W-A-Y ACADEMYNon-Profit

Criteria – Grant drawdowns should be based on actual costs incurred and must be properly documented. Condition and Description – During our procedures we noted the Academy had $78,155 in drawdowns for the Title I grant, but only $4,906 could be supported. The Academy had $1,191 in drawdowns for Title II that could not be supported. Questioned Costs - $73,349 – Title I $ 1,916 – Title II

2021-003 ? Allowable Costs/Cost Principles ? Disbursements Finding Type. Material Weakness in Internal Control over Compliance Federal program(s) U.S. Department of Education Education Stabilization Fund (CFDA# 84.425); Passed through MDE; All project numbers Criteria. The Uniform Guidance requires the Academy to support disbursements charged to federal cost objectives with adequate documentation in accordance with the Academy's purchasing policies, which require approved purchase orders and invoices. These purchase orders should be properly reviewed and approved. Condition. Eighteen of the twenty seven disbursements selected for testing did not include the required purchase order and other documentation of approvals by the appropriate, authorizing individual. Cause. While the Academy has procedures in place to cover thse areas, due to staff turnover, the small size of its accounting staff, and limited resources, the Academy did not adequately follow through on documenting and retaining evidence of approvals for disbursements as is their policy. Effect. As a result of this condition, the Academy was exposed to increased risk that disbursements of federal awards could be made for unallowable costs. Questioned Costs. No costs have been questioned as a result of this finding. Recommendation. We recommend that the Academy review its written policies and procedures over federal awards to ensure that all disbursements have the appropriate documentation and evidence of review and approval prior to payment.

2021-004 ? Written Policies Required by the Uniform Grant Guidance Finding Type. Immaterial Noncompliance; Significant Deficiency in Internal Controls over Compliance. Federal program(s) U.S. Department of Education Education Stabilization Fund (CFDA# 84.425); Passed through MDE; All project numbers Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to: 1) Payments (draws of federal funds and how to minimize the time lapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (?200.302(6)); 2) Procurement (including bidding and a conflict of interest policy) (?200.318) 3) Allowability of costs charged to federal programs (?200.302(7)); 4) Compensation (personnel and benefits policy) (?200.430 and ?200.431); and 5)Travel costs (including mileage and per diem) (?200.474). Condition. Although the Academy has processes in place to cover these areas, there are no formal written policies covering payments, procurement, allowability of costs, compensation, and travel costs in accordance with the Uniform Guidance. Cause. This condition is a result of the Academy?s limited resources, and the small size of its accounting staff. Effect. As a result of this condition, the Academy was exposed to increased risk that grant requirements under 2 CFR 200 would not be followed. Questioned Costs. No costs were questioned as a result of this finding. Recommendation. We recommend that the Academy develop and implement the required policies as soon as practical.