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CAROI
First Supplement to Matrix of Closed Findings

Commonwealth of Pennsylvania (PA) and U.S. Department of Education (ED)

Year/ Finding# PA Auditee Finding Description PA Comments
(Provided to ED on 7/9/97)
Determination
FINDINGS RELATED TO OESE
FY 1994 - 86

 

DOH DOH did not comply with Drug-Free Schools and Communities (DFSC) Program subgrantee application and monitoring requirements, and did not comply with supplanting requirements of Section 5123 of the DFSC Act, resulting in questioned costs of $966,177. (A similar condition was noted in prior year finding #86.) DOH has implemented its corrective action plan for this finding. This corrective action involves improving the current language in the Single County Authority (SCA) contracts, and strengthening reporting and monitoring procedures for DFSC funds. This revised language is included in Amendment #2 of the current contract with the SCAs, effective July 1, 1996. Additionally, reporting forms and reporting requirements have been revised to meet audit requirements and are being submitted by SCAs for SFY 1996/97. Based on the information provided by PA, it appears that DFSCA funds were used to support the implementation of SAPs. A violation of the supplement, not supplant provision has not been established and recovery of any questioned costs in connection with finding #86 for 1994 and finding #63 for 1995 is not warranted. Therefore, no corrective action is required and we consider this matter closed.
FY 1995 - 44

 

PDE The auditors found that, in calculating maintenance of effort (MOE) for its LEAs under Chapter 1 of Title I of the Elementary and Secondary Education Act (ESEA), the PDE did not deduct the correct amount of Federal expenditures. According to the auditors, PDE deducted only Chapter 1 and Chapter 2 expenditures, whereas the auditors interpreted the Chapter 1 regulations to require expenditures of all Federal funds to be deducted. The auditors recommended that PDE recalculate MOE, deducting expenditures of all Federal funds. In a letter dated January 17, 1997, PDE indicated that it had recalculated MOE according to the auditors' recommendation and found that all LEAs were in compliance. During the 1995/96 single audit review of PDE, the auditors have indicated that this finding did not recur. Section 1018(a) of Chapter 1 provided that MOE could be met by an LEA by determining "either the combined fiscal effort per student or the aggregate expenditures of that agency and the State with respect to the provision of a free public education by that agency...." The Chapter 1 regulations found at 34 CFR 200.41(a)(3)(ii) stated that expenditures made from funds provided under Chapter 1 and Chapter 2 of the ESEA were not to be considered in determining an LEA's compliance with the MOE requirement. At the time of the audit, all other Federal funds were to be part of the MOE calculation. Thus, PDE properly excluded only Chapter 1 and Chapter 2 funds. Although the auditors disagreed with this method of calculating MOE, they did not find any LEAs out of compliance. Moreover, according to PDE's January 17, 1997 letter, all LEAs were also in compliance with MOE even if all expenditures of Federal funds were excluded.

Currently, the MOE requirement that applies to Part A of Title I of the ESEA (successor to Chapter 1 of the ESEA) is in section 14501 of Title XIV of the ESEA. The regulations implementing this MOE requirement in 34 CFR 299.5(d)(2)(ii) require that all expenditures of Federal funds be excluded from the calculation of MOE. According to information provided by PDE, the PDE is currently excluding all expenditures of Federal funds in calculating MOE. Therefore, we consider this finding closed.

FY 1995 - 63

 

PDE DOH did not comply with DFSC Program subgrantee application and monitoring requirements and did not comply with supplanting requirements of Section 5123 of DFSC Act, resulting in questioned costs of $892,982. (A similar condition was noted in prior year finding #86.) In response to ED's December 17, 1996 request, PDE provided additional information in a January 17, 1997 letter to ED. In a response to ED's March 5, 1997 letter, the Governor's [Drug?] Policy Office [Council?] indicated concurrence with PDE's January 17, 1997 letter to ED. PDE will await a response from ED. This finding is considered closed. Please see the determination for Finding #86.
FY 1996 - 28

 

