EIN: 526000928
UEI: MMZ9ZBYJS881
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 25, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 25, 2026 (30 days from today).
What is a management decision? →Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 Federal Award Identification Number and Year: H027A230035 and 2023 Pass-Through Agency: Maryland State Department of Education Pass-Through Numbers: 24132402 Award Period: October 1, 2023 – September 30, 2025 Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Uniform Guidance requires non-federal entities to establish and follow documented procurement procedures that are consistent with federal procurement standards and ensure full and open competition. Such policies must address allowable procurement methods, required documentation, applicable thresholds, and approval requirements in accordance with 2 CFR §§ 200.317–200.327. Condition/Context: During testing of procurement transactions charged to the federal program, one of five procurement transactions tested did not follow the procurement requirements of Uniform Guidance. Specifically, the required procurement method was not properly applied and supporting documentation was insufficient to demonstrate compliance with federal procurement standards. Questioned Costs: None Cause: The Board’s procurement policies were not fully compliant with federal procurement requirements under Uniform Guidance. As a result, internal controls did not adequately ensure that procurement transactions charged to federal programs complied with applicable federal standards prior to payment. Effect: Procurement policies that are not aligned with federal requirements increase the risk of noncompliance with Uniform Guidance, potentially resulting in disallowed costs, reduced competition, or the need for corrective action by the pass-through or federal awarding agency. Repeat Finding: No Recommendation: We recommend the Board revise its procurement policies to fully align with Uniform Guidance requirements and strengthen internal controls to ensure procurement transactions charged to federal awards are reviewed for compliance prior to payment. This should include updated policy guidance, staff training, and documented supervisory review. Views of Responsible Officials: The Board concurs with the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 Federal Award Identification Number and Year: H027A230035 and 2023 Pass-Through Agency: Maryland State Department of Education Pass-Through Numbers: 24132402 Award Period: October 1, 2023 – September 30, 2025 Compliance Requirement: Procurement Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Uniform Guidance requires non-federal entities to establish and follow documented procurement procedures that are consistent with federal procurement standards and ensure full and open competition. Such policies must address allowable procurement methods, required documentation, applicable thresholds, and approval requirements in accordance with 2 CFR §§ 200.317–200.327. Condition/Context: During testing of procurement transactions charged to the federal program, one of five procurement transactions tested did not follow the procurement requirements of Uniform Guidance. Specifically, the required procurement method was not properly applied and supporting documentation was insufficient to demonstrate compliance with federal procurement standards. Questioned Costs: None Cause: The Board’s procurement policies were not fully compliant with federal procurement requirements under Uniform Guidance. As a result, internal controls did not adequately ensure that procurement transactions charged to federal programs complied with applicable federal standards prior to payment. Effect: Procurement policies that are not aligned with federal requirements increase the risk of noncompliance with Uniform Guidance, potentially resulting in disallowed costs, reduced competition, or the need for corrective action by the pass-through or federal awarding agency. Repeat Finding: No Recommendation: We recommend the Board revise its procurement policies to fully align with Uniform Guidance requirements and strengthen internal controls to ensure procurement transactions charged to federal awards are reviewed for compliance prior to payment. This should include updated policy guidance, staff training, and documented supervisory review. Views of Responsible Officials: The Board concurs with the finding.
