EIN: 621715618
UEI: GSA_MIGRATION
Data as of August 23, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 6, 2022. 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 December 6, 2022 (1357 days ago).
What is a management decision? →The Agency allocates the salary of two administrative employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. There is no documentation of the method used to allocate these salaries. Criteria: Tennessee Department of Finance and Administration Policy 03 ? Uniform Reporting Requirements and Cost Allocation Plans for Sub-recipients of Federal and State Grant Monies allows for the direct allocation of salaries and benefits on the basis of time records, records of the number of clients served, or other approved basis. Context: I reviewed two of the quarterly reimbursement reports and noted that the salary of two administrative employees were allocated to the grant for reimbursement. I then determined that the allocation was made on an estimate and that there was no supporting documentation. Cause: The Agency estimates the time spent by the administrative employees involved in the Migrant Education grant and allocates their time accordingly. Effect: While the amount of salary of the administrative employees allocated to the grant does not seem excessive or unreasonable it could be determined to be a questioned cost in the future without proper documentation of the allocation. Recommendation: The Agency should confer with their contacts at the State on the grant and should develop a method to allocate the administrative salaries to the grant. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
Show full finding ▾Hide full finding ▴2021-003 ? Grant reimbursement for administrative salaries Statement of Condition: The Agency allocates the salary of two administrative employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. There is no documentation of the method used to allocate these salaries. Criteria: Tennessee Department of Finance and Administration Policy 03 ? Uniform Reporting Requirements and Cost Allocation Plans for Sub-recipients of Federal and State Grant Monies allows for the direct allocation of salaries and benefits on the basis of time records, records of the number of clients served, or other approved basis. Context: I reviewed two of the quarterly reimbursement reports and noted that the salary of two administrative employees were allocated to the grant for reimbursement. I then determined that the allocation was made on an estimate and that there was no supporting documentation. Cause: The Agency estimates the time spent by the administrative employees involved in the Migrant Education grant and allocates their time accordingly. Effect: While the amount of salary of the administrative employees allocated to the grant does not seem excessive or unreasonable it could be determined to be a questioned cost in the future without proper documentation of the allocation. Recommendation: The Agency should confer with their contacts at the State on the grant and should develop a method to allocate the administrative salaries to the grant. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
2021-003?Grant reimbursement for administrative salaries Statement of Condition: The Agency allocates the salary of two administrative employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. There is no documentation of the method used to allocate these salaries. Views of Responsible Officials and Planned Corrective Actions: The agency agrees that a small allocation of time and as such, compensation of two employees that have direct, ongoing and meaningful involvement with the program, is charged to the grant. Agency staff, and in particular management staff, does not as a matter of routine practice keep hourly or daily timesheets. As such the allocation of time is done on an estimated basis following very conservative estimates of the time devoted to the program. The agency agrees with the findings that such allocation by no means represents unreasonable or excessive.
2020-004
The Agency allocates the health insurance benefits of the employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. Health insurance was allocated for employees who did not participate in the Agency health insurance plan. Section III - Federal Award Findings and Questioned Costs - Continued Criteria: Tennessee Department of Finance and Administration Policy 03 ? Uniform Reporting Requirements and Cost Allocation Plans for Sub-recipients of Federal and State Grant Monies allows for the direct allocation of salaries and benefits on the basis of time records, records of the number of clients served, or other approved bases. Context: I reviewed two of the quarterly reimbursement reports and compared the name of the employees who had an insurance allocation to the health insurance general ledger account and noted that the employee had health insurance withheld from their paycheck for the period of the reimbursement. In performing this test, I noted one employee that had an insurance allocation on reimbursement report who did not have any insurance withheld during one of the periods of the reimbursement. I then expanded my test to include the insurance allocation for the other two quarterly reimbursement reports and found that the same employee had an insurance allocation on the reimbursement report but did not have any health insurance withheld during one of those reimbursement periods. Cause: The Agency was not reviewing the monthly health insurance billing when the quarterly reimbursement report was prepared. Effect: The Agency overbilled the State for the amount of this error. This finding only applies to the last two quarters of the Agency?s fiscal year. It occurred when an employee went part time and no longer had insurance. Recommendation: The Agency should continue to review the health insurance billing for all three months of the grant period when the quarterly reimbursement report is prepared. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
