Northwest Suburban Integration School District

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF EDUCATION, MAGNET SCHOOLS ASSISTANCE ? CFDA NO. 84.165 2019-001 Internal Controls Over Compliance with Cash Management, Allowable Costs, Subrecipient Monitoring, and Standards for Financial Management Criteria ? 2 CFR ? 200.302(b)(5), (6), and (7) require Northwest Suburban Integration School District (the District) to have written cash management procedures, which includes procedures for determining the allowability of costs in accordance with 2 CFR 200 Subpart E ? Cost Principles, as well as a required written budget to actual comparison of expenditures for each federal award. In instances where the District grants subawards, 2 CFR ? 200.331 requires the District, as a pass-through entity, to have written subrecipient monitoring policies and procedures that include a written risk assessment of each subrecipient and documentation of the District?s monitoring of the subrecipient. Condition ? During our audit, we noted that the District did not have documented written controls to ensure compliance with the U.S. Office of Management and Budget?s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) cash management, allowable costs, subrecipient monitoring, and financial management standards. Questioned Costs ? None. Our testing did not indicate any instances of noncompliance. Context ? The lack of written controls pertains to all federal grants. This was not a statistically valid sample. Repeat Finding ? This is a current year finding only. Cause ? The implementation of the Uniform Guidance requirements for federal awards is relatively new to the District, and some written internal control policies, including cash management, allowable costs, subrecipient monitoring, and financial management were not updated to reflect the necessary changes. Effect ? This could be viewed as a violation of the award agreement. Recommendation ? We recommend that the District review its internal control procedures relating to cash management, allowable costs, subrecipient monitoring, and financial management for all federal programs. The District should review the Uniform Guidance to obtain a better understanding of the requirements and identify any needed policy and procedure changes, in addition to those already referenced above. We also recommend the District adopt written policies pertaining to cash management, allowable costs, subrecipient monitoring, and financial management for all federal programs. The District should also document and perform regular budget to actual comparison of expenditures for each federal award. Finally, we recommend the District document identify subrecipients and written risk assessments as well as the monitoring of each subrecipient. View of Responsible Official and Planned Corrective Actions ? The District agrees with the finding. The District is in the process of reviewing and updating its written policies and procedures relating to cash management, allowable costs, subrecipient monitoring, and financial management standards for its federal programs to ensure compliance with the Uniform Guidance in the future. The District has separately issued a Corrective Action Plan related to this finding.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF EDUCATION, MAGNET SCHOOLS ASSISTANCE ? CFDA NO. 84.165 2019-001 Internal Controls Over Compliance with Cash Management, Allowable Costs, Subrecipient Monitoring, and Standards for Financial Management Finding Summary Northwest Suburban Integration School District No. 6078 (the District) did not have documented written controls to ensure compliance with the U.S. Office of Management and Budget?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) cash management, allowable costs, subrecipient monitoring, and financial management standards, as required by the Uniform Guidance. Corrective Action Plan Actions Planned ? The District is in the process of reviewing and updating its written policies and procedures relating to cash management, allowable costs, subrecipient monitoring, and financial management standards for its federal programs to ensure compliance with the Uniform Guidance in the future. Official Responsible ? The District?s Executive Director. Planned Completion Date ? December 31, 2019. Disagreement With or Explanation of Finding ? The District agrees with this finding. Plan to Monitor ? The District?s Executive Director will assure appropriate written internal controls and procedures are updated and in place for future federal grants.