PDE The auditors found that PDE, in allocating basic grant funds to its LEAs under Chapter 1 of Title I of the ESEA, incorrectly calculated the hold harmless amounts for 22 LEAs tested. Specifically, the auditors found that PDE assigned funds generated by delinquent children to the LEA providing services to those children but did not assign the corresponding child count. The auditors concluded that only one LEA--Central Bucks School District--received an incorrect basic grant allocation due to the incorrect method for calculating hold harmless amounts and questioned $9,710. Central Bucks School District was notified that its allocation for 1995/96 was in error and that its allocation would thereby be reduced by $9,710. Central Bucks submitted an original and revised Final Completion Report indicating that it reduced expenditures by $9,710. The PDE's Division of Federal Programs is in the process of having all administrative technicians cross trained in computing allocations. By doing this, PDE can better monitor the situation. This finding is now resolved and closed. For the year in question, PDE calculated basic grant hold harmless amounts by assigning funds generated by delinquent children to the LEAs providing services to those children, rather than the LEAs in which those children generated funds. However, the LEA did not assign the corresponding child counts to the serving LEAs. The auditors found, and we agree, that this methodology was incorrect because funds and child counts were not treated consistently. According to the auditors, however, only one LEA--Central Bucks SD--received an incorrect basic grant allocation because of PDE's methodology and, based on documentation provided by PDE, that allocation has been corrected.

PDE described its current procedures for calculating hold harmless amounts and they appear to be acceptable. According to those procedures, PDE assigns both funds and child counts to the LEA for which the funds were generated.

FY 1995 - 43 PDE The auditors found that PDE and LECS Comptroller Office did not have procedures to ensure that obligations of Federal funds were liquidated on a timely basis. The auditors cited 34 CFR 80.23, which required a grantee to liquidate all obligations no later than 90 days after the end of the funding period unless this deadline was extended by ED at the request of the grantee. Specifically, the auditors found one LEA that had not liquidated $7,201 under Chapter 1 of Title I of the ESEA within 90 days of the end of the funding period. Accordingly, the auditors questioned $7,201. In response to this finding, PDE referred to a letter from ED dated August 29, 1996, wherein PDE was given an extension of the 90-day liquidation deadline for 1992-1993 and 1993-1994. PDE also indicated that the LECS Comptroller Office has established a new policy requiring LEAs to submit final completion reports within 30 days after the funding period ends in order to ensure that all obligations have been liquidated within 90 days. This finding is now resolved and closed. Section 80.23(b) of the Education Department General Administrative Regulations requires a grantee to liquidate all obligations no later than 90 days after the end of the funding period unless this deadline is extended by ED at the request of the grantee. On August 29, 1996, ED granted PDE's request for an extension of the 90-day liquidation period for FYs 1993 and 1994. However, that extension did not cover FY 1995 and subsequent fiscal years. The PDE has established procedures that require LEAs to submit Final Completion Reports within 30 days after the end of the funding period. These procedures will enable PDE to ensure timely processing of reports and liquidation of obligations within the 90-day period. In light of these new procedures and in response to a request from PDE, we are extending the 90-day liquidation period for FYs 95, 96, and 97, as needed, until September 30, 1998 and are not requiring the repayment of $7,201 of Chapter 1 funds questioned in the audit report.
FY 1995 - 45 OB - LECS The annual State per pupil expenditure report prepared by LECS Comptroller Office was inaccurate. Additional information was submitted on January 14, 1997 stating that the LECS Comptroller Office has automated all possible edit checks on the source financial reports and will meet with programmers each year to review these edit checks. Additional manual compensating controls have also been incorporated with the 1995 NPEFS. This finding is now resolved and closed. State per pupil expenditure (SPPE) data are used for calculating billions of dollars in allocations under several Federal education programs, including Title I of the ESEA and its predecessor, Chapter 1. See e.g., 20 U.S.C. 6333(a)(1994); 20 U.S.C. 2711(a)(2)(1988). It is extremely important that these data are accurate, because allocations under Title I, for example, are interdependent and thus, an error in reporting SPPE data by one State may affect the allocations of all other States.

In response to the auditors' finding, PDE revised its SPPE data for FY 1994 and submitted those revisions to ED's National Center for Education Statistics before those data were used for allocating Federal funds. Moreover, LECS Comptroller Office and the PDE have instituted extensive procedures including crosswalks and edit checks designed to eliminate errors in SPPE reporting. ED is satisfied that LECS and PDE have taken substantial steps to ensure that this finding does not recur.

