Presentation on theme: "August 10, 2012. Overview During the last several years, federal agencies have put more emphasis on states’ responsibility to provide fiscal oversight."— Presentation transcript:
Overview During the last several years, federal agencies have put more emphasis on states’ responsibility to provide fiscal oversight of federal funds that they grant to sub- recipients Federal grants and the requirements have been around for decades At times LEAs do not comply with certain federal fiscal requirements because they are unaware of them and unaware of the potential loss of funds
Overview This training is intended to: Assist fiscal managers with fiscal administration of those grants Assist auditors with the audit requirements of federal and state aid received by 2r charter schools This training does not address: All areas of grant management Specific federal program requirements that accompany every grant General accounting principles
What are the types of requirements that apply to federal grants management and where are they found? Federal government established uniform procedures for the use of federal funds that are meant to minimize the potential for fraud or misuse of federal funds
Types of Requirements that Apply to Federal Grants Code of Federal Regulations (CFR) http://ecfr.gpoaccess.gov/cgi/t/text/text- idx?sid=b248f3949e2c06c722742aeb38c17562&c=ecfr&t pl=/ecfrbrowse/Title34/34tab_02.tplhttp://ecfr.gpoaccess.gov/cgi/t/text/text- idx?sid=b248f3949e2c06c722742aeb38c17562&c=ecfr&t pl=/ecfrbrowse/Title34/34tab_02.tpl Education Department General Administrative Regulations (EDGAR) Title 34 (Education), CFR, Parts 74-86 and 97-99 http://www2.ed.gov/policy/fund/reg/edgarReg/edgar. html http://www2.ed.gov/policy/fund/reg/edgarReg/edgar. html
Types of Requirements that Apply to Federal Grants Administration Office of Management and Budget (OMB) Circular A- 102 Common rule Identify the administrative systems and procedures that must be in place to receive, expend, account for and report on the uses of federal funds Incorporated OMB Circular A-102 into 34 CFR part 80 EDGAR Title 34 (Education), CFR, Part 80 Establishes uniform administrative rules for federal grants to state, local and Indian tribal governments
Types of Requirements that Apply to Federal Grants Management EDGAR Title 34 (Education), CFR Part 76 State- Administered Programs How funds are to be distributed to LEAs Program or fiscal conditions that must be met on the state/local level When obligations are made How grant recipients are accountable for fiscal reporting and for the reporting of the program
Types of Requirements that Apply to Federal Grants Cost Principles OMB Circular A-87 Identify how federal funds can be expended
Types of Requirements that Apply to Federal Grants Office of Management and Budget Circulars http://www.whitehouse.gov/omb/circulars_default/ OMB Circular A-87 - Cost Principles OMB Circular A-102 - Common rule OMB Circular A-133 - Audit State/Local OMB Circular A-133 - Compliance Supplement
Education Department General Administrative Regulations (EDGAR) 34 CFR Part 80.20 (a)Fiscal control and accounting procedures must be sufficient to: (1) Permit preparation of reports required (2) Permit tracing of funds to a level of expenditures adequate to establish that such funds have not been used in violation of the applicable standards.
Education Department General Administrative Regulations (EDGAR) (b)The financial management systems must meet the following standards: Financial Reporting Accounting Records Internal Control Budget Control Allowable Cost Source Documentation Cash Management
Education Department General Administrative Regulations (EDGAR) (c)’An awarding agency may review the adequacy of the financial management system of any applicant for financial assistance as part of a preaward review or at any time subsequent to award.’
Financial Reporting “Accurate, current, and complete disclosure of the financial results of financially assisted activities must be made in accordance with the financial reporting requirements of the grant or subgrant.”
Financial Reporting Individuals who prepare, review and approve reports possess knowledge, skills and abilities necessary Written policies and procedures to establish responsibilities and ensure proper monitoring, verification and reporting Review and approval of reports by appropriate individual prior to submission (separate from preparer) Accounting system set up to provide the financial information as needed for reporting
Accounting Records “Grantees and subgrantees must maintain records which adequately identify the source and application of funds provided for financially-assisted activities. These records must contain information pertaining to grant or subgrant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income.”