Show full finding ▾Hide full finding ▴2021-004 ? Grant reimbursement for administrative benefits Statement of Condition: The Agency allocates the health insurance benefits of the employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. Health insurance was allocated for employees who did not participate in the Agency health insurance plan. Section III - Federal Award Findings and Questioned Costs - Continued Criteria: Tennessee Department of Finance and Administration Policy 03 ? Uniform Reporting Requirements and Cost Allocation Plans for Sub-recipients of Federal and State Grant Monies allows for the direct allocation of salaries and benefits on the basis of time records, records of the number of clients served, or other approved bases. Context: I reviewed two of the quarterly reimbursement reports and compared the name of the employees who had an insurance allocation to the health insurance general ledger account and noted that the employee had health insurance withheld from their paycheck for the period of the reimbursement. In performing this test, I noted one employee that had an insurance allocation on reimbursement report who did not have any insurance withheld during one of the periods of the reimbursement. I then expanded my test to include the insurance allocation for the other two quarterly reimbursement reports and found that the same employee had an insurance allocation on the reimbursement report but did not have any health insurance withheld during one of those reimbursement periods. Cause: The Agency was not reviewing the monthly health insurance billing when the quarterly reimbursement report was prepared. Effect: The Agency overbilled the State for the amount of this error. This finding only applies to the last two quarters of the Agency?s fiscal year. It occurred when an employee went part time and no longer had insurance. Recommendation: The Agency should continue to review the health insurance billing for all three months of the grant period when the quarterly reimbursement report is prepared. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
2021-004?Grant reimbursement for administrative benefits Statement of Condition: The Agency allocates the health insurance benefits of the employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. Health insurance was allocated for employees who did not participate in the Agency health insurance plan. Views of Responsible Officials and Planned Corrective Actions: The agency agrees with the recommendation. As this was a finding last cycle, we instituted a system in place to make sure this would not occur again. However, the overbilling of$283.13 per month occurred over a period of 5 months for a total of $1,415.75 for an employee who switched her status from Full time to Part time and thus was not covered by Health Insurance anymore. Once the employee became a parttime employee, she was noneligible health insurance and the CFO failed to adjust the report to eliminate that cost for her. While the system was set up to minimize the for human error persists and we will continue to strive to minimize such errors.
2020-005
The Agency has no documentation of its financial or programmatic internal control over the Cares Act Grant. Criteria: The administrative requirements of the Uniform Guidance for Federal Awards require auditees to establish and maintain effective internal control over its federal awards. Context: I inquired about the Agency?s financial and programmatic internal control documentation related to the Cares Act program and was told that the internal control was not documented. Cause: The Agency relied on its Migrant Education Program fiscal procedures for the Cares Act Grant. The Agency did not realize that separate fiscal procedures are required for each federal program. Effect: An effective internal control document may have prevented some of the other compliance findings Recommendation: The Agency should develop an internal control document over the Cares Act Grant program that documents both its financial controls and its program controls. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
Show full finding ▾Hide full finding ▴2021-005 ? Internal Control Over Federal Awards Programs Statement of Condition: The Agency has no documentation of its financial or programmatic internal control over the Cares Act Grant. Criteria: The administrative requirements of the Uniform Guidance for Federal Awards require auditees to establish and maintain effective internal control over its federal awards. Context: I inquired about the Agency?s financial and programmatic internal control documentation related to the Cares Act program and was told that the internal control was not documented. Cause: The Agency relied on its Migrant Education Program fiscal procedures for the Cares Act Grant. The Agency did not realize that separate fiscal procedures are required for each federal program. Effect: An effective internal control document may have prevented some of the other compliance findings Recommendation: The Agency should develop an internal control document over the Cares Act Grant program that documents both its financial controls and its program controls. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
2021-005?Internal Control Over Federal Awards Programs Statement of Condition: The Agency has no documentation of its financial or programmatic internal control over the Cares Act Grant. Views of Responsible Officials and Planned Corrective Actions: Funding for the Cares Act was deployed very quickly during the pandemic and did not follow the traditional contracting timelines and scrutiny that other federal funding streams that we?ve received before. As such, we were not aware that a separate set of internal controls from the ones that already exists, had to be drafted. As such we agree with the finding and realize that if further Covid related funding is granted to the organization, we will need to specifically craft controls for such programs. As the organization?s current financial management policies are well established management feels the management of the deployment of Cares Act funds was done responsibility, according to its intent and without meaningful error that would affect the impact and results of the program.
FAC accepted this audit on March 21, 2021 — management decision was due September 21, 2021.