FINDINGS RELATED TO OSERS/OSEP
FY 1993 - 67

 

PDE Subgrantee child count reports were not certified. PDE will continue to review the child count reports and require certification from the LEAs. LEAs who fail to meet the required timeliness will be advised that their child count will not be included in PDE's submission to ED. PDE considers this finding resolved with no further action necessary. PDE is awaiting final notification from ED. This finding is closed and no further corrective action is required. The Assistant Secretary for Special Education and Rehabilitative Services determines that PDE's representation that it has taken appropriate steps to ensure that proper certifications of LEA child count submissions are obtained is sufficient to resolve this finding.
FY 1994 - 73

 

PDE PDE and LECS Comptroller Office did not have procedures to ensure that obligations were liquidated on a timely basis, resulting in questioned costs of $135,529. PDE will change the report submission date to 30 days after the end of the project year and will, if necessary, ask the appropriate ED office for an extension of the 90 day deadline. PDE continues to review the Final Completion Reports in a timely manner. PDE awaits a PDL from ED. This finding is closed. The Assistant Secretary for Special Education and Rehabilitative Services determines that PDE has taken appropriate steps to ensure its compliance with the requirements, set out at 34 CFR 80.23(b), that expenditures be liquidated on a timely basis or that a request for an extension will be made. In addition, the Assistant Secretary concludes that no return of funds or any other corrective action is needed to resolve this finding. The Assistant Secretary also, consistent with the determination of the Assistant Secretary for Elementary and Secondary Education for finding 43, fiscal year 1995, extends the liquidation period for FYs 94, 95, 96, and 97 until September 30, 1998. (Finding 43, fiscal year 1995, is resolved as part of First Supplement to Matrix of Closed Findings.)
FY 1995 - 48

 

PDE Inadequate documentation to support an undetermined amount of personnel costs up to $69,490. (A similar condition was noted in prior year finding #67.) During the 1995/96 single audit review of PDE, the auditors have indicated resolution of this finding. However, PDE awaits a PDL from ED. This finding is closed. The Assistant Secretary for Special Education and Rehabilitative does not sustain this finding. The cost principles applicable during the time period covered by this finding establish that an employee paid with Federal funds is only required to maintain time distribution records if working on more than one cost objective. OMB Circular A-87, 46 Fed. Reg. 9552 (January 28, 1981). Thus, an employee who works on only one cost objective does not have to maintain such records. In this instance, the audit finding does not establish that this employee worked on more than one cost objective and, as a result, is not sufficient to establish a prima facie case for recovery of the questioned costs. See 20 USC 1234a(a)(2). All the various activities that the audit indicates this employee worked on, Chapter 1 - Handicapped, Private Residential Rehabilitative Institutions and Public School Special Education, payments for State funding for special education, all concern special education and therefore could relate to the IDEA-B program. More importantly, there is nothing in the audit report that indicates that this particular employee worked on matters that were unrelated to Part B. Finally, in an audit determination issued on June 28, 1996, involving a similar finding for this same employee, the Assistant Secretary concludes that recovery of funds because of a lack of time distribution records was not appropriate. For these reasons, the Assistant Secretary concludes that this finding should not be sustained and that PDE is not required to return any of the costs questioned under it.
FINDINGS RELATED TO OSERS/RSA
FY 1992 - 77

 

L&I L&I did not adhere to contracting and procurement requirements resulting in questioned costs of $13,812. L&I and LECS Comptroller Office met with a member of the OB Legal Staff in November 1993 to request a waiver from MD M215.1. The OB Legal Staff recommended that a waiver from the provisions of MD M215.1 and 215.6 be granted and a waiver was approved. On August 29, 1996, L&I responded to a PDL explaining their position, stating what corrective action has been taken and that they believe no further corrective action is required. L&I is awaiting a response from ED. This finding is now resolved and closed. None of the questioned costs are disallowed. The Department has accepted the documentation submitted by L&I explaining and describing its procurement policies and procedures. The Department also accepts L&I's corrective actions with respect to the suspension and debarment issue, which were detailed in L&I's letters of August 29, 1996, and September 5,1997.

The Department further states that, absent a finding by auditors that unreasonable or unnecessary costs have been charged to a Federal grant, the Department will accept a waiver from State procurement policies and procedures granted by a State to a State agency, if those procurement policies and procedures permit such a waiver. However, if auditors find that unreasonable or unnecessary costs have been charged to a Federal grant as a result of the alternative procurement policies and procedures, the Department may: (a) reject such a waiver or that part of the waiver that resulted in the charging of unreasonable or unnecessary costs to the Federal grant; and (b) require that the alternative procurement policies and procedures, or such part of them that resulted in the charging of unreasonable or unnecessary costs to the Federal grant, be revised to conform with the State's normally applicable procurement policies and procedures, consistent with the Department's regulations at 34 C.F.R. ' 80.36(a). The Department will not use isolated instances of unreasonable or unnecessary costs that are not the result of the alternative procurement policies and procedures as a basis to reject a waiver or any part of a waiver granted by a State.