Accounting Records The foundation of fiscal management of a federal grant is the grant’s accounting record Common errors School does not create an accounting record for each grant and post expenditures to that account. Rather the school just identifies expenditures for grant reimbursement Expenditures are originally reported to a general account and later reclassified Accounting records do not integrate and track against the grant’s approved budget Accounting record cannot be used for budget control when expenditures are not posted to the grant as they occur and when they are not tracked against an approved budget
Accounting Records An accounting record that incorporates the amount of the award and approved budget. At a minimum each general area of planned expenditures Provisions should be made to track expenditures and available balances against each budget line to exercise budget control An accounting system that provides separate identification of federal and non-federal transactions and allocation transactions applicable to both
Accounting Records Reports provided timely to administration or governance board for review and appropriate action Easy access to accurate information on grant expenditures and comparison to grant budget and claims Recording of expenditures to appropriate account when incurred to assist with budget control
Tracking Expenditures Wisconsin Uniform Financial Accounting Requirements (WUFAR) Used for reporting to DPI Object Service or commodity acquired Salaries, fringe benefits, purchased services, non-capital objects, capital objects, insurance and judgments Function Purpose for which an object is used Instruction, support services Project Identify the activity IDEA, Title I, special education state aid
Accounting Records Per EDGAR) §76.730 s chool shall keep records that fully show: Amount of funds under the grant How the funds will be used Total cost of the project Share of the cost provided from other sources Other records to facilitate an effective audit
Internal Control “Effective control and accountability must be maintained for all grant and subgrant cash, real and personal property, and other assets. Grantees and subgrantees must adequately safeguard all such property and must assure that it is used solely for authorized purposes.” 34 CFR 80.36(a) “When procuring property and services under a grant, a State (LEA) will follow the same policies and procedures it uses for procurements from its non- Federal funds.”
Internal Control Internal controls that separate duties from being performed by one individual and strengthen accountability for all cash activity No one person should be able to both authorize a transaction and record the transaction in the accounting record. Controls over processing of cash receipts, disbursements and payroll.
Internal Control A fiscal transaction should be approved: By a person (program manager) who can attest that the planned/actual expenditure is allowable and approved under the grant and By another person (business manager/accountant) who can attest to the availability of funds and to its consistency with the approved budget and who enters the transaction into the fiscal record Each of these individuals should initial or sign the documentation for the transaction
Internal Control Examples: Small office of 1 or 2 people requires greater administrative and board participation in the day to day operations One individual should not be creating PO’s, receiving the goods, authorizing payment and reconciling the bank statement. Use authorized vendor list Have the administrator or board member review and approve all expenditures Use pre-numbered checks Limit petty cash transactions Review and authorize credit card transactions
Internal Control Common errors: Written policy that is: Non-existent Outdated Not being implemented Do not document the review of fiscal transactions by two people Do not routinely require approval of or posting of expenditures
Budget Control “Actual expenditures or outlays must be compared with budgeted amounts for each grant or subgrant. Financial information must be related to performance or productivity data, including the development of unit cost information whenever appropriate or specifically required in the grant or subgrant agreement. If unit cost data are required, estimates based on available documentation will be accepted whenever possible.”
Budget Control Grant funds cannot be expended on an activity until that activity has been approved When grant is awarded, school has authority to fund the activities at the amounts approved in the application.
Budget Control During the year, funding strategies may change for a variety of reasons Approval shall be obtained whenever any of the following changes is anticipated under a non- construction award: Revision which would result in the need for additional funding Cumulative transfers among direct cost categories, or among separately budgeted programs, projects, functions, or activities which exceed or are expected to exceed ten percent of the current total approved budget
Budget Control Common error: Program managers sometimes authorize expenditures for activities that are not part of the approved application or Make expenditures in anticipation of submitting an amendment
Budget Control Accounting records should have budget lines for each general area of planned expenditures Provision to track expenditures and available balances against each budget line to exercise budget control Post expenditures as they occur directly to the appropriate budget line within the grant’s accounting record Whenever changes are planned, review whether an amendment is required and obtain approval for proposed changes before expenditures are made
Allowable Cost “Applicable OMB cost principles, agency program regulations, and the terms of grant and subgrant agreements will be followed in determining the reasonableness, allowability, and allocability of costs.”