Management has the financial knowledge, competencies and skills to oversee the process of preparing its own financial statements and related disclosures in accordance with GAAP and to understand and determine that its financial statements are free of material misstatement, however, management requested the auditors provide year-end closing, accounting and reporting assistance during the audit process that resulted in adjustments related to the following: ? Recording grants and contributions, contributions receivable and the related grant and contribution revenue ? Temporarily restricted net assets ? Interest income, interest expense, allowance for loan losses, notes receivable and notes payable balances for the down payment assistance program ? Property and equipment and depreciation expense ? Accounts payable and accrued expenses ? Investment earnings ? Allocation of loan costs and related amortization Criteria: Management is responsible for establishing and maintaining effective internal control over financial reporting in accordance with accounting principles generally accepted in the United States of America ("GAAP"). Cause: The Agency requested the auditor prepare the financial statements and related disclosures. Effect: The auditor has to be very diligent to make sure that independence is not impaired. Recommendation: We recommend that management consider annually, the cost effectiveness of taking the time to prepare its financial statements and related disclosures such that any misstatements would be prevented or detected early and corrected. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
Show full finding ▾Hide full finding ▴2020-001 - Internal control over financial reporting Statement of Condition: Management has the financial knowledge, competencies and skills to oversee the process of preparing its own financial statements and related disclosures in accordance with GAAP and to understand and determine that its financial statements are free of material misstatement, however, management requested the auditors provide year-end closing, accounting and reporting assistance during the audit process that resulted in adjustments related to the following: ? Recording grants and contributions, contributions receivable and the related grant and contribution revenue ? Temporarily restricted net assets ? Interest income, interest expense, allowance for loan losses, notes receivable and notes payable balances for the down payment assistance program ? Property and equipment and depreciation expense ? Accounts payable and accrued expenses ? Investment earnings ? Allocation of loan costs and related amortization Criteria: Management is responsible for establishing and maintaining effective internal control over financial reporting in accordance with accounting principles generally accepted in the United States of America ("GAAP"). Cause: The Agency requested the auditor prepare the financial statements and related disclosures. Effect: The auditor has to be very diligent to make sure that independence is not impaired. Recommendation: We recommend that management consider annually, the cost effectiveness of taking the time to prepare its financial statements and related disclosures such that any misstatements would be prevented or detected early and corrected. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
2020-001 - Internal control over financial reporting Statement of Condition: Management has the financial knowledge, competencies and skills to oversee the process of preparing its own financial statements and related disclosures in accordance with GAAP and to understand and determine that its financial statements are free of material misstatement, however, management requested the auditors provide year-end closing, accounting and reporting assistance during the audit process that resulted in adjustments related to the following: ? Recording grants and contributions contributions receivable and the related grant and contribution revenue ? Temporarily restricted net assets ? lnterest income, interest expense, allowance for loan losses, notes receivable and notes payable balances for the down payment assistance program ? Property and equipment and depreciation expense ? Accounts payable and accrued expenses ? lnvestment earnings ? Allocation of loan costs and related amortization Views of Responsible Officials and Planned Corrective Actions: Management acknowledges that the internally prepared financial statements primarily follow a cash basis presentation, and that opting to use primarily follow a cash basis presentation, and that opting to use this accounting methodology may lead to sho11comings in GAAP. Accordingly, management asked the auditors to adjust the internally prepared statements, that are primarily used for internal organizational management purposes, to fully comply with GAAP standards, and to assure they are free of material misstatements. Management will continue to consider annually the feasibility of preparing financial statements and related disclosures.
2019-001
I examined 40 cash disbursement transactions and 12 payroll mileage reimbursements related to the Migrant Education Program. There was no documentation of the approval for payment on 2 of the 52 items tested. Criteria: The person that approves an invoice for payment should sign the approval slip attached to the supporting documentation or sign the supporting documentation itself as proof that the invoice was approved for payment. Context: This condition was discovered while performing the test of cash disbursements related to the Migrant Education Program. There was evidence that the disbursement was being reviewed but there was no signature to document that the disbursement was approved for payment. Cause: It appears to be just an oversight by the person preparing the supporting documentation for payment. These both occurred in the first two quarters of the fiscal year before procedures were instituted as a result of prior year findings. Effect: In the future an invoice could get paid that was not a proper expenditure and therefore be a questioned cost. Recommendation: The individual that reviews the invoice before the bill is processed for payment should make sure that the documentation of the approval is signed and attached to the invoice before the check is printed. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
Show full finding ▾Hide full finding ▴2020-002 ? Documentation of approval for payment Statement of Condition: I examined 40 cash disbursement transactions and 12 payroll mileage reimbursements related to the Migrant Education Program. There was no documentation of the approval for payment on 2 of the 52 items tested. Criteria: The person that approves an invoice for payment should sign the approval slip attached to the supporting documentation or sign the supporting documentation itself as proof that the invoice was approved for payment. Context: This condition was discovered while performing the test of cash disbursements related to the Migrant Education Program. There was evidence that the disbursement was being reviewed but there was no signature to document that the disbursement was approved for payment. Cause: It appears to be just an oversight by the person preparing the supporting documentation for payment. These both occurred in the first two quarters of the fiscal year before procedures were instituted as a result of prior year findings. Effect: In the future an invoice could get paid that was not a proper expenditure and therefore be a questioned cost. Recommendation: The individual that reviews the invoice before the bill is processed for payment should make sure that the documentation of the approval is signed and attached to the invoice before the check is printed. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
2020-004 - Grant reimbursement for administrative salaries Statement of Condition: The Agency allocates the salary of two administrative employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. There is no documentation of the method used to allocate these salaries. Views of Responsible Officials and Planned Corrective Actions: The agency agrees that a small allocation of time and as such, compensation of two employees that have direct, ongoing and meaningful involvement with the program, is charged to the grant. Agency staff, and in particular management staff, does not as a matter of routine practice keep hourly or daily timesheets. As such the allocation of time is done on an estimated basis following very conservative estimates of the time devoted to the program. The agency agrees with the findings that such allocation by no means represents unreasonable or excessive. The agency agrees that conferring with grant administrators to properly document and allocate such costs will is a prudent strategy moving forward.