FY 1993 - 76 L&I L&I did not adhere to contracting and procurement requirements, resulting in questioned costs of $14,360. (A similar condition was noted in the previous single audit.) L&I and LECS Comptroller Office met with a member of the OB legal staff in November 1993 to request a waiver from MD M215.1. The OB legal staff recommended that a waiver from the provisions of MD M215.1 and 215.6 should be granted and a waiver was approved. L&I has explained their position to ED, what corrective action has been taken and that they believe no further corrective action is required. L&I is awaiting a response from ED. This finding is now resolved and closed. None of the questioned costs are disallowed. The determination for Finding #77 (1992) applies to this finding. Therefore, the Department withdraws that part of the determination issued on June 30, 1997, for this finding, in which the waiver from the Commonwealth's procurement policies and procedures that was granted to L&I was determined invalid.
FY 1993 - 77

 

DPW DPW did not adhere to contracting and procurement requirements resulting in questioned costs of $1,683. DPW strongly disagrees with the auditors' contention that general contracting and procurement provisions apply to these services and therefore plans no corrective action. However, DPW has not been contacted with regard to this finding. This finding is now resolved and closed. None of the questioned costs are disallowed. The determination for Finding #77 (1992) applies to this finding. Therefore, the Department will accept DPW's assurance that it will obtain a waiver from those policies and procedures as adequate corrective action to resolve this finding. If DPW is not successful in obtaining a waiver from the Commonwealth's procurement policies and procedures, DPW must comply with those procurement policies and procedures. The Department will monitor DPW's attempt to obtain the waiver.

The Department also accepts DPW's new form for contracts, which has all the required certifications and has been approved by the Attorney General as an approved contract, as adequate corrective action with respect to the suspension and debarment issue raised in the determination issued on September 30, 1997.

FY 1994 - 78

 

DPW DPW did not adhere to contracting and procurement requirements resulting in questioned costs of $6,538. (A similar condition was noted in prior year finding #77.) DPW disagrees with this finding and previous findings on this issue. DPW has not yet been contacted with regard to this finding. This finding is now resolved and closed. None of the questioned costs are disallowed. See determination for Finding #77 (1993).
FY 1994 - 79 L&I L&I did not adhere to contracting and procurement requirements, resulting in questioned costs of $63,220. (A similar condition was noted in prior year finding #76.) No additional corrective action has been taken. L&I is awaiting determination from ED. This finding is now resolved and closed. None of the questioned costs are disallowed. The determination for Finding #77 (1992) applies to this finding.
FY 1995 - 55

 

DPW DPW did not adhere to contracting and procurement requirements, resulting in questioned costs of $400,966. (A similar condition was noted in prior year finding #78.) DPW strongly disagrees with the auditors' contention that contracting and procurement provisions apply and therefore no corrective action is planned. DPW has not yet been contacted with regard to this finding or previous findings. This finding is now resolved and closed. None of the questioned costs are disallowed. See determination for Finding #77 (1993).
FY 1995 - 56

 

L&I L&I did not adhere to contracting and procurement requirements, resulting in questioned costs of $18,849. (A similar condition was noted in prior year finding #79.) No additional corrective action has been taken. L&I is awaiting a determination from ED. This finding is now resolved and closed. None of the questioned costs are disallowed. The determination for Finding #77 (1992) applies to this finding.
FY 1996 - 32

 

DPW DPW did not adhere to contracting and procurement requirements resulting in an undetermined amount of questioned costs up to $3,608,890. (A similar condition was noted in prior year finding #55.) With the approval of the Secretary of DPW, the Office of Social Programs, Bureau of Blindness and Visual Services, will prepare a written request for a waiver of the Commonwealth's contracting policy, Contracting for Services Manual (M215.1) and Contract Management (MD215.6) relative to the purchase of services on behalf of consumers in the VR Program. The completion of this waiver and a final report is expected no later than July 1, 1997. This finding is now resolved and closed. None of the questioned costs are disallowed. See determination for Finding #77 (1993).
FY 1996 - 33

