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CAROI

MATRIX OF CLOSED FINDINGS

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

November 7, 1997

Year/
Finding#
PA Auditee ED Principal
Office
Finding PA Comments
(Provided to ED on 7/09/97)
ED Status/Next Steps
Fiscal Year (FY) 1990          
FY 1990

80

Office of the Budget (OB) Office of Special Education and Rehabilitative Services (OSERS)/ Office of Special Education Programs (OSEP) The Comptroller's Office of the PA Department of Education (PDE) did not ensure the completeness of the subgrantee payment listing. Additional documentation was submitted on May 14, 1993. No response has been received regarding the acceptability of the additional information. The Labor, Education, and Community Services Comptroller Office (LECS) is awaiting a final determination by ED. Finding closed. ED accepted PDE's documentation. No further information required.
FY 1990

83

OB OSERS/OSEP PDE's Comptroller's Office did not adequately review subgrantee expenditure reports. Additional documentation was submitted on May 17, 1993. No response has been received regarding the acceptability of the additional information. LECS is awaiting a final determination by ED. Finding closed. ED accepted PDE's documentation. No further information required.
FY 1990

95

OB OSERS/OSEP PDE's Comptroller Office did not adequately review subgrantee expenditure reports. (A similar condition was noted in the previous single audit.) Additional documentation was submitted on May 12, 1993. No response has been received regarding the acceptability of the additional information. LECS is awaiting a final determination by ED. Finding closed. ED accepted PDE's documentation. No further information required.
FY 1990

96

PDE/OB/ LECS Office of Vocational and Adult Education (OVAE) PDE's Comptroller Office did not adequately review subgrantee expenditure reports. (A similar condition was noted in a previous single audit.) Additional documentation was submitted on May 14, 1993. No response has been received regarding the acceptability of the additional information. LECS is awaiting a final determination by ED. Finding closed. ED issued a program determination letter (PDL) on 3/31/93 asking PDE to document that: (1) $745,184 was timely obligated; and (2) new procedures were established to ensure that all subgrantees' obligations were timely. Similar findings reported in FYs 1991 (#79) and 1992 (#68). ED does not have a record of receiving the 5/14/93 corrective action submitted by PA. However, the auditors have not issued a similar finding since the FY 1992 audit, which preceded PA's corrective action. Therefore, ED is satisfied that PA's corrective action was properly implemented. No further action required.
FY 1990

102

OB Office of Elementary and Secondary Education (OESE) PDE's Comptroller's Office should obtain detailed subgrantee expenditure reports (Form PDE-2033). Additional documentation was submitted on May 12, 1993. No response has been received regarding the acceptability of the additional information. LECS is awaiting a final determination by ED. Finding closed. ED accepted May 12, 1993 documentation. No further information required.
FY 1991          
FY 1991

69

OB/LECS OSERS/OSEP LECS Comptroller Office did not adequately review subgrantee expenditure reports. (A similar condition was noted in the previous single audit report.) Additional documentation was submitted on 5/3/93. No response has been received regarding the acceptability of the additional information. LECS is awaiting a final determination by ED. Finding closed. ED accepted May 3, 1993 documentation. No further information required.
FY 1991

79

PDE/OB/ LECS OVAE LECS Comptroller Office did not adequately review subgrantee expenditure reports for 10 of 25 entities selected for testing. (A similar condition was noted in a previous single audit.) Additional documentation was submitted on November 17, 1993. No response has been received regarding the acceptability of the additional information. LECS is awaiting a final determination by ED. Finding closed. ED issued PDL on 9/30/93 asking PDE to document: (1) that $38,170 was timely obligated; and (2) new procedures established to ensure that all subgrantees' obligations were timely. Similar finding reported in FY 1990 (#96) and 1992 (#68). ED does not have a record of receiving the 11/17/93 corrective action submitted by PA. However, the auditors have not issued a similar finding since the FY 1992 audit, which preceded PA's corrective action. Therefore, ED is satisfied that PA's corrective action was properly implemented. No further action required.
FY 1991

87

OB/PHES/

L&I

Office of the Chief Financial Officer (OCFO) Public Health and Employment Services (PHES) Comptroller system of cash management does not minimize time lag between receipt and disbursement of Federal funds. No additional corrective action has been taken. Bureau of Financial Management (BFM) is awaiting further action from ED. Finding closed. Similar findings #62, 74, 81, and 82 reported in FY 1992, #75 in FY 1993, #65, 85, and 87 reported in FY 1994, #46 and 62 in FY 1995, and #27 and 37 in FY 1996. In 1995 ED officials visited PA to resolve this finding. Based on discussions with OB officials, including Commonwealth auditors, ED agreed to a 30-day cash advance on hand because PA does not have an electronic funds transfer system, and PA said it would improve cash monitoring. In January 1996, LECS' Comptroller Office began to suspend payments if projected cash available (at a subgrantee) was $1 more than the next scheduled monthly payment (i.e., one month cash on hand). PA's auditors also agreed to these procedures. The 1996 audit of PA found two projects where the subgrantee's cash exceeded 30-days' needs. ED accepts PA new procedures and the small amount of funds in question. No further action is required.
FY 1991