2019-002
The amount of contributions and foundation grants recorded in the general ledger is more than the contributions and grants recorded in the donor records. Criteria: The general ledger and the donor records should be reconciled periodically throughout the year to make sure that all contributions and foundation grants are properly recorded on both the general ledger and the donor records. Context: I compared the total donations on the donor printout furnished by Agency personnel with the total donations on the general ledger. The amount on the general ledger was significantly larger. Cause: This is primarily due to certain foundation grants being omitted from the donor records. Effect: In the future this could lead to foundation grants and grants not being properly recorded. Recommendation: The general ledger and the donor records should be reconciled periodically throughout the year to make sure that all contributions and foundation grants are properly recorded on both the general ledger and the donor records. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
Show full finding ▾Hide full finding ▴2020-003 ? Reconciliation of the donor records Statement of Condition: The amount of contributions and foundation grants recorded in the general ledger is more than the contributions and grants recorded in the donor records. Criteria: The general ledger and the donor records should be reconciled periodically throughout the year to make sure that all contributions and foundation grants are properly recorded on both the general ledger and the donor records. Context: I compared the total donations on the donor printout furnished by Agency personnel with the total donations on the general ledger. The amount on the general ledger was significantly larger. Cause: This is primarily due to certain foundation grants being omitted from the donor records. Effect: In the future this could lead to foundation grants and grants not being properly recorded. Recommendation: The general ledger and the donor records should be reconciled periodically throughout the year to make sure that all contributions and foundation grants are properly recorded on both the general ledger and the donor records. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
2019-003 - Reconciliation of the donor records Statement of Condition: The amount of contributions and foundation grants recorded in the general ledger is more than the contributions and grants recorded in the donor records. Views of Responsible Officials and Planned Corrective Actions: The Agency agrees with the recommendation. While a protocol was established in 2017 to channel information in a way that reduced the number of discrepancies between the donor management system and the general ledger, there are still occasions in which the information bypassed the donor management system and doesn't get recorded. This happens primarily when funds come from large funders whose grants and support traditionally had not been captured in the donor management system. The Covid 19 Pandemic which caused the shifting of operations to work remotely also contributed to disruptions in the flow of information and processes that had been implemented in prior years. The agency will strive to make sure the donor records fully captured contributions by establishing a reconciliation process between the general ledger and the donor system.
2019-003
The Agency allocates the salary of two administrative employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. There is no documentation of the method used to allocate these salaries. Criteria: Tennessee Department of Finance and Administration Policy 03 ? Uniform Reporting Requirements and Cost Allocation Plans for Sub-recipients of Federal and State Grant Monies allows for the direct allocation of salaries and benefits on the basis of time records, records of the number of clients served, or other approved basis. Context: I reviewed two of the quarterly reimbursement reports and noted that the salary of two administrative employees were allocated to the grant for reimbursement. I then determined that the allocation was made on an estimate and that there was no supporting documentation. Cause: The Agency estimates the time spent by the administrative employees involved in the Migrant Education grant and allocates their time accordingly. Effect: While the amount of salary of the administrative employees allocated to the grant does not seem excessive or unreasonable it could be determined to be a questioned cost in the future without proper documentation of the allocation. Recommendation: The Agency should confer with their contacts at the State on the grant and should develop a method to allocate the administrative salaries to the grant. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
Show full finding ▾Hide full finding ▴Statement of Condition: The Agency allocates the salary of two administrative employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. There is no documentation of the method used to allocate these salaries. Criteria: Tennessee Department of Finance and Administration Policy 03 ? Uniform Reporting Requirements and Cost Allocation Plans for Sub-recipients of Federal and State Grant Monies allows for the direct allocation of salaries and benefits on the basis of time records, records of the number of clients served, or other approved basis. Context: I reviewed two of the quarterly reimbursement reports and noted that the salary of two administrative employees were allocated to the grant for reimbursement. I then determined that the allocation was made on an estimate and that there was no supporting documentation. Cause: The Agency estimates the time spent by the administrative employees involved in the Migrant Education grant and allocates their time accordingly. Effect: While the amount of salary of the administrative employees allocated to the grant does not seem excessive or unreasonable it could be determined to be a questioned cost in the future without proper documentation of the allocation. Recommendation: The Agency should confer with their contacts at the State on the grant and should develop a method to allocate the administrative salaries to the grant. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
2020-004 - Grant reimbursement for administrative salaries Statement of Condition: The Agency allocates the salary of two administrative employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. There is no documentation of the method used to allocate these salaries. Views of Responsible Officials and Planned Corrective Actions: The agency agrees that a small allocation of time and as such, compensation of two employees that have direct, ongoing and meaningful involvement with the program, is charged to the grant. Agency staff, and in particular management staff, does not as a matter routine practice keep hourly or daily timesheets. As such the allocation of time is done on an estimated basis following very conservative estimates of the time devoted to the program. The agency agrees with the findings that such allocation by no means represents unreasonable or excessive. The agency agrees that conferring with grant administrators to properly document and allocate such costs will is a prudent strategy moving forward.