Allowable Cost Policy for procedures regarding determination of an allowed cost that include: Properly accounting for the expenditure upfront and determining it as an allowed cost per cost principles when incurred Review of expenditures claimed for reimbursement by someone other than the individual preparing the claim
Allowable Cost Common error: Salaries and Wages - no process in place for time and effort reporting Employees that are expected to work solely on a single federal award or cost objective supported by periodic certifications that the employee worked solely on that program for period covered by certification Employees that work on multiple activities or cost objectives supported by personnel activity reports or equivalent documentation
Source Documentation “Accounting records must be supported by such source documentation as cancelled checks, paid bills, payrolls, time and attendance records, contract and subgrant award documents, etc.”
Source Documentation Policies and procedures: Periodic certifications or personnel activity reports Adequate source documentation to support amounts and items reported All goods or services are initiated, approved and paid for through the established disbursement internal controls which should include a purchase order, packing slip if applicable, invoice and school check or electronic transfer
Cash Management “Procedures for minimizing the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by grantees and subgrantees must be followed whenever advance payment procedures are used. Grantees must establish reasonable procedures to ensure the receipt of reports on subgrantees’ cash balances and cash disbursements in sufficient time to enable them to prepare complete and accurate cash transactions reports to the awarding agency. When advances…”
Cash Management Basic standard – methods and procedures for payment shall minimize the time lapsing between the transfer of funds and disbursement by the school No expenditure may be claimed for reimbursement unless it is obligated Report expenditures on a timely basis
EDGAR §76.707 When Obligations are Made If the obligation is for -The obligation is made - (a)Acquisition of real or personal propertyOn the date on which the school makes a binding written commitment to acquire the property. (b) Personal services by an employee of the school When the services are performed. (c) Personal services by a contractor who is not an employee of the school On the date on which the school makes a binding written commitment to obtain the services (d) Performance of work other than personal services On the date on which the school makes a binding written commitment to obtain the work. (e) Public utility servicesWhen the school receives the services (f) TravelWhen the travel is taken. (g) Rental of real or personal propertyWhen the school uses the property. (h) A pre-agreement cost that was properly approved by the State under the cost principles identified in 34 CFR 74.171 and 80.22.
EDGAR §80.32 Equipment May be used in the program or project for which acquired as long as needed, whether or not the project or program continues to be supported by federal funds When no longer needed may be used in other activities currently or previously supported by a federal agency
EDGAR §80.32 Equipment Shall be available for use on other projects or programs currently or previously supported by federal government providing that use will not interfere with work on the projects or program for which it was originally acquired When acquiring replacement equipment, may use the equipment to be replaced as a trade-in or sell the property and use the proceeds to offset the cost of the replacement property subject to the approval of DPI
Property Management Records must be maintained that include the following: Description of the property Serial number or other identification number Source of property Who holds title Acquisition date Cost of the property Percentage of federal participation in the cost of the property Location Use and condition of the property Any ultimate disposition data including date of disposal and sale price of the property
Property Management Physical inventory of property must be taken and reconciled with the property records at least once every two years. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft. Any lost, damage, or theft shall be investigated. Adequate maintenance procedures must be developed to keep the property in good condition.
Property Management If school is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return.
Property Management When original or replacement equipment acquired under a grant is no longer needed for original project or program or for other activities currently or previously supported by a federal agency, disposition of the equipment will be made as follows: 1) Current fair market value < $5,000 may be retained, sold or disposed of with no further obligation to the federal government. 2) Current fair market value > $5,000 may be retained or sold and the federal government shall have a right to an amount calculated by multiplying the current market value or proceeds from sale by the federal share of the equipment.
