Finding Text
Program: Special Education Cluster (IDEA)
ALN #: 84.027
Federal Agency: Department of Education
Federal Award Number: NA
Award Year: July 1, 2022–June 30, 2023
Period of Performance
Type of finding: Material weakness and noncompliance
Prior-year finding: No
Statistically valid sample: No
Criteria
Per Part 4 of the Compliance Supplement, LEAs and SEAs must obligate funds during the 27 months, extending from July 1 of the fiscal year for which the funds were appropriated through September 30 of the second following fiscal year. This maximum period includes a 15-month period of initial availability plus a 12-month period for carryover. For example, funds from the fiscal year 2019 appropriation initially became available on July 1, 2019 and may be obligated by the grantee and subgrantee through September 30, 2021 (Section 421(b) of GEPA (20 USC 1225(b)); 34 CFR sections 76.703 through 76.710). According to 2 CFR 200.303, the nonfederal entity must establish and maintain effective internal control
over the federal award that provides reasonable assurance that the nonfederal 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 be in compliance 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
During testing over period of performance for the IDEA program, 14 samples were selected for testwork. For four selections (all related to the same vendor), we noted that expenditures were charged to the SC23605 grant 52 days prior to the grant’s start date. The expenditures were invoiced on August 1, 2022, and the grant’s period of performance began on September 22, 2022 (the date the Massachusetts Department of Education notified the City of this grant’s effective date).
Cause
The cause of the noncompliance relates to an error assigning POs for a certain vendor. POs created for this vendor for July 2022 tuition were mistakenly charged to the incorrect grant. A lack of review over charges to individual grants and programs has caused the City to charge expenses to the IDEA grant outside of its period of performance.
Questioned Costs
Not determinable
Recommendation
We recommend the City establish more precise controls over the review and approval of invoices, specifically relating to the review and approval over the direct grant that the expense will be charged to.
Views of Responsible Officials and Corrective Actions
Cambridge Public Schools' CFO or Grants Coordinator will review and sign-off on all tuition requisitions that will be charged to grants to confirm the grant approval date and compliance with the period of performance.
Implementation Date
The new approval process will be in place by July 1, 2024.
Responsible Officials
Dr. Karyn Grace, Assistant Superintendent of Student Services, Cambridge Public Schools, Ivy Washington, Chief Financial Officer, Cambridge School Department, and Lindsay Smythe, Grant Coordinator, Cambridge School Department