90

OB OESE PDE did not maintain a system for accumulating Elementary and Secondary Education Act (ESEA) Chapter 2 discretionary funds provided to subgrantees. No additional corrective action has been taken. LECS is awaiting a final determination by ED. Finding closed. No further information required.
FY 1992          
FY 1992

58

PDE OSERS/OSEP Subgrantees were not monitored in accordance with Federal regulations. (A similar condition was noted in the previous single audit.) The auditors' review of PDE's monitoring of ESEA-1-H program disclosed that PDE did not monitor program effectiveness of subgrantees at least once every two years as required by Federal regulations. Personnel in the Bureau of Special Education (BSE) have continued their efforts to obtain ED approval of the monitoring instrument. The new monitoring system began implementation in the fall of 1992. PDE is waiting for a PDL from ED in response to PDE's August 8, 1994 letter. Finding closed for purposes of the FY 1992 audit. OSEP will address this issue through its monitoring activities.
FY 1992

59

PDE OESE Accuracy of allocations to local educational agencies (LEAs) is questioned. (A similar condition was noted in the previous single audit.) Revised PDE-3048 and instructions were sent to local institutions on October 4, 1991 for caseload eligibility for funding for the 1992/93 school year. Written response was requested and received from ED regarding the age criteria for eligibility. Technical assistance (TA) provided to local institutions reflects correct interpretation of 34 CFR 200.23. PDE monitors are sent on-site to local institutions to review caseloads at routine intervals. Single auditors review sampling of caseloads annually. ED monitors Pennsylvania extensively annually. Although PDE considers this finding resolved based on ED's February 4, 1993 letter to PDE, which indicated resolution to finding 65 in the June 30, 1991 Single Audit report, PDE still awaits a final close-out letter from ED. Finding closed. ED accepted PDE's corrective action plan. No further action required.
FY 1992

60

OB OESE The LECS Comptroller Office did not review 11 of 25 subgrantee expenditure reports selected to test to ensure funds were obligated within the grant period, resulting in questioned costs of $419. Additional documentation was submitted on March 22, 1995. No response has been received regarding the acceptability of the additional information. LECS is awaiting a management decision letter from ED. Finding closed. ED has accepted March 22, 1995 documentation. No further action required.
FY 1992

61

OB OESE The LECS Comptroller Office did not adequately monitor LEAs' subgrantee expenditures for one entity selected for testing. (A similar condition was noted in the previous single audit.) Additional documentation was submitted on March 22, 1995. No response has been received regarding the acceptability of the additional information. LECS is awaiting a management decision letter from ED. Finding closed. ED has accepted March 22, 1995 documentation. No further action required.
FY 1992

62

OB OCFO Weaknesses in the system of monitoring subgrantee "cash on hand." (A similar condition was noted in the previous single audit.) No additional corrective action has been taken. LECS is awaiting a management decision letter from ED. Finding closed. See discussion for FY 1991 finding #87 above. No further action is required.
FY 1992

65

PDE OSERS/OSEP Inadequate documentation to support $198,983 in personnel costs. (A previous condition was noted in the previous single audit.) This finding not included in PA's list. Finding closed. On June 28, 1996, ED issued PDL allowing salary and benefits for Employee C. No further action required.
FY 1992

66

PDE OSERS/OSEP PDE did not ensure subgrantees under the Special Education - State Grants Program complied with non-supplanting requirements, resulting in $24,282,816 in questioned costs. PDE continues to believe that the citation (34 CFR 300.230) is inappropriate for the conclusions reached in the finding and, therefore, no corrective action is required. PDE reviews all project applications to assure compliance with Federal statute, including 34 CFR 300.230, and will continue to do so. PDE refutes the costs in question. In response to ED's June 28, 1996 request, PDE in an August 27, 1996 letter provided additional documentation to ED as requested. PDE is waiting for a response from ED. Finding closed. On 6/28/96, ED issued a PDL closing this finding. No further action required.
FY 1992

