A UDIT R ESOLUTION Debra Jennings, Team C (McPherson) Charles Kniseley, Team B (Gregorian) Lisa...

AUDIT AUDIT RESOLUTIONRESOLUTION

Debra Jennings, Team C (McPherson)

Charles Kniseley, Team B (Gregorian)

Lisa Pagano, Team A (Corr)

Cynthia Bryant, Team D (Ringer)

Deborah Morrow, Special Assistant for Policy and Fiscal Issues (Ryder)

8/17/09

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INTEGRATED FISCAL ACCOUNTABILITY (IFA)

AUDIT RESOLUTION AUDIT RESOLUTION PROCESSPROCESS

Single Audit Act requires annual audit - Type A programs ($500,000) and at-risk Type B ($100,000)

Completed audits submitted to Clearinghouse

Clearinghouse disperses audits to agencies

ED Audit Triage group meets monthly to receive new audits and determine whether resolution will be “abbreviated” or “full”

8/17/09INTEGRATED FISCAL ACCOUNTABILITY (IFA) 2

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Resolve 6 Months from date audit report is issued

Timelines and process beginning with 2008 audits

Notify State of receipt within a month

Set up call to discuss findings

Confirm call with email or letter requesting documentation

8/17/09INTEGRATED FISCAL ACCOUNTABILITY (IFA)

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Collaborative process

Proactive response from State – as soon as you know what the audit finding will be (usually when you are responding to the draft report from the auditor)

Begin compiling documentation

Develop policies and procedures

Obtain approvals within your Division or Department as required


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When providing documentation to OSEP

Talk to your AF in advance

Clearly indicate the audit (ACN if you have it, such as 02-08-67823) and the specific finding to which it applies

Notify (email or phone) your AF


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PDL within 30-60 days of receipt of documentation – if documentation resolves the finding

If documentation not received in 35 days, MSIP Director will contact State and provide 10 days for response

If documentation is not received in 10 days, the OSEP Director will contact the CSSO and provide 10 days for a response


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g

COMMON AUDIT FINDINGS COMMON AUDIT FINDINGS (AND WHAT TO DO ABOUT (AND WHAT TO DO ABOUT

THEM)THEM)

Monitoring

Examples

Evidence of Processes

Procedures

Policy(ies)


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THEM)THEM)

Subrecipient monitoring Audit standard: SEA must monitor

subrecipient’s use of Federal funds through reporting, site visits, regular contact, or other means to ensure legal requirements are met and performance goals achieved.

Documentation for resolution Policies/procedures related to monitoring Recent monitoring results Demonstration of monitoring for

programmatic and fiscal requirements


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THEM)THEM)Time and Effort Distribution

Audit Standard:

Employees work on a single Federal award - at least semi-annual certifications, signed by the employee or supervisory official.

Employees work on multiple Federal grants, distribution of salaries supported by personnel activity reports that: (a) reflect an after-the-fact distribution of the actual activity of each employee; (b) account for the total activity for which each employee is compensated; (c) be prepared at least monthly and must coincide with one or more pay periods; and (d) be signed by the employee. See OMB Circular A-87, Attachment B.8.h.3.


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THEM)THEM) Documentation for resolution

Policies/procedures related to time and effort distribution

Sample certification forms or time sheets showing how employees distribute their time and effort among grants

Samples of signed certifications or completed time sheets reflecting time and effort distribution


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THEM)THEM)

State Maintenance of Financial Support

Audit Standard: A State must not reduce the amount of financial support for special education and related services...below the amount of that support for the preceding year (34 CFR §300.163(a))


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THEM)THEM) Documentation for Resolution

Policies and procedures for calculating State maintenance of support

Documentation of calculation of support in preceding year along with documentation of support in preceding year

Documentation of calculation of support in audit year along with documentation of support in audit year


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THEM)THEM)LEA Maintenance of Effort (MOE) Audit standard: Funds provided under

Part B of the Act must not be used to reduce the level of expenditures...below the level...of the preceding year:

Local funds only OR State and local funds (year to year)

Per capita or in total


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Policies and procedures regarding LEA MOE

Verification of documentation of effort in preceding year

Verification of documentation of effort in audit year

Verification of exceptions under 34 CFR §300.204

Verification of authority under 34 CFR §300.205


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THEM)THEM)

Timely Obligation/Liquidation of FundsAudit Standard: In accordance with applicable period of availability requirements, funds appropriated in July of a fiscal year remain available for obligation during the succeeding 27 months with ninety days to liquidate obligations after the period of availability ends.