Contact Information for Program Accountants DPI Website – Divisions and Teams – School Management Services – Federal Aids and Audit Each Accountant Assigned Specific Grants Accounting Staff and Assignments http://dpi.wi.gov/sms/fedasign.html Link to Aids Register Codes 47 Federal Aids and Audit Section
Financial Management Handbook for Federal and State Grant Programs http://dpi.wi.gov/sms/handbook.html Fiscal Requirements and Procedures to Assist Grant Recipients Proper Disbursement, Accounting and Accountability for Federal and State Funds 48 Federal Aids and Audit Section
Claiming for Grant Funds – Accountants Claims Must Match Budgets Final Claim Report Must be Signed Certifying Accuracy of the Report Fiscal Claim Report PI-1086 http://dpi.wi.gov.sms/pi-1086.html Instructions http://dpi.wi.gov.sms/pdf/instruct.pdf 49 Claims
To receive reimbursement for grant expenditures submit a Program Fiscal Report (Form PI-1086). Quarterly claims are recommended, however, you can submit monthly claims. A final claim is due 90 days after the end of the project. Most programs require expenses to be paid by June 30 and final claims submitted by September 30. An authorized signature is required on the final claim. 50 Claims
A signed copy of the final claim can be submitted by: MAIL: Department of Public Instruction Federal Aids and Audit Section P O Box 7841 Madison WI 53707-7841 FAX: 608/267-9207 (Attn. to Grant Accountant) E-MAIL: To the DPI accountant assigned to the program. See the following link for the assignment sheet: http://dpi.wi.gov/sms/fedasign.html 51
Instructions for completing the Program Fiscal Report District Number: LEAs use the 4-digit agency code. District/Agency Legal Name: Name of LEA. CFDA Number or State Statute Report for Period Ending: Report month and year through which report is completed. Project Grant Number: Report Grant Number from Notification of Grant Award. 53 Claim Instructions
Program Name: For example, ESEA Title II B Math & Science Partnership. Project Beginning Date: Beginning date as specified in Notification of Grant Award. Project Ending Date: Ending date as specified in Notification of Grant Award. Account Code: WUFAR Codes for LEAs. 54 Claim Instructions
Account Name: Report categories from the Budget Summary page (example, PI-9550-IIB) from application. Approved Budget: Enter the budget amounts as approved from the application Budget Summary page. Unliquidated Encumbrances: Report unpaid obligations (i.e., payables, open purchase orders, personal services contracts, etc.). Encumbrances should be liquidated on the final report. Total Disbursements: Report the cumulative total of disbursements made to date. 55 Claim Instructions
Unencumbered Balance: Report the amount of funds that have neither been obligated nor disbursed. Cash Summary: Report total funds received to date, disbursed and remaining. Amount Requested: Enter amount requested for this claim. 56 Claim Instructions
Federal Grant Guidance is available at: http://dpi.wi.gov/sms/handbook.html http://dpi.wi.gov/sms/handbook.html Federal Aids & Audit Personnel and Staff Assignments: http://dpi.wi.gov/sms/fedasign.html Program Fiscal Report (PI-1086) and Instructions: http://dpi.wi.gov/sms/pi-1086.html Related Links: http://dpi.wi.gov/sms/relatedlinks.html 57
Audit Requirement Wis. Stat. 118.40 (2r)(b)(2) “A charter shall include all of the provisions specified under sub.(1m)(b)3. to 14.” Wis. Stat. 118.40 (1m)(b)11 “The manner in which annual audits of the financial and programmatic operations of the school will be performed.”
2r Independent Charter Schools 2r charter schools are considered a local educational agency. Wis. Stat. 115.775; “….an operator of a charter school under s. 118.40(2r) is a local educational agency, as defined in 20 USC 1401 (19)...” United States code: title 20,1401 defines an LEA as: “local education agency” means a public board of education or other public authority legally constituted within a State for either administrative control or direction of, or to perform a service function for, public elementary schools or secondary schools in a city, county, township, school district, or other political subdivision of a State, or for such combination of school districts or counties as are recognized in a State as an administrative agency for its public elementary schools or secondary schools.”
Federal Single Audit Non-Federal entities that expend $500,000 or more in a year in Federal awards shall have a single or program- specific audit conducted for that year in accordance with the provisions of OMB Circular A-133. Non-Federal entities that expend less than $500,000 a year in Federal awards are exempt from Federal audit requirements for that year,, but records must be available for review or audit by appropriate officials of the Federal agency, pass-through entity, and General Accounting Office (GAO).
Federal and State Aid Aids Register - http://dpi.wi.gov/sfs/online_ar.htmlhttp://dpi.wi.gov/sfs/online_ar.html Reflects payments the school received from the department during the year. Does not reflect year end receivables but does include prior year end receivables. STRICTLY cash basis!
State Single Audit Guidelines Available at: http://www.doa.state.wi.us/section.asp?linkid=81 &locid=167 http://www.doa.state.wi.us/section.asp?linkid=81 &locid=167 *SSAG Summary 2011 Department of Public Instruction Appendix to the State Single Audit Guidelines for Programs from the Department of Public Instruction
State Single Audit Guidelines 2.1 Audit requirement for DPI programs Audits of agencies receiving state aid for programs from the Department of Public Instruction will be in accordance with the following standards prescribed by the department. These agencies include school districts, 2r independent charter schools, cooperative educational services agencies (CESA) and county children with disability education boards (CCDEB).