 

L&I L&I did not adhere to contracting and procurement requirements resulting in an undetermined amount of questioned costs up to $12,628. (A similar condition was noted in prior year finding #56.) The Department has been continually charged with this finding and our position remains unchanged. Year after year we are cited for noncompliance, year after year we explain the absurdity of this finding and explain the department's commitment to achieving compliance. The department has pursued the resolution of this issue in a sound and logical manner. We have proven that we have followed all applicable Management Directives to the letter of the law, specifically Management Directives 215.1 and 215.6, which provides for circumstances which require the need to explore exceptions to established regulations. In an effort to ensure compliance, legal options have been pursued resulting in a waiver, which was considered to be the appropriate method to deviate from but to be in compliance with established Commonwealth rules and regulations. The department cannot understand how following regulations results in an audit finding. The auditors' position appears to conflict philosophically with the language and position stated in those applicable Management Directives, the Commonwealth's established policy and procedures manual. It has been stated in both EDGAR, under CFR 80.36(a), and A-87 that OVR must follow the same contracting and procurement procedures for its Federal funds as it does for its State funds, in this case that would suggest compliance with both Management Directives 215.1 & 215.6. Since the State's regulatory authority has, in its judgement , seen fit to grant a waiver, that waiver would establish compliance. To dispute that would require challenging the credibility of the established rules and regulations. Although this finding has been formally addressed with the Federal agency, ED, no determination letter has been received. However, to confirm our position and to obtain a sense of the federal authority's position, the department has discussed this issue with the Financial Management Officer of the Rehabilitation Services Administration (RSA) Region III &V (Philadelphia & Atlanta). The department is also suggesting that the auditor contact this officer who has indicated she would be willing to discuss this matter with them in hopes of being able to help us both come to agreement with regard to this situation. To address the issue of debarred/suspended service providers, OVR is presently in the process of obtaining the List of Parties Excluded from Federal Procurement and Nonprocurement Programs. Once this list is received we will check each service provider against this List before we add them to our active file of service providers. We anticipate this process should be started in the next 60 to 90 days. This finding is now resolved and closed. None of the questioned costs are disallowed. The determination for Finding #77 (1992) applies to this finding.
Findings Related to OVAE
FY 1991 - 78 PDE - OB - LECS Financial Status Report (FSR) submitted to ED was not accurate and internal control structure over preparation and authorization of FSRs was not adequate. (A similar condition was noted in a previous single audit.) Additional documentation was submitted on November 8, 1993. No response has been received regarding the acceptability of the additional information. LECS is awaiting a final determination by ED. This finding is now resolved and closed. ED issued PDL on 9/30/93 asking PDE for: (1) revised FSR for grant period ending 9/30/93 (V048A80038); and (2) evidence of review to ensure State match was met. Similar findings were reported in fiscal years (FYs) 1992 (#67) and 1993 (#69). PDE disagrees that it should submit revised FSRs.

The LECS Comptroller's Office has adopted revised internal control procedures to accumulate, claim, and report all State administrative costs, whether paid from Federal or non-Federal sources. ED has accepted this corrective action, the implementation of which will be reviewed in subsequent audits.

FY 1991 - 84 PED - OB - LECS Internal control structure was not adequate to ensure the accuracy of State matching amounts. Additional documentation was submitted on November 9, 1993. No response has been received regarding the acceptability of the additional information. LECS is awaiting a final determination by ED. This finding is now resolved and closed. ED issued a PDL on 9/30/93 asking PDE to submit implemented procedures ensuring accuracy of data reported for State and local matching requirements used in completing the FSR. Similar findings were reported in FYs 1992 (#71), 1993 (#71) and 1996 (#31).

The LECS Comptroller's Office has adopted revised internal control procedures to accumulate, claim, and report all State administrative costs, whether paid from Federal or non-Federal sources. ED has accepted this corrective action, the implementation of which will be reviewed in subsequent audits.

FY 1992 - 67 PED - OB - LECS Costs of $380,838 questioned due to improper procedures for claiming and reporting costs. (A similar condition was noted in the previous single audit.) Additional documentation was submitted on April 28, 1995. No response has yet been received. LECS is awaiting a management decision letter from ED. This finding is now resolved and closed. Similar findings were reported in FYs 1991 (#78) and 1993 (#69).