2019-005
The Agency allocates the health insurance benefits of the employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. Health insurance was allocated for employees who did not participate in the Agency health insurance plan. Criteria: Tennessee Department of Finance and Administration Policy 03 ? Uniform Reporting Requirements and Cost Allocation Plans for Sub-recipients of Federal and State Grant Monies allows for the direct allocation of salaries and benefits on the basis of time records, records of the number of clients served, or other approved bases. Context: I reviewed two of the quarterly reimbursement reports and compared the name of the employee who had an insurance allocation to the health insurance general ledger account and noted that the employee had health insurance withheld from their paycheck for the period of the reimbursement. In performing this test I noted employees that had an insurance allocation on reimbursement report but who did not have any insurance withheld during the period of the reimbursement. I then expanded my test to include the insurance allocation for the other two quarterly reimbursement reports and found additional employees that had an insurance on the reimbursement report but did not have any health insurance withheld during the reimbursement period. Cause: The Agency was not reviewing the monthly health insurance billing when the quarterly reimbursement report was prepared. Effect: The Agency overbilled the State for the amount of this error. This finding only applies to the first two quarters of the Agency?s fiscal year. It was corrected on the last two quarters of the fiscal year. Recommendation: The Agency should continue to review the health insurance billing for all three months of the grant period when the quarterly reimbursement report is prepared. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
Show full finding ▾Hide full finding ▴2020-005 ? Grant reimbursement for administrative benefits Statement of Condition: The Agency allocates the health insurance benefits of the employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. Health insurance was allocated for employees who did not participate in the Agency health insurance plan. Criteria: Tennessee Department of Finance and Administration Policy 03 ? Uniform Reporting Requirements and Cost Allocation Plans for Sub-recipients of Federal and State Grant Monies allows for the direct allocation of salaries and benefits on the basis of time records, records of the number of clients served, or other approved bases. Context: I reviewed two of the quarterly reimbursement reports and compared the name of the employee who had an insurance allocation to the health insurance general ledger account and noted that the employee had health insurance withheld from their paycheck for the period of the reimbursement. In performing this test I noted employees that had an insurance allocation on reimbursement report but who did not have any insurance withheld during the period of the reimbursement. I then expanded my test to include the insurance allocation for the other two quarterly reimbursement reports and found additional employees that had an insurance on the reimbursement report but did not have any health insurance withheld during the reimbursement period. Cause: The Agency was not reviewing the monthly health insurance billing when the quarterly reimbursement report was prepared. Effect: The Agency overbilled the State for the amount of this error. This finding only applies to the first two quarters of the Agency?s fiscal year. It was corrected on the last two quarters of the fiscal year. Recommendation: The Agency should continue to review the health insurance billing for all three months of the grant period when the quarterly reimbursement report is prepared. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
2020-005 - Grant reimbursement for administrative benefits Statement of Condition: The Agency allocates the health insurance benefits of the employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. Health insurance was allocated for employees who did not participate in the Agency health insurance plan. Views of Responsible Officials and Planned Corrective Actions: The agency agrees with the recommendation. As this was a finding last cycle, we instituted a system in place to make sure this would not occur again. The errors that were identified happened in the first part of the year, prior to the implementation of such system. Once the system was implemented, no further instances of the error were found.
2019-006
FAC accepted this audit on March 9, 2020 — management decision was due September 9, 2020.
