Post on 15-Dec-2015
Texas Education AgencyDivision of Federal Fiscal Monitoring
Audit Findings and How to Avoid Them
October 8, 2014
About the Presenter
Roger Hingorani
ManagerGrant Review UnitDivision of Federal Fiscal MonitorsTexas Education Agency(512) 463-9918Roger.Hingorani@tea.state.tx.us
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Agenda
•Acronyms Used In This Presentation•Division of Federal Fiscal Monitoring•Reviews Conducted•Common Findings•How to Avoid Them•Useful links
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Acronyms Used In Presentation
• CFR – Code of Federal Regulations • FASRG – Financial Accountability School Resource Guide• LEA – Local Education Agency• NCLB – No Child Left Behind• OMB – Office of Management and Budget• PAR – Personnel Activity Report• TEA – Texas Education Agency• PER-DIEM – Daily Allowance for Expenses
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Division of Federal Fiscal Monitoring (FFM)
• Grant Review Unit (GRU)• Conducts monitoring activities including both desk and
onsite reviews as part of TEA’s annual risk assessment and investigations for complaints and/or management referrals of the discretionary and formula grants awarded to school districts, charter schools, regional education service centers and non-profit entities.
• Conducts reviews of annual financial reports for compliance with federal single audit requirements and issues management decisions related to audit findings pertaining to any federal awards passed through the TEA.
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Division of Federal Fiscal Monitoring (FFM)
• Monitoring Review Unit (MRU)• Conducts monitoring activities including desk
reviews of LEAs as part of the TEA’s annual risk assessment
• Monitoring for special conditions imposed on discretionary and formula grants awarded to school districts, charter schools, regional education service centers and other entities.
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January 28, 2014 Copyright © 2014 by TEA 7
Is Your School District in Compliance with Grant Requirements?
Division of Federal Fiscal Monitoring (FFM)
Grant Review Unit
• 55 Desk and Onsite Reviews Conducted• 41 Reviewed had Findings• 27 had Findings with Questioned Costs• $165,348.57 in Total Questioned Cost• $157,444.14 in Questioned Cost Resolved through
Corrective Actions Taken
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Common Findings - Financial Management Systems
1. Internal Controls - Effective ControlLack of Written Policies and Procedures
Reporting of Expenditures for ReimbursementCredit CardsTravelEmployee ReimbursementsInventory ControlsTime and EffortBudgetary ControlsPurchasing
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Common Findings – Payroll
2. Time and EffortNot adequately maintained or after-the-fact
a.Periodic Certifications Prepared in Advance not after the factNot signed by employee or supervisor
b. Personnel Activity Report (PAR) Did not account for 100% of the time
compensated Budgeted Hours Reported on PAR
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Common Findings – Payroll
2. Time and Effort continued…
Not adequately maintained or Not after-the-factc. Substitute Time and Effort Reporting
System Not approved by TEAThe employee did not work on a set schedule
Semi-Annual Certificate not signed by employee and supervisor
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Common Findings – Payroll
3. Lack of Supporting Documentation
Signed and Dated Job Descriptions Tutoring / Extra-duty Pay Supplemental Pay Agreement
Time Sheets Documentation Demonstrating Highly Qualified Status
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Common Findings – Payroll
3. Lack of Supporting Documentation continued…
Amounts Recorded in the Payroll Journals does not match with the payroll costs charged to the grant in the General Ledger
Payroll costs charged to the incorrect grant periodPayroll checks issued in midmonth every month prior to services being performed.
Expenditures claimed for reimbursement not recorded in financial records
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Common Findings
4. Budgets/Amendments
Positions not Approved in the TEA Approved Program Budget
Encumbrances not Recorded in the General Ledger.
Incorrect Fund Codes Used for Reporting Expenditures
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Common Findings
4. Budgets/Amendments – continued…
Items Requiring TEA Approval Purchased without Approval(Capital Outlay Items)
Cost Incurred from Class Object Codes not Approved in the Program Budget.