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THEM)THEM) Documentation of Resolution

Policies and procedures specifying the period of availability, required documentation and accounting procedures to ensure appropriate obligation/liquidation

Purchase orders, signed contracts or other accounting records of obligations for allowable purposes within the obligation period

Invoices, checks, payroll records or other accounting records demonstrating liquidation within the allowable period


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THEM)THEM)ProcurementAudit Standard: Grantees must follow EDGAR standards intended to ensure effective procurement and compliance with Federal requirements. Standards address responsibilities of grantees, codes of conduct, encouraging competition, establishing written procedures, cost and price analysis, maintenance of records, monitoring contract administration and various other provisions.


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Policies and procedures that address all required EDGAR provisions (34 CFR §80.36)

Process flow charts, forms reflecting the appropriate requirements/standards

Completed forms documenting the flow chart processes, reflecting implementation of requirements, including appropriate approvals and justifications; evidence of training on revised procedures


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THEM)THEM)Prior Grantor Approval

Audit Standard: According to OMB Circular A-87 (2 CFR Part 225), Attachment B, section 19.2.C, capital expenditures for equipment, including replacement equipment, other capital assets, and improvements which materially increase the value of the useful life of the equipment or other capital asset are allowable as a direct cost when approved by the awarding agency. Federal awarding agencies are authorized, at their option, to waive or delegate this approval requirement.


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THEM)THEM) Documentation of Resolution

Policies and procedures that require approval from OSEP to purchase items of equipment with a unit price of $5000 or more, for construction or for renovation

RFPs, contracts, purchase orders or other records that document approval and obligations AFTER approval is received

Documentation that expenditures comply with section 605 of IDEA and that expenditures are for allowable purposes


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SUMMARYSUMMARY

Begin correction upon receipt of audit – don’t wait for OSEP

Focus on the finding – do you need to submit policies/ procedures, evidence of process, evidence of implementation?

Identify appropriate State staff to assist OSEP

Communicate status of resolution activities

Respond to information requests promptly

Request assistance, as needed


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OSEP AUDIT FACILITATORSOSEP AUDIT FACILITATORS

Team A – Gregg Corr [email protected] 202-245-7413

Team B – Judy Gregorian [email protected] 202-245-7322

Team C – Alma [email protected]

202-245-7389

Team D – Larry Ringer [email protected]

202-245-7284

Fax – 202-245-7614

[email protected]

ADDRESS:Office of Special Education

ProgramsU.S. Department of Education400 Maryland AvenueWashington, DC 20202ATTN: ------


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ELECTRONIC ELECTRONIC CALCULATORSCALCULATORS

1. Appendix A to Part 300 --Excess Costs Calculation

2. Appendix B to Part 300 --Proportionate Share Calculation

3. Appendix D to Part 300 --Maintenance of Effort and Early Intervening Services


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RATIONALE FOR RATIONALE FOR ELECTRONIC ELECTRONIC

CALCULATORSCALCULATORS To offer a streamline process of

researching Federal regulations and appendixes related to each calculation

To provide tools that can be easily referenced

To offer easy access to LEAs and SEAs

To serve as resources for LEAs and SEAs

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CALCULATORS FEATURESCALCULATORS FEATURES

Data is presented in an application format

Allows users to access regulations as they use calculators

Large amount of data can be consolidated and displayed in one view, using graphics like gauges and thermometers

Ability to predict and forecast by using “what if” scenarios

Visual effects that allow users to see impact as numbers change

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CALCULATORS CALCULATORS FEATURES – FEATURES – CONTINUEDCONTINUED

Allows the integration of specific Q & A from the Part B ARRA April 2009 Guidance

Can be adjusted to reflect more Federal regulations and State Statutes and Procedures

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CALCULATORS LINKSCALCULATORS LINKS

Proportionate Share: http://www.northcentralrrc.org/calculators/Proportionate%20Share%20Calc%20v1.swf

MOE-EIS: http://www.northcentralrrc.org/calculators/MOE%20EIS%20Calc%20v1.swf

Excess Cost: http://www.northcentralrrc.org/calculators/Excess%20Cost%20Calc%20v1.swf

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OTHER MOE CALCULATORSOTHER MOE CALCULATORS

Wisconsin Department of Public Instruction http://www.dpi.state.wi.us/sped/idearecovery.html

Contact Information:

Rachel Zellmer, IDEA Grant SpecialistEmail: [email protected]

Mark Magnuson, IDEA Grant AccountantEmail: [email protected]

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OTHER MOE CALCULATORSOTHER MOE CALCULATORS

State of Washington Office of Superintendent of Public Instructionhttp://www.k12.wa.us/safs/TT/tools.asp

Contact Information

Mary Ellen Parrish, Special Education Safety Net SupervisorEmail: [email protected]

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CONTACT INFORMATIONCONTACT INFORMATION

Contact Information:

Michael Luseni, State Technical Assistance Specialist

Email: [email protected]: 612-625-2388

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