Half Hollow Hills Central School DistrictLocal Government

2021-001. Allowable Costs/Cost Principles Department of Education, Passed-through New York State, Department of Education Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund Assistance Listing (CFDA) No. 84.425C Condition: Upon review of the District?s FS-10F filing, it was determined that a final expenditure reported for grant funds reimbursed was based upon an amount originally encumbered for a budgeted cost in the grant, and not for an actual expenditure incurred and recorded by the District in the general ledger. Criteria: The District is required to file certain grant documents, including final grant expenditure reports (FS-10F). This FS-10F should agree to the actual expenditures recorded in the District?s general ledger for the grant period. Cause: While preparing the FS-10F, the District incorrectly recorded an amount encumbered on a purchase order in their financial software system, instead of the actual expenditures incurred for items purchased. Effect: This resulted in the District submitting an incorrect amount of reimbursement for program expenditures on their FS-10F for the Governor?s Emergency Education Relief (GEER) fund. This resulted in the District receiving a $2,500 overpayment from the New York State Education Department for this grant. Recommendation: The District should contact the New York State Education Department to determine the appropriate course of action to resolve this overpayment received. Additionally, the District should review its procedures for submitting a final FS-10F report to New York State Education Department to ensure that is it properly reviewed prior to submission, and accurately reflects the final program expenditures being requested for reimbursement. Management?s Response: The District?s Assistant Superintendent for Finance and Operations and Supervisor of Accounting and Payroll has contacted the New York State Education Department to determine the appropriate course of action for resolving the overpayment of funds collected in excess of actual expenditures. In accordance with their instructions, the District has submitted a revised FS-10F. Additionally, the District will review its procedures to ensure that a reconciliation of actual expenditures incurred agrees to the total FS-10F expenditures, prior to final submission for reimbursement from the New York State Education Department.

Significant Deficiency 2019-001. Internal Control Over Compliance Department of Education Child Nutrition Cluster School Breakfast Program CFDA No. 10.553 National School Lunch Program CFDA No. 10.555 Criteria: 2 CFR section 200.303 of the Uniform Guidance requires non-Federal entities receiving Federal awards to establish and maintain internal control over the Federal awards 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. Under the Uniform Guidance, Federal awards recipients must maintain written documentation of internal control policies and procedures, such as procurement policies that adhere to state and local law as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Condition: The District has not updated their existing policies and written procedures to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the District?s ability to perform a timely review of its existing policies and written procedures. Effect: Having insufficient or non-compliant written policies and procedures weaken the internal controls over the Federal award, increasing the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Identification of a Repeat Finding: This is not a repeat finding from the previous audit. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District?s Assistant Superintendent for Finance & Facilities will review all policies and procedures relating to US Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.

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