Management has the financial knowledge, competencies and skills to oversee the process of preparing its own financial statements and related disclosures in accordance with GAAP and to understand and determine that its financial statements are free of material misstatement, however, management requested the auditors provide year-end closing, accounting and reporting assistance during the audit process that resulted in adjustments related to the following: ? Recording grants and contributions, contributions receivable and the related grant and contribution revenue ? Temporarily restricted net assets ? Interest income, interest expense, allowance for loan losses, notes receivable and notes payable balances for the down payment assistance program ? Property and equipment and depreciation expense ? Accounts payable and accrued expenses ? Investment earnings ? Allocation of loan costs and related amortization Criteria: Management is responsible for establishing and maintaining effective internal control over financial reporting in accordance with accounting principles generally accepted in the United States of America ("GAAP"). Cause: The Agency requested the auditor prepare the financial statements and related disclosures. Effect: The auditor has to be very diligent to make sure that independence is not impaired. Recommendation: We recommend that management consider annually, the cost effectiveness of taking the time to prepare its financial statements and related disclosures such that any misstatements would be prevented or detected early and corrected. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
Show full finding ▾Hide full finding ▴Section II - Financial Statement Findings 2019-001 - Internal control over financial reporting Statement of Condition: Management has the financial knowledge, competencies and skills to oversee the process of preparing its own financial statements and related disclosures in accordance with GAAP and to understand and determine that its financial statements are free of material misstatement, however, management requested the auditors provide year-end closing, accounting and reporting assistance during the audit process that resulted in adjustments related to the following: ? Recording grants and contributions, contributions receivable and the related grant and contribution revenue ? Temporarily restricted net assets ? Interest income, interest expense, allowance for loan losses, notes receivable and notes payable balances for the down payment assistance program ? Property and equipment and depreciation expense ? Accounts payable and accrued expenses ? Investment earnings ? Allocation of loan costs and related amortization Criteria: Management is responsible for establishing and maintaining effective internal control over financial reporting in accordance with accounting principles generally accepted in the United States of America ("GAAP"). Cause: The Agency requested the auditor prepare the financial statements and related disclosures. Effect: The auditor has to be very diligent to make sure that independence is not impaired. Recommendation: We recommend that management consider annually, the cost effectiveness of taking the time to prepare its financial statements and related disclosures such that any misstatements would be prevented or detected early and corrected. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
2019-001 - Internal control over financial reporting Statement of Condition: Management has the financial knowledge, competencies and skills to oversee the process of preparing its own financial statements and related disclosures in accordance with GAAP and to understand and determine that its financial statements are free of material misstatement, however, management requested the auditors provide year-end closing, accounting and reporting assistance during the audit process that resulted in adjustments related to the following: ? Recording grants and contributions, contributions receivable and the related grant and contribution revenue ? Temporarily restricted net assets ? Interest income, interest expense, allowance for loan losses, notes receivable and notes payable balances for the down payment assistance program ? Property and equipment and depreciation expense ? Accounts payable and accrued expenses ? Investment earnings ? Allocation of loan costs and related amortization Views of Responsible Officials and Planned Corrective Actions: Management acknowledges that the internally prepared financial statements primarily follow a cash basis presentation, and that opting to use this accounting methodology may lead to shortcomings in GAAP. Accordingly, management asked the auditors to adjust the internally prepared statements, that are primarily used for internal organizational management purposes, to fully comply with GAAP standards, and to assure they are free of material misstatements. Management will continue to consider annually the feasibility of preparing financial statements and related disclosure
2018-001
I examined 40 cash disbursement transactions and 21 payroll mileage reimbursements related to the Migrant Education Program. There was no documentation of the approval for payment on 4 of the 61 items tested. Criteria: The person that approves an invoice for payment should sign the approval slip attached to the supporting documentation or sign the supporting documentation itself as proof that the invoice was approved for payment. Context: This condition was discovered while performing the test of cash disbursements related to the Migrant Education Program. There was evidence that the disbursement was being reviewed but there was no signature to document that the disbursement was approved for payment. Cause: It appears to be just an oversight by the person preparing the supporting documentation for payment. Effect: In the future an invoice could get paid that was not a proper expenditure and therefore be a questioned cost. Recommendation: The individual that reviews the invoice before the bill is processed for payment should make sure that the documentation of the approval is signed and attached to the invoice before the check is printed. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
Show full finding ▾Hide full finding ▴Section II - Financial Statement Findings - Continued 2019-002 ? Documentation of approval for payment Statement of Condition: I examined 40 cash disbursement transactions and 21 payroll mileage reimbursements related to the Migrant Education Program. There was no documentation of the approval for payment on 4 of the 61 items tested. Criteria: The person that approves an invoice for payment should sign the approval slip attached to the supporting documentation or sign the supporting documentation itself as proof that the invoice was approved for payment. Context: This condition was discovered while performing the test of cash disbursements related to the Migrant Education Program. There was evidence that the disbursement was being reviewed but there was no signature to document that the disbursement was approved for payment. Cause: It appears to be just an oversight by the person preparing the supporting documentation for payment. Effect: In the future an invoice could get paid that was not a proper expenditure and therefore be a questioned cost. Recommendation: The individual that reviews the invoice before the bill is processed for payment should make sure that the documentation of the approval is signed and attached to the invoice before the check is printed. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