Special Education Cluster – Assistance Listing No. 84.027 Recommendation: We recommend the Board revise its procurement policies to fully align with Uniform Guidance requirements and strengthen internal controls to ensure procurement transactions charged to federal awards are reviewed for compliance prior to payment. This should include updated policy guidance, staff training, and documented supervisory review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Action Plan: CCPS Purchasing Department will make the following changes to our current purchasing policy manual to comply with the Audit recommendation above: Noncompetitive bidding (written justification and purchase desc. Docs require) $ 0 - 5K threshold. Informal bidding (3) price quotes required for $5k - $25,000 purchase threshold with no exceptions for MOI. Formal Bidding required at 25K or greater (ITB, RFP, RFQ’s etc) Require purchase justification for all purchases regardless of dollar threshold Require authorized signature approval based on our current dollar threshold for all purchases Name(s) of the contact person(s) responsible for corrective action: Nelson E. Sample, CPPO, Procurement Manager Planned completion date for corrective action plan: No later than June 30,2026
Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.173 Federal Award Identification Number and Year: H173A240089 and 2024 Pass-Through Agency: Maryland State Department of Education Pass-Through Numbers: 25033401 Award Period: July 1, 2024 – September 30, 2026 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Uniform Guidance (2 CFR §200.403 and §200.309) requires that costs charged to a federal award be incurred during the approved period of performance and be allowable, allocable, and reasonable for the federal program. Costs incurred before the start date of the award period are not allowable unless specifically authorized by the federal awarding or pass-through agency. Condition/Context: During testing of expenditures charged to the Special Education Cluster, it was noted that one of three transactions tested were incurred and charged to the federal program prior to the beginning of the approved period of performance. Questioned Costs: $4,157.27 Cause: The Board did not have sufficient internal controls in place to ensure that expenditures charged to federal awards were reviewed for period-of-performance allowability prior to posting and payment. Effect: Charging expenditures incurred outside the approved period of performance increases the risk of unallowable costs, potential repayment to the pass-through or federal awarding agency, and noncompliance with Uniform Guidance requirements. Repeat Finding: No Recommendation: We recommend that the Board strengthen internal controls over federal grant expenditure by implementing procedures to ensure costs are incurred within the approved period of performance prior to being charged to federal awards. This should include enhanced supervisory review, system controls where feasible, and training for staff responsible for grant accounting and compliance. Views of Responsible Officials: The Board concurs with the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.173 Federal Award Identification Number and Year: H173A240089 and 2024 Pass-Through Agency: Maryland State Department of Education Pass-Through Numbers: 25033401 Award Period: July 1, 2024 – September 30, 2026 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Uniform Guidance (2 CFR §200.403 and §200.309) requires that costs charged to a federal award be incurred during the approved period of performance and be allowable, allocable, and reasonable for the federal program. Costs incurred before the start date of the award period are not allowable unless specifically authorized by the federal awarding or pass-through agency. Condition/Context: During testing of expenditures charged to the Special Education Cluster, it was noted that one of three transactions tested were incurred and charged to the federal program prior to the beginning of the approved period of performance. Questioned Costs: $4,157.27 Cause: The Board did not have sufficient internal controls in place to ensure that expenditures charged to federal awards were reviewed for period-of-performance allowability prior to posting and payment. Effect: Charging expenditures incurred outside the approved period of performance increases the risk of unallowable costs, potential repayment to the pass-through or federal awarding agency, and noncompliance with Uniform Guidance requirements. Repeat Finding: No Recommendation: We recommend that the Board strengthen internal controls over federal grant expenditure by implementing procedures to ensure costs are incurred within the approved period of performance prior to being charged to federal awards. This should include enhanced supervisory review, system controls where feasible, and training for staff responsible for grant accounting and compliance. Views of Responsible Officials: The Board concurs with the finding.
Special Education Cluster – Assistance Listing No. 84.173 Recommendation: We recommend that the Board strengthen internal controls over federal grant expenditure by implementing procedures to ensure costs are incurred within the approved period of performance prior to being charged to federal awards. This should include enhanced supervisory review, system controls where feasible, and training for staff responsible for grant accounting and compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To address this issue, the Board will implement the following corrective actions: 1. Enhanced Review Procedures: All payroll journal entries to reclassify expenditures charged to federal grants will be reviewed by Lead Staff Accountant and/or Budget Manager to verify that the time worked along with the transaction accounting date falls within the approved grant period of performance prior to posting. 2. System and Process Improvements: The Board will explore report customizations regarding payroll transactions to provide more visibility of the actual days worked regardless of the transaction accounting date. This system improvement will help prevent payroll journal entry reclassifications from being charged to grants outside of the approved period of performance. These procedures will strengthen internal controls over federal grant expenditures and help ensure compliance with federal regulations. Name(s) of the contact person(s) responsible for corrective action: Sherri Fisher-Davis Planned completion date for corrective action plan: March 2026
FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.
