member districts. Henry-Stark County Special Education District met those requirements and fulfilled their financial obligations by providing evidence-based activities through their member districts"