2019-002 - Documentation of approval for pavment Statement of Condition: - There was no documentation of the approval for payment on 4 ofthe 40 cash disbursements and 21 payroll mileage reimbursements tested. Views of Responsible Officials and Planned Corrective Actions: The Agency agrees with the recommendation and will strive to make sure that the approval for payment is documented on all disbursements. Staff responsible for entering Accounts Paya ble into the system has been directed to postpone check issuance if a request for payment is not properly authorized. lt's noteworthy to share that overthe last year the protocols that have been implemented have substantially reduced the instances In which these aren't signed. For example, all credit card statements are now reviewed and approved by program supervisors. All mileage reimbursements are approved before the are sent for payroll processing
2018-002
The amount of contributions and foundation grants recorded in the general ledger is more than the contributions and grants recorded in the donor records. Criteria: The general ledger and the donor records should be reconciled periodically throughout the year to make sure that all contributions and foundation grants are properly recorded on both the general ledger and the donor records. Section II - Financial Statement Findings - Continued Context: I compared the total donations on the donor printout furnished by Agency personnel with the total donations on the general ledger. The amount on the general ledger was significantly larger. Cause: This is primarily due to three foundation grants being omitted from the donor records. Effect: In the future this could lead to foundation grants and grants not being properly recorded. Recommendation: The general ledger and the donor records should be reconciled periodically throughout the year to make sure that all contributions and foundation grants are properly recorded on both the general ledger and the donor records. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
Show full finding ▾Hide full finding ▴2019-003 ? Reconciliation of the donor records Statement of Condition: The amount of contributions and foundation grants recorded in the general ledger is more than the contributions and grants recorded in the donor records. Criteria: The general ledger and the donor records should be reconciled periodically throughout the year to make sure that all contributions and foundation grants are properly recorded on both the general ledger and the donor records. Section II - Financial Statement Findings - Continued Context: I compared the total donations on the donor printout furnished by Agency personnel with the total donations on the general ledger. The amount on the general ledger was significantly larger. Cause: This is primarily due to three foundation grants being omitted from the donor records. Effect: In the future this could lead to foundation grants and grants not being properly recorded. Recommendation: The general ledger and the donor records should be reconciled periodically throughout the year to make sure that all contributions and foundation grants are properly recorded on both the general ledger and the donor records. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
2019-003 - Reconciliation of the donor records Statement of Condition: The amount of contributions and foundation grants recorded in the general ledger is more than the contributions and grants recorded in the donor records. Views of Responsible Officials and Planned Corrective Actions: The Agency agrees with the recommendation and will strive to make sure that the donor records are reconciled to the general ledger on a regular basis. While a protocol was establ ished in 2017 to channel information in a way that reduced the number of discrepancies between the donor management system and the general ledger, there are still occasions in which the information bypassed the donar management system and doesn't get recorded. This happens primarily when funds come from large funders whose grants and support traditionally had not been captured in the donar management system. The agency will strive to make sure the donor records reflect accurate contributions by establishing a monthly reconciliation process between the general ledger and the donor system.
2018-003
The Agency has no documentation of its financial or programmatic internal control over the Migrant Education Grant. Criteria: The administrative requirements of the Uniform Guidance for Federal Awards require auditees to establish and maintain effective internal control over its federal awards. Context: I inquired about the Agency?s financial and programmatic internal control documentation related to the Migrant Education program during last year?s audit and was told that the internal control was not documented. The Agency began working on an internal control document but it was not completed until after year end. Section III - Federal Award Findings and Questioned Costs - Continued Cause: The Agency relied on its fiscal procedures for the Migrant Education Grant. Effect: An effective internal control document may have prevented some of the other compliance findings. Recommendation: The Agency completed an internal control document over the Migrant Education Grant program subsequent to year end. Agency personnel should make sure that it documents both its financial controls and its program controls and that it is being followed by Migrant Education Grant personnel. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached
Show full finding ▾Hide full finding ▴Section III - Federal Award Findings and Questioned Costs U.S. DEPARTMENT OF EDUCATION PASS THROUGH TENNESSEE DEPARTMENT OF EDUCATION CFDA Numbers 84.011 and 84.144; Grant Number 51366 Significant Deficiency ? The significant deficiency at Finding 2019-002 applies to this grant. 2019-004 ? Internal Control Over Federal Awards Programs Statement of Condition: The Agency has no documentation of its financial or programmatic internal control over the Migrant Education Grant. Criteria: The administrative requirements of the Uniform Guidance for Federal Awards require auditees to establish and maintain effective internal control over its federal awards. Context: I inquired about the Agency?s financial and programmatic internal control documentation related to the Migrant Education program during last year?s audit and was told that the internal control was not documented. The Agency began working on an internal control document but it was not completed until after year end. Section III - Federal Award Findings and Questioned Costs - Continued Cause: The Agency relied on its fiscal procedures for the Migrant Education Grant. Effect: An effective internal control document may have prevented some of the other compliance findings. Recommendation: The Agency completed an internal control document over the Migrant Education Grant program subsequent to year end. Agency personnel should make sure that it documents both its financial controls and its program controls and that it is being followed by Migrant Education Grant personnel. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached
2019-004- Interna! Control Over Federal Awards Programs Statement of Condition: The Agency has no docurnentation of its financia! or programmatic interna) control over the Migrant Education Grant. Views of Responsible Officials and Planned Corrective Actions: The Agency agrees with the recommendation and actually completed an interna! control document over the Migrant Education Grant program subsequent to year end. Agency personnel now documents both its financial controls and its program controls and these are being fo llowed by Migrant Education Grant personnel.