68

PDE/OB LECS OVAE LECS Comptroller Office did not adequately review subgrantee expenditure reports resulting in questioned costs of $28,136. (A similar condition was noted in a previous single audit.) Additional documentation was submitted April 28, 1995. No response has yet been received regarding the acceptability of the additional information. LECS is awaiting a management decision letter from ED. Finding closed. ED has received PDE's corrective action dated 4/28/95. Similar findings reported in FYs 1990 (#96) and 1991 (#79). The auditors have not issued a similar finding since this FY 1992 audit was issued. Therefore, ED is satisfied that PA's corrective action was properly implemented. No further action required.
FY 1992

69

PDE OVAE Procedures for monitoring of subrecipients need improvement. (A similar condition was noted in a previous single audit.) A process has been developed to ensure that actual signatures are obtained. The Performance Review's internal manual outlining procedures were to be revised and finalized by March 31, 1993. This manual will be used by PDE to monitor the performance reviewing and reporting process. PDE is waiting for a PDL from ED in response to PDE's August 8, 1994 letter. Finding closed. Similar finding reported in FY 1995 (#53). On 11/9/97, the ED and PA Cooperative Audit Resolution Oversight Initiative (CAROI) Project Teams discussed PDE's corrective action and current procedures and agreed that they provide sufficient internal control to ensure that the monitoring requirement is met. No further action required.
FY 1992

70

PDE OVAE Administrative costs of $2,570 are questioned. (A similar condition was noted in a previous single audit.) PDE will research Office of Management and Budget (OMB) Circular A-87 and make the necessary adjustments to appropriately allocate leave among the various State/Federal programs based upon the time sheets of employees involved. PDE is waiting for a PDL from ED in response to PDE's August 8, 1994 letter. Finding closed. On 9/30/93, ED issued a PDL for similar findings #80A and B reported in FY 1991 requesting PDE to: (1) document new procedures for charging salaries using time distribution records: and (2) refund $79,323. PDE's appeal of the PDL was resolved when OVAE accepted PDE's documentation. ED has received PDE's August 8, 1994 letter. Similar finding reported in FY 1993 (#72). On 11/4/97, the ED and PA CAROI Project Teams discussed PDE's corrective action and current procedures and agreed that procedures exist to ensure that salaries and leave are charged appropriately using time distribution records. No further action required.
FY 1992

72

PDE OVAE PDE supplanted State and local funds with Federal funds resulting in questioned costs of $16,668. (A similar condition was noted in a previous single audit.) Although PDE considers this finding resolved based on ED's September 30, 1993 letter to PDE regarding finding 85 in the June 30, 1991 Single Audit report, PDE still awaits a final close-out letter from ED. Finding closed. On 9/30/93, ED issued a PDL not sustaining similar finding (#85) reported in FY 1991. ED did not agree with auditors that supplanting had occurred or that State internal controls were inadequate. On 11/4/97, the ED and PA CAROI Project Teams discussed the PDL regarding the supplement-not-supplant requirement and how the auditors should test for compliance. No further action required.
FY 1992

73

PDE OVAE Costs of $349,913 are questioned because PDE did not match TA costs on dollar-for-dollar basis from non-Federal sources. Testing of payroll expenditures for State FY 1992 (7/1/91 to 6/30/92) disclosed that salaries and benefits of 8 employees tested that were charged to vocational education (Voc Ed) were claimed under the State leadership (SL) funding category. Costs claimed under SL are fully reimbursed by the Federal government without any nonfederal matching share required. However, PDE provided job descriptions for the 8 employees which indicated that 6 worked on TA and SL, 1 worked only on TA, and 1 worked on neither TA nor SL but worked on other Voc Ed-related activities. In addition, time allocation sheets provided indicated that the 8 employees' time worked on Voc Ed was related only to TA. Further, Bureau of Voc-Tech Ed (BVTE) personnel disclosed that time allocation sheets submitted throughout the State fiscal year for all 21 employees indicated that the time charged to Voc Ed was for TA and no time was charged to SL.

As of 6/24/92, revised time distribution sheets were completed and approved by the bureau's management staff. Effective 7/1/92, the BVTE and other bureaus funded through Voc Ed, began using the newly revised time sheets. Breakdown of columns included other categories under voc ed. Updated job descriptions and essential functions are on file in the BVTE. Effective 7/1/92, a computerized program was implemented in PDE for voc ed. Time sheets and computer input documentation will be submitted monthly to the Budget Office. PDE is waiting for a PDL from ED.