The LECS Comptroller's Office has adopted revised internal control procedures to accumulate, claim, and report all State administrative costs, whether paid from Federal or non-Federal sources. ED has accepted this corrective action, the implementation of which will be reviewed in subsequent audits, and seeks no recovery of funds.

FY 1992 - 71 PDE - OB - LECS Questioned cost of $59,215 due to weakness in internal control to ensure State match is met. No additional corrective action has been taken. LECS is awaiting a management decision letter from ED. This finding is now resolved and closed. Similar findings were reported in FYs 1991 (#84), 1993 (#71) and 1996 (#31).

The LECS Comptroller's Office has adopted revised internal control procedures to accumulate, claim, and report all State administrative costs, whether paid from Federal or non-Federal sources. ED has accepted this corrective action, the implementation of which will be reviewed in subsequent audits, and seeks no recovery of funds.

FY 1993-69 PDE - OB - LECS Inaccurate FSRs submitted due to improper procedures for reporting costs. (A similar condition was noted in a previous single audit.) In finding recurring from FY 1992, procedures LECS used were inadequate to ensure reporting of data to show that 50% match requirement had been met. (Corrective action plan in previous fiscal year findings.) PDE will review the auditors' work papers to determine if any adjustments are required on the final FSRs submitted for Vocational Education. The LECS Comptroller Office will complete the final FSR for this Federal program. PDE awaits a PDL from ED. This finding is now resolved and closed. Similar findings were reported in FYs 1991 (#78) and 1992 (#67).

The LECS Comptroller's Office has adopted revised internal control procedures to accumulate, claim, and report all State administrative costs, whether paid from Federal or non-Federal sources. ED has accepted this corrective action, the implementation of which will be reviewed in subsequent audits.

FY 1993-71 PDE - OB -LECS Internal control weakness exists within LECS Comptroller Office for ensuring State match is met. (A similar condition was noted in a previous single audit.) (The auditors were unable to identify all matching indirect costs because these amounts had not been posted to the comptroller's accounting records. Therefore, cost related to Vocational Education were not included in matching costs.) No additional corrective action has been taken. LECS is awaiting a management decision letter from ED. This finding is now resolved and closed. Similar findings were reported in FYs 1991 (#84), 1992 (#71) and 1996 (#31).

The LECS Comptroller's Office has adopted revised internal control procedures to accumulate, claim, and report all State administrative costs, whether paid from Federal or non-Federal sources. ED has accepted this corrective action, the implementation of which will be reviewed in subsequent audits.

FY 1996-31 PDE - OB - LECS An internal control weakness exists for PDE's system for ensuring state match is met. (A similar condition was noted in a previous single audit.) PDE believes that no steps can be taken until a ruling by ED has determined that PDE has incorrectly applied the regulations governing TA and matching requirements. Staff in the LECS Comptroller Office reviews Vocational Education administrative costs to determine if state matching requirements are met. This review is done on a quarterly basis. A copy of the review is sent to PDE for comment. PDE continues to disagree with the finding and subsequent recommendation in this finding pertaining to proper matching from nonfederal sources for Vocational Education state administrative costs relating to TA areas. The finding was referred to ED several years ago. It is necessary for ED to rule on that original finding to resolve this one. Until then, the response of PDE, based on regulation 403.181 and 403.180(b)(4), remains unchanged as stated in that first finding. The LECS Comptroller states that the state share of indirect costs in the amount of $188,529 used to meet the Vocational Education administrative matching requirement for grant number V048A40038 were posted to the Commonwealth's ICS Accounting System and to the Grant Accounting Subsystem prior to submission of the final Financial Status Report in December 1996. This amount was used to meet the administrative cost match requirement only and not for any match for TA. This finding is now resolved and closed. Similar findings on internal controls for ensuring the matching requirement was met were reported in FY 1991(#84), FY 1992 (#71) and FY 1993 (#71).

The LECS Comptroller's Office has adopted revised internal control procedures to accumulate, claim, and report all State administrative costs, whether paid from Federal or non-Federal sources. ED has accepted this corrective action, the implementation of which will be reviewed in subsequent audits.

Abbreviations Used in Matrix

OSERS - Office of Special Education and Rehabilitative Services
RSA - Rehabilitation Services Administration
L&I - PA Department of Labor and Industry
OSEP - Office of Special Education Programs
PDE - PA Department of Education
OVAE - Office of Vocational and Adult Education

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