2018-005
The Agency allocates the health insurance benefits of the employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. Health insurance was allocated for employees who did not participate in the Agency health insurance plan. Criteria: Tennessee Department of Finance and Administration Policy 03 ? Uniform Reporting Requirements and Cost Allocation Plans for Sub-recipients of Federal and State Grant Monies allows for the direct allocation of salaries and benefits on the basis of time records, records of the number of clients served, or other approved bases. Context: I reviewed two of the quarterly reimbursement reports and compared the name of the employee who had an insurance allocation to the health insurance general ledger account and noted that the employee had health insurance withheld from their paycheck for the period of the reimbursement. In performing this test I noted employees that had an insurance allocation on reimbursement report but who did not have any insurance withheld during the period of the reimbursement. I then expanded my test to include the insurance allocation for the other two quarterly reimbursement reports and found additional employees that had an insurance on the reimbursement report but did not have any health insurance withheld during the reimbursement period. Cause: The Agency was not reviewing the monthly health insurance billing when the quarterly reimbursement report was prepared. Section III - Federal Award Findings and Questioned Costs - Continued Effect: The Agency overbilled the State for the amount of this error. In the future this could result in questioned cost. Recommendation: The Agency should review the health insurance billing for all three months of the grant period when the quarterly reimbursement report is prepared. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
Show full finding ▾Hide full finding ▴2019-005 ? Grant reimbursement for administrative benefits Statement of Condition: The Agency allocates the health insurance benefits of the employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. Health insurance was allocated for employees who did not participate in the Agency health insurance plan. Criteria: Tennessee Department of Finance and Administration Policy 03 ? Uniform Reporting Requirements and Cost Allocation Plans for Sub-recipients of Federal and State Grant Monies allows for the direct allocation of salaries and benefits on the basis of time records, records of the number of clients served, or other approved bases. Context: I reviewed two of the quarterly reimbursement reports and compared the name of the employee who had an insurance allocation to the health insurance general ledger account and noted that the employee had health insurance withheld from their paycheck for the period of the reimbursement. In performing this test I noted employees that had an insurance allocation on reimbursement report but who did not have any insurance withheld during the period of the reimbursement. I then expanded my test to include the insurance allocation for the other two quarterly reimbursement reports and found additional employees that had an insurance on the reimbursement report but did not have any health insurance withheld during the reimbursement period. Cause: The Agency was not reviewing the monthly health insurance billing when the quarterly reimbursement report was prepared. Section III - Federal Award Findings and Questioned Costs - Continued Effect: The Agency overbilled the State for the amount of this error. In the future this could result in questioned cost. Recommendation: The Agency should review the health insurance billing for all three months of the grant period when the quarterly reimbursement report is prepared. Views of Responsible Officials and Planned Corrective Actions: Please see the Agency?s views and planned corrective actions in the attached letter.
2019-005 - Grant reimbursement for admini strative benefits Statement of Condition: The Agency allocates the health insurance benefits of the employees who are involved in the operations of the Migrant Education grant to the grant for reimbursement. Health insurance was allocated for employees who did not pa11icipate in the Agency health insurance plan. Views of Responsible Officials and Planned Corrective Actions: The agency agrees with the recommendation. While the agency reviews the allocation of benefits there was a human mistake made in one of the billing cycles when employees status changes that led to the mistake. The system in place to make sure this doesn't occur failed, and management is revising the process to assure this doesn't happen in the future.
2018-008
FAC accepted this audit on March 24, 2019 — management decision was due September 24, 2019.
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