State Single Audit Guidelines State Single Audit Guidelines – Agencies receiving state aid that have audits in accordance with OMB Circular A-133 “Audits of States, Local Governments, and Non-Profit Organizations” and that receive more than $25,000 in department funds, need to have audits in accordance with the State Single Audit Guidelines, including this appendix to the Guidelines. Wisconsin Public School District Audit Manual – Agencies with designated major state programs must have an audit of compliance with the requirement applicable to those designated state programs and must also issue a report on its system of internal control over compliance in accordance with the Wisconsin Public School District Audit Manual.
State Special Education Aid The Department of Public Instruction has designated certain programs to be state major programs when agencies receive these programs directly from the department. In the parlance of OMB Circular A-133, the department considers these programs to be Type A programs that cannot be treated as low risk programs. Therefore, these programs are to be tested as major programs in all audits for which the auditee receives funding for these programs directly from the department: Designated major programs Section 3.1 General Aids (not applicable to 2r charter schools) Section 3.2 Special Education and School Age Parents Aid
Audit Requirement Wis. Stat. 115.88(1m)(am) “(am) Subject to par. (b), if the operator of a charter school established under s. 118.40 (2r) operates a special education program and the state superintendent is satisfied that the operator of the charter school is complying with 20 USC 1400 to 1491o, the state superintendent shall certify to the department of administration in favor of the operator of the charter school a sum equal to the amount that the operator of the charter school expended during the previous school year for salaries of full-time or part-time licensed teachers, licensed coordinators of special education, school nurses, licensed school social workers, licensed school psychologists, licensed schoolcounselors, paraprofessionals, licensed consulting teachers to work with any teacher of regular education programs who has a child with a disability in a class and any other personnel, as determined by the state superintendent, as costs eligible for reimbursement from the appropriation under s. 20.255 (2)(b). The state superintendent may audit costs under this paragraph and adjust reimbursement to cover only actual, eligible costs.”(b)118.40 (2r)20 USC 14001491o20.255 (2)(b)
Auditing State Special Education Aid Audit Program available at: http://dpi.wi.gov/sms/cs_currentChrSchs.html http://dpi.wi.gov/sms/cs_currentChrSchs.html Reports Needed Audit Procedures Reporting
Auditing State Special Education Aid Reports Needed All special education excess costs identified Includes all costs and not just those eligible for state categorical aid Special Education claim filed with DPI May not be available at time of audit Special Education Categorical Aid Eligible Costs Resource guide on what is eligible Special education license staff listings (valid and non-valid) Online or per request from DPI
Auditing State Special Education Aid State Special Education Categorical Project Codes: Project 011 - State Categorical Aid Aidable Cost Project 019 - Non-Aidable Cost Project 340 - Cost Reimbursable by Direct Federal IDEA Monies Project 810 - Cost Reimbursable by Direct Federal ARRA Monies
Auditing State Special Education Aid Audit Procedures Verify claim to expenditures in general ledger No valid license list http://dpi.wi.gov/sfs/safrlinks.html Do not need to test the individuals on the list Send an e-mail to DPI with the salaries and benefits reported If individual was incorrect on PI-1202, obtain written representation from school administrator or individual authorized to complete the PI- 1202 Perform payroll test Valid license list Payroll register and general ledger Review: Personal services costs or employee travel Payments to non-governmental agencies Pupil transportation costs Vehicle acquisition
Auditing State Special Education Aid Reporting Questioned Cost Excel spreadsheet e-mailed to DPI (online) Included in “Summary of Audit Findings” in the single audit report Identify total eligible cost on “Schedule of State Awards” footnote
Reporting Package Financial Statement(s) Opinion on Financial Statements Schedule of Expenditures of Federal Awards Schedule of Expenditures of State Awards Summary Schedule of Prior Audit Findings Schedule of Findings and Questioned Costs Corrective Action Plan Date Collection Form filed with Federal Clearinghouse
Reporting Package Independent Auditor’s Report on Internal Control over Financial Reporting and on Compliance and Other matters Based on an Audit of Financial Statements Performed in Accordance with Government Auditing Standards Independent Auditor’s Report on Compliance with Requirements that Could have a Direct and Material Effect on Each Major Federal and State Program and on Internal Control over Compliance in Accordance with OMB Circular A-133 and the State Single Audit Guidelines If the school is not required to have a federal single audit: Independent Auditor’s Report on Compliance with Requirements Applicable to State programs and Internal Control Over Compliance Samples available at: http://dpi.wi.gov/sfs/aud_list.htmlhttp://dpi.wi.gov/sfs/aud_list.html