Finding closed. Similar finding reported in FYs 1993 (#70), 1995 (#52), 1996 (#31). On 11/4/97, the ED and PA CAROI Project Teams discussed the matching requirement under the Perkins Act and agreed that TA costs are not required to be matched when the costs are charged to SL funds, as opposed to State administration funds. No further action required.
FY 1992

74

OB OCFO LECS Comptroller system of cash management does not minimize the time lag between receipt and disbursement of Federal funds. (A similar condition was noted in the previous single audit.) No additional corrective action has been taken. BFM awaiting further action from ED. Finding closed. See discussion for FY 1991 finding #87 above. No further action is required.
FY 1992

75

PA Department of Labor and Industry (L&I) OSERS/Rehabilitation Services Administration (RSA) Inadequate controls over monitoring of fee rates paid. (A similar condition was noted in the previous single audit.) On August 29, 1996, L&I responded to an ED PDL explaining their position that corrective action has been taken and they believe no further corrective action is required. L&I is waiting for a response from ED. Finding closed. ED has accepted L&I's corrective action. No further action required.
FY 1992

76

L&I OSERS/RSA Lack of documentation in client case files resulted in $129 of questioned costs. No additional corrective action has been taken. L&I is waiting for a response from ED. Finding closed. ED has accepted that L&I could not locate the two client case files. No further action required.
FY 1992

79

PDE OESE System to ensure accuracy of grant awards distributed to LEAs needs improvement. (A similar condition was noted in the previous single audit.) PDE is developing a new computer edit program that hopefully will eliminate the auditors' concerns. Efforts will be made to document the internal reviews performed on this data. PDE is waiting for a PDL from ED. Finding closed. ED accepts PDE's corrective action. No further action required.
FY 1992

80

OB OESE PDE and LECS Comptroller Office did not maintain a system for accumulating ESEA Chapter 2 discretionary funds provided to subgrantees. (A similar condition was noted in the previous single audit.) No additional corrective action has been taken. LECS is awaiting a management decision letter from ED. Finding closed. ED has accepted PDE's corrective action described in the FY 1992 audit report. No further action required.
FY 1992

81

PDE OCFO Procedures for the timely expenditure of Federal funds drawn down need improvement. Staff in PDE's Bureau of Community and Student Services (BCSS) contacted staff in the Comptroller's Office of the Department of Public Welfare (DPW) to determine if there are excess funds remaining under grant #S186A10098. PDE has been informed that there are no excess funds. Memoranda of understanding (MOUs) which transferred the funds ran for various time periods, which may differ from the State fiscal year. A review of the MOUs for State FY (SFY) 91/92 shows that at the termination of the MOU, DPW only received funds for actual expenditures. Staff in PDE's BCSS will work with the Governor's Drug Policy Council (GDPC) [which is now known as the Governor's Policy Office] to develop a system of requiring fiscal reports from DPW and other agencies which receive funds through MOUs. Also, effective with SFY 1995/96, PDE assumed responsibility of activities formerly associated with GDPC. An ED letter of June 28, 1996 to PDE indicates that this finding has been referred to the Program Financing Branch, Financial Operations Division, Financial Management, in ED for further review and action. Finding closed. See discussion for FY 1991 finding #87 above. No further action is required.
FY 1992

82

PDE OCFO Cash management system is not adequate with respect to PDE's discretionary funding under Drug-Free Schools and Communities (DFSC) Program. Effective with SFY 93/94, subgrantees will be required to submit quarterly expenditure reports for the Drug-Free Schools Program. PDE will no longer make advance payments. Payment of actual expenditures for the previous quarter will be made after review of the expenditure reports. Reimbursement of expenditures after the fact will assure that the subgrantee does not have excess Federal cash on hand. Expenditure reports will be reviewed by PDE staff responsible for the preparation and processing of subgrants. An ED letter of June 28, 1996 to PDE indicates that this finding has been referred to the Program Financing Branch, Financial Operations Division, Financial Management, ED for further review and action. Finding closed. See discussion for FY 1991 finding #87 above. No further action is required.
FY 1992

83

OB OESE LECS Comptroller Office did not adequately review subgrantee expenditure reports resulting in questioned costs of $70,133. No additional corrective action has been taken. LECS awaiting a management decision letter from ED. Finding closed. ED has accepted PA's corrective action described in the FY 1992 audit report. No further action required.
FY 1992

84

PDE OESE Internal control structure was not adequate to ensure enrollment data used in allocations of grant awards to LEAs was accurate. The auditors' review of the formula allocation process for the distribution of the 1991-92 grant award to LEAs disclosed that PDE did allocate grant awards to LEAs based on enrollment data supplied from LEAs. However, the Public School Enrollment Reports (PDE-4035) were not signed by an authorized official of the LEA indicating LEA representation