EIN: 016005773
UEI: GSA_MIGRATION
2021-001 - Cash Management Federal Program Information: Department of Treasury: ALN - 21.019 - Coronavirus Relief Funds Criteria: The following CFR(s) apply to this finding: 2 CFR 200.514(c), 2 CFR section 200.305(b)(3). Condition: During audit procedures, it was identified that the District?s monthly federal reimbursement requests were not submitted in a timely manner subsequent to the month end. Cause: The District did not have any policies or procedures that required reimbursement requests to be submitted in a timely manner according to the requirements of the grant. Effect: The District is not minimizing the time between disbursement and reimbursement due to the delay in submissions. This increases the likelihood that errors could be made that result in an incorrect amount of funds being received by the District and creates potential cash flow issues. Identification of Questioned Costs: None identified. Context: Out of a population of 12 months of reimbursements tested, 4 months were not submitted timely. Sampling methods were not used since the entire population was tested. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the District implement internal control processes and procedures to ensure that federal reimbursements requests are submitted on a timely basis. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the District.
2021-001 Finding: Cash Management Status: Corrective Action in Progress Client Planned Action: The District concurs with the recommendation and is currently working to implement a system of tracking grant expenses in spreadsheets where they can be reviewed, totaled, invoiced and reconciled on a quarterly basis. Client Responsible Party: Tina Davidson, Business Manager and Hillary Bunker, Bookkeeper Completion Date: Invoicing using this strategy will commence July 1, 2022.
2021-002 - Procurement Federal Program Information: Department of Treasury: ALN - 21.019 - Coronavirus Relief Funds Criteria: The following CFR(s) apply to this finding: 2 CFR sections 200.318 through 200.326. Condition: During audit procedures, it was identified that the District did not have a procurement policy consistent with federal compliance standards. Cause: The District did not adopt a procurement policy consistent with current federal compliance standards. Effect: By not having a compliant federal procurement policy, the District is at increased risk for making unallowable purchases. Additionally, the District increases their risk of overpaying for goods and services by not having proper procurement procedures in place as these ensure that they purchase from the lowest priced vendor. Identification of Questioned Costs: None identified. Context: A review was conducted of the District?s procurement policy and the policy was not in compliance with Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the District adopt and use a federal procurement policy that is consistent with State, local and tribal laws and regulations and the standards of the aforementioned CFR. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the District.
2021-002 Finding: Procurement Status: Corrective Action in Progress Client Planned Action: The District concurs with the recommendation and will adopt a procurement policy that is consistent with federal compliance standards. Client Responsible Party: Monte Selby, Superintendent and Tina Davidson, Business Manager Completion Date: Policy will be brought to the school board for first read at the regularly scheduled school board meeting August 17th, 2022.
2021-003 - Allowable Costs/Cost Principles Federal Program Information: Department of Treasury: ALN - 21.019 - Coronavirus Relief Funds Criteria: The following CFR(s) apply to this finding: 2 CFR section 200.303. Applicable guidance is also contained in the Department of Treasury?s FAQs included in Federal Register Vol. 86, No. 10 dated January 15, 2021. Condition: During audit procedures, it was identified that the District did not maintain documentation for the determination of the necessity of costs due to the COVID-19 public health emergency. Cause: The District did not have any policies or procedures that required the documentation to be on file concerning the necessity of all expenses incurred against the grant funds. Effect: The District may not effectively prevent and detect costs expensed to the grant which could be determined to be unallowable costs. Identification of Questioned Costs: None identified. Context: Out of a population exceeding 250 items, 27 transactions were sampled of which all 27 items lacked the documentation for the determination of the necessity of costs due to COVID-19. The sample represented approximately $351,000 out of $560,126 of total program expenditures. This is not a statistically valid sample. Repeat Finding: This is not a repeat finding. Recommendation: It is recommended that the District implement internal control processes and procedures to ensure the completeness and accuracy of all required backup documentation to support costs expensed under the grant. Views of Responsible Officials and Corrective Action Plan: Please see the Corrective Action Plan issued by the District.
2021-003 Finding: Allowable Costs/Cost Principles Status: Corrective Action in Progress Client Planned Action: The District concurs with the recommendation and in combination with 2021-002 Finding - Procurement, the District?s adoption of a procurement policy that is consistent with federal compliance standards, the District will also maintain a description of reasoning or how a purchase aligns with spending guidelines or goals outlined in grant documents. Client Responsible Party: Monte Selby, Superintendent and Tina Davidson, Business Manager Completion Date: Following school board approval of procurement policy, records will be maintained that include procurement documentation as well as justification for the expenditures.
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