Report Due Dates October 12, 2012Special Ed - No Valid License Worksheet (if applicable) December 3, 2012Audited Financial Statements December 3, 2012Federal and State Single Audit Report May 1, 2013Membership Audit
Common Control Deficiencies Segregation of Duties Preparation of financial statements and schedule of financial assistance Material Adjustments Internal Control Deficiencies
Finding Claims submitted for reimbursement are not reviewed by anyone other than the preparer District has no review procedure related to claims submitted for reimbursement Auditor Recommendation An individual other than the preparer of the claim should review and approve the claim prior to submission Review of claims filed
Allowable Costs/Cost Principles Compensation for Personnel Services (includes salaries, wages, and fringe benefits) Compensation considered reasonable to the extent that it is consistent with that paid for similar work in other activities of the governmental unit Time and Effort Reporting Allowable if costs are reasonable, comparable for similar work, and charges are supported with time distribution records or other documentation as stipulated in OMB A-87. Types of Compliance Requirements
Time and Effort Reporting Finding Payroll certifications were not prepared to support the salaries of individuals tested The District's management was unaware of the requirement under OMB Circular A-87 Auditor Recommendation District obtain semi-annual payroll certifications and timesheets for all employees funded by Federal programs Allowable Costs/Cost Principles
Time and Effort Reporting DPI Response for 2010-11 findings The District needs to implement a procedure for the preparation of semi-annual certifications or personnel activity reports as soon a they receive the auditor finding. DPI will be following up with a notification that monitoring will occur for verification of personnel claimed on the grant in the 2011-12 school year. Allowable Costs/Cost Principles
Finding Special Education Teacher not properly licensed Auditor Recommendation District review staff each year for appropriate license Allowable Costs - Unlicensed Staff
Finding The District claimed 100% of the salary and benefits of an employee for the IDEA program. This employee only spends 90% of their time working with the IDEA program. Therefore, only 90% of their wages should be expensed to the program Miscommunication between the IDEA program office and the accounting department Auditor Recommendation District perform an evaluation to determine what percent of this and other employees’ total time is spent working on the IDEA program and adjust accounting records accordingly. Allowable Cost - Excess Salaries
Finding District charged a portion of special education aide’s wages and fringe benefits to the IDEA Flow through grant but the aide did not work with special education students District did not timely review employee eligibility to be charged to the grant. Error was found by the District while preparing the time and effort certifications. Auditor Recommendation. District personnel review employees charged to federal grants to ensure compliance with allowable cost principles. Allowable Costs-Excess Salaries
Finding Not segregating all of the ARRA grant expenditures by using project codes to track them ARRA reporting requires all expenditures for these grants need to be accounted for separately Auditor Recommendation District record all ARRA grant expenditures to the proper project code and submit quarterly grant reimbursements based on those expenditures Allowable Costs- Use of Project Codes
Finding General ledger detail did not agree to the line item expenditures reported on the grant claims District did not request amendments to original budget approved by DPI Lines for salaries, employee benefits, purchased services, non-capital objects, and capital objects were not in agreement. Total expenditures charged to the grant agreed in total to the grant claims Allowable Costs
Auditor Recommendation Before submitting reimbursement request, District should request a budget amendment to move expenditures between the budget line items, if necessary Allowable Costs
Finding Drew down Title I funds before incurring the expenditure Lack of controls in place to prevent the drawdown prior to the expenditure Auditor Recommendation Procedures be put in place to verify expenditure occurred prior to the claim Cash Management
Audit Finding filed with DPI DPI School Finance Auditor Reviews School Finance Auditor provides appropriate program staff with the finding Program staff follow up with district Resolution required Follow up in subsequent year Fiscal Monitoring DPI Follow-up and Resolution to Federal Audit Findings
Requires the State as the pass-through agency to issue a management decision on audit findings and ensure that appropriate and timely corrective action is taken. The management decision states whether or not the audit finding is sustained, the reasons for the decision, and the expected action to repay disallowed costs, make financial adjustments or take other action. Prior to issuing the management decision, the State may request additional information or documentation OMB Circular A-133
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