Budget Amendments-25% Variance/Threshold
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Common Findings
5. Required Set Asides
Amounts not appropriated/Identified in financial records to match amounts reserved for specific activities such as a Districtwide Parental Involvement or Districtwide Professional Development Activities as reported on Schedule PS-3101 of Consolidated Federal Grant Application
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Common Findings – Non-payroll
6. Lack of Source Documentation Third Party Documents such as an invoice/billing statement to support expenditure
Lack of Approval from Authorized PersonnelLack of Purchase Order. Gift Cards without additional support
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Common Findings – Non-payroll
6. Lack of Source Documentation continued…
Incomplete Receipts/Invoices Credit Card Statements without Backup Receipts Lack of Valid Contracts/Agreements for
Professional/contracted Services Proof of Attendance: Registration/Certificate of
Completion
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Common Findings – Non-payroll
7. Unallowable costsNecessary and Reasonable
Non-Educational Fieldtrips Not Aligned with Camus/District Improvement PlanAttend out of town training available in city of domicile
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Common Findings – Non-payroll
7. Unallowable costs – continued…
TravelLack of Authorization for TravelFull PER-DIEM Claimed without attestation of actual funds expended
Use of grant funds to attend training/conference unrelated to the Program.
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Common Findings – Non-payroll
7. Unallowable costs continued…
Food Costs/Incentives Food for Staff Meetings/Development Full Meals for Parental Involvement Food as Incentives for Student Participation
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Common Findings – Non-payroll
8. Allocable Costs Goods / Services at the end of the grant period
- Stockpiling of Supplies
Cost Allocation Plans for:-Rent/Utilities-Maintenance and Repair Agreements-Other Shared Costs
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Common Findings - Other
9. Period of Availability- Pre-Award Costs Charged to the Grant without TEA
Approval- Annual Subscriptions/Software Licenses-Outside of
the Grant Period10.Supplement / Supplant
a. Curriculum Management Systems / Softwareb. State Mandated
– Required Trainings – Books
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Common Findings - Other
11. Shared Service AgreementsLack of shared service agreement with member
districtsAgreement not clear about roles and
responsibilities of fiscal agent and member district
Lack of oversight by Fiscal Agent regarding expenditures of grant funds.
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Common Findings - OtherShoolwide Program: Consolidation of State,
local & Federal Funds
12. Schoolwide Program out of ComplianceLack of Documentation to Demonstrate Needs
Assessments School Improvement Plans Missing Key Elements Methodology demonstrating the accounting for
expenditures from schoolwide pool at each participating campus
Demonstration of supplement not supplant requirements on schoolwide program
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Common Findings - OtherShoolwide Program: Consolidation of State,
local & Federal Funds Continued…
12. School Improvement Plan missing key elementsTen Required ComponentsGoals, objectives, Targets based on Identified Needs
Assessment (Comprehensive Needs Assessment)Listing of specific federal, State and local funds
consolidated and amount each fund source contributed to the consolidated pool
Demonstration of Intent and purpose of each federal program whose funds were consolidated.
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How to Avoid Findings
Strong Internal Controls•Policies and Procedures (P & Ps)•Tone at the Top – Adherence to P & Ps and Compliance Requirements
•Organizational Structure - Identify reporting/supervisory responsibilities as well as assignment of authority and responsibilities
•Provide Adequate Training
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How to Avoid Findings
Compliance with Statutory RequirementsProgram Statutes
• Elementary and Secondary Education Act (NCLB) Regulations
• Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments (34 CFR 80 )
• OMB Circular A-87 (Cost Principles for State, Local, and Indian Tribal Governments
Guidance• Non-regulatory Guidance• Application Guidance
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Useful Website Links
Texas Education Agency• http://www.tea.state.tx.us/United States Department of Education• http://www.ed.gov/index.jhtmlOffice of Management and Budget• http://www.whitehouse.gov/omb/circulars/Code of Federal Regulations• http://www.gpoaccess.gov/cfr/index.htmlOffice of Executive Councils, Chief Financial Officers Council • https://cfo.gov/COFAR/
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More Useful Links (TEA)
TEA: Substitute System of Time-and-Effort Reportinghttp://www.tea.state.tx.us/index2.aspx?id=2147510385TEA: Financial Accountability System Resource Guidehttp://www.tea.state.tx.us/index2.aspx?id=25769817568&menu_id=645TEA: Grantshttp://www.tea.state.tx.us/index2.aspx?id=2147487920&menu_id=951Grant Management Resourceshttp://www.tea.state.tx.us/index4.aspx?id=8339&menu_id=951
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