Federal Agency: U.S. Department of the Treasury Federal Program Name: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 500142-8 and 2021 Pass-Through Agency: Maryland State Department of Education Pass-Through Numbers: 211760501, 21178701, 21182601, 21184201, 21185801, 21188501, and 21193001 Award Period: March 3, 2021 through December 31, 2024 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition/Context: Two of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per sam.gov, there was no history of the vendor being suspended or debarred. Questioned costs: None Cause: The Board's policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with federal grant funds. Effect: The Board could make a disbursement to a vendor that is suspended or debarred. Repeat Finding: No Recommendation: We recommend the Board review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Views of responsible officials: The Board concurs with the finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of the Treasury Federal Program Name: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 500142-8 and 2021 Pass-Through Agency: Maryland State Department of Education Pass-Through Numbers: 211760501, 21178701, 21182601, 21184201, 21185801, 21188501, and 21193001 Award Period: March 3, 2021 through December 31, 2024 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition/Context: Two of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per sam.gov, there was no history of the vendor being suspended or debarred. Questioned costs: None Cause: The Board's policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with federal grant funds. Effect: The Board could make a disbursement to a vendor that is suspended or debarred. Repeat Finding: No Recommendation: We recommend the Board review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Views of responsible officials: The Board concurs with the finding.
Suspension and Debarment - Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend the Board review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CCPS will require verification that an entity isn’t suspended or debarred through sam.gov for every purchase order issued. The documentation with headers and footers showing the date that it is verified will be attached to every purchase order before it is issued and before any payments are made. CCPS policy is to have purchase orders for all transactions except in the case of an emergency. If an accounts payable check is issued without a purchase order, accounts payable will get the sam.gov report from purchasing and attach the report before issuing the check. To ensure that all purchase orders have a suspension and debarment search, the Purchasing Assistant will update the desk reference to include the requirement for a suspension and debarment search to be completed before a purchase order can be issued and that it must be date stamped and attached to each purchase order. Name of the contact person responsible for corrective action: Nelson Sample Planned completion date for corrective action plan: July 2024 If the Department of the Treasury has questions regarding this plan, please call Sherri Fisher-Davis at 301-934-7352.
FAC accepted this audit on January 18, 2023 — management decision was due July 18, 2023.
Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Education Federal Program Name: Special Education Cluster Assistance Listing Number: 84.027 and 84.173 Federal Award Identification Number and Year: H027A160035-2017 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 18052801 Award Period: July 1, 2017 through September 30, 2019 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award?s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award 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. These internal controls should comply 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: Costs were incurred and charged to the grant after the allowable end of the period of performance. Questioned costs: Undetermined. Context: One out of thirty-seven grants under this Special Education Cluster had expenditures charged to the grant after the allowable period of performance. Cause: The Board did not have proper internal controls and procedures to ensure that expenditures charged to the grant were incurred within the award?s period of performance. Effect: Costs could be deemed unallowable by the awarding agency if funds are expended outside of the allowable period of performance. Repeat Finding: No Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Views of responsible officials: There is no disagreement with the audit finding.
U.S. Department of Education 2022-004 Special Education Cluster ? Assistance Listing No. 84.027 and 84.173 Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Fiscal Services will improve internal controls over the procedures that ensure expenditures to a program are incurred within an award?s allowable period of performance. During the year-end close out process, the Lead Restricted Funds Accountant will review the close out of all restricted funds against the grant periods. If expenditures are inadvertently incurred outside of the grant period, the expenditures will be reclassified to an existing like grant if allowable or to the operating budget. If the Lead Restricted Funds Accountant is unavailable or has closed out grants themselves, this review will be done by the Budget Manager. The school district will implement a new financial system in July 2023. The implementation of this new system will allow for more automated internal controls. Name(s) of the contact person(s) responsible for corrective action: Rosa Aquino and/or Sherri Fisher-Davis Planned completion date for corrective action plan: December 31, 2022
FAC accepted this audit on December 27, 2018 — management decision was due June 27, 2019.
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