Garfield Heights City School DistrictLocal Government

2 C.F.R. ? 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R.??200.1 and 200.313(d). 2 C.F.R. ? 200.1 defines equipment as tangible personal property having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-Federal entity for financial statement purposes, or $5,000. 2 C.F.R. ? 200.313(d) indicates: Procedures for managing equipment whether acquired in whole or in part under Federal award, until disposition takes place will, as a minimum, meet the following standards: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award for which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. The District purchased air ionization units to be placed in each buildings HVAC air handling units with ESSER grant funds, and the units, including costs to install the units, met the definition of equipment in 2 C.F.R.?200.1. However, the District did not identify these units as equipment, as such, they did not maintain a listing of the description of the property, including the cost, acquisition date, location, etc. Additionally, since the units were not identified as equipment, the District did not have controls in place to ensure the equipment was maintained in accordance with 2 C.F.R. ? 200.313(d), including ensuring the equipment is inspected every two years and ensuring there are adequate maintenance procedures in place to keep the property in good condition. The District should review the requirements of 2 C.F.R. ? 200.313(d) and ensure all required elements for maintaining Federal equipment are followed. The District should also start by compiling a list of equipment purchased with ESSER funds, with all necessary identifying information and should develop written procedures indicating how the District will ensure the equipment is safeguarded and will be maintained in good working order. Finally, the District should ensure the equipment is still functional and properly included on the equipment listing at least every two years, and maintain a written record the inspection.

2 CFR ?200.328(b)(1) states a non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report will be due 90 calendar days after the period of performance end date. The Ohio Department of Education (ODE) reporting requirements also states "A Final Expenditure Report (FER) shall be submitted for each project no later than sixty days after the project ending date for projects applied for and funded using a paper application.? Furthermore, per ODE guidance allowable expenses obligated during the grants period of availability and paid before or during the liquidation period (July 1st ? September 30th) should be reported on the FER. Expenses are reported by object and amounts and must coincide with the entities financial records. Amounts reported on the fiscal year 2019 FER were understated by $80,895 in the District's Title I Major Federal Program. This resulted from the report being completed prior to September 30, 2019. Failure to submit an FER or correct FER discrepancies in a timely manner may result in a temporary suspension of cash payments for the project, a suspension of program operations, or termination and repayment of any or all grant awards until said project is closed. The District should ensure data for the FER is being calculated at a time that would allow for all total expenditures incurred during the period of availability and paid before or during the liquidation period to be reported to ODE.

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