Finding Text
CONDITION: During my review of the District’s compliance with the laws and regulations related to filing its federal grant program ‘Quarterly Cash On Hand Reconciliations’, and ‘Final Expenditure Reports (FER)’, I noted that 1) the School District did not file the required Quarterly Cash on Hand Reconciliation for its ESSER and ARP ESSER funding for the 3rd fiscal quarter ending March 31, 2023, and 2) the School District did not file the required Final Expenditure Report (FER) for the ESSER II grant program until December 14, 2023. The report was required to be filed with the Pennsylvania Department of Education (PDE) within 30 days of the close of the grant (September 30, 2023), or as soon as funds are obligated, whichever comes first.
CRITERIA: The Department of Education requires the completion of the Quarterly Cash on Hand Reconciliation by the 10th working day after each quarter, and submission of a ‘Final Expenditure Report’ (FER) within 30 days of expending all grant funding. In addition, Section 2 CFR 200.344 of the Uniform Guidance requires the submission of financial reports no later than 90 calendar days after the end date of the grant period for performance (or an earlier date as agreed-upon by the pass-through entity and subrecipient, which in this case is 30 days as required by PDE).
EFFECT: The District is not in compliance with the financial reporting requirements for submission and/or timely submission of its Quarterly Cash on Hand Reconciliations for the 3rd fiscal quarter ending March 31, 2023, and the ‘final expenditure report’ (FER) for its ESSER II grant program in accordance with PDE policy and Section 2 CFR 200.344 of the Uniform Guidance.
QUESTIONED COST: None
CAUSE: The District had a changeover in the business office during the fiscal year and was without a business manager for a period of months, including the 3rd fiscal quarter of the District’s fiscal year which resulted in the oversight of not filing the required Quarterly Cash on Hand Reconciliations. In addition, the process of onboarding the District’s contracted third-party accountants and the necessary time needed to ensure the accuracy of the federal reporting of ESSER II funding, caused a delay in the submission of the Final Expenditure Report (FER). RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Quarterly Cash on Hand Reconciliations’ and ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions such as suspension of grant payments by PDE as a result of not filing these reports in a timely manner. These procedures should include, at a minimum, cross-training of business office personnel with regard to the completion of these reports so that the absence of one individual would not result in these reports not being filed in a timely manner.
VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.