CENTER FOR HEIRS' PROPERTY PRESERVATIONNon-Profit

Internal Control over Compliance with Reporting Condition: The District did not have sufficient controls in place within its ESSER II grant program to ensure compliance with the Reporting requirement. Criteria: The District is required to prepare SCDE financial reports that are complete and submitted in a timely manner. The proper submission of claims in the State?s online GAPS software satisfies the Reporting compliance requirement. Therefore, the internal controls over the Reporting compliance requirement should include policies and procedures that ensure accurate and timely claims are submitted. Effect of Condition: Internal controls over Reporting requirement were considered deficient, which could be viewed as a violation of the award agreement. Additionally, the deficient controls did not prevent or detect material noncompliance with the Reporting compliance requirement as described in finding 2022-010. Cause: While sufficient documentation exists to support the review and approval of expenditures to proper account codes within the general ledger, the act of transferring those coded expenditures into the GAPS system to claim reimbursement did not appear to be properly reviewed or monitored. Recommendation: The District should review its internal control procedures relating to the process for claiming reimbursements through GAPS. Specifically, we recommend that the program coordinator (or someone other than the individual processing the claims) compare the year-to-date GAPS claims with the total year-to-date program expenditures recorded in the general ledger on at least a quarterly basis. Auditee Response: Management agrees with the auditor?s recommendations. The District is being consolidated with another District and the successor Finance Director will correct finding.

Compliance Requirement: Reporting Condition: Claims for reimbursement did not agree to amounts recorded as expenditures in the general ledger. Criteria: The District is awarded various grant monies whereby an expenditure must first be incurred and then the periodic submission of expenditure reports to SCDE is used to pass federal financial assistance to the District. When preparing claims for reimbursement in the State Department of Education?s online GAPS software, the dollar amount requested for reimbursement under a specific account code must agree to the expenditures recorded on the general ledger under the same specific account code. Effect of Condition: In general, funds that are over claimed require money to be paid back to the State Department of Education and funds that are under claimed require that those expenditures be paid out of the General Fund. Specifically, for ESSER II, the claims submitted through GAPS were materially more than the expenditures on the general ledger. Cause: The method used to request claims for reimbursement simply did not include a proper reconciliation back to the expenditures recorded in the general ledger. Recommendation: Claims for reimbursement should be prepared based on detailed general ledger reports. The ledger reports should be printed and reconciled to the actual claim. Auditee Response: Management agrees with the auditor?s recommendations. The District is being consolidated with another District and the successor Finance Director will correct finding.

Finding 2021-006 (Internal Control Over Compliance ? Material Weakness) Title I Regular 2021 Grant, CFDA no. 84.010, U.S. Department of Education, Passed Through S.C. Department of Education, Pass-Through Grantor?s identifying number H63010100121 Internal Control over Compliance with Reporting Condition: The District did not have sufficient controls in place within its Title I program to ensure compliance with the Reporting requirement. Criteria: The District is required to prepare SCDE financial reports that are complete and submitted in a timely manner. The proper submission of claims in the State?s online GAPS software satisfies this compliance requirement. Effect of Condition: Internal controls over Reporting requirement were considered deficient, which could be viewed as a violation of the award agreement. Recommendation: The District should review its internal control procedures relating to the process for claiming reimbursements through GAPS. Auditee Response: Management agrees with the auditor?s recommendation. The District will implement procedures to provide better internal controls over the Reporting compliance requirement.

Title I Regular 2021 Grant, CFDA no. 84.010, U.S. Department of Education, Passed Through S.C. Department of Education, Pass-Through Grantor?s identifying number H63010100121 Compliance Requirement: Reporting Condition: Claims for reimbursement did not agree to amounts recorded as expenditures in the general ledger. Criteria: The District is awarded various grant monies whereby an expenditure must first be incurred and then the periodic submission of expenditure reports to SCDE is used to pass federal financial assistance to the District. When preparing claims for reimbursement in the State Department of Education?s online GAPS software, the dollar amount requested for reimbursement under a specific account code must agree to the expenditures recorded on the general ledger under the same specific account code. Effect of Condition: In general, funds that are over claimed require money to be paid back to the State Department of Education and funds that are under claimed require that those expenditures have to be paid for out of the General Fund. Specifically, for Title I, the expenditures on the general ledger were not claimed or reconciled with prior claims causing material under-claiming of funds for reimbursement. Cause: The Finance Director appears to have made a good faith attempt at keeping track of items claimed. She would use ledger reports and summarize what the claim should be on an Excel spreadsheet, and then use the Excel spreadsheet to complete the claim in the GAPS software. It appears, however, as though she wasn?t printing out the general ledger expenditure reports she used to prepare her spreadsheets that would identify each expenditure being claimed. The spreadsheets were only summaries. Therefore, each succeeding claim may or may not have included expenditures that were already included in those summaries. Recommendation: Claims for reimbursement should be prepared based on detailed general ledger reports. The ledger reports should be printed and reconciled to the actual claim. Auditee Response: The Finance Director will use detailed ledger reports to prepare claims for reimbursement. Subsequent claim reports will be compared to prior reports to ensure every expenditure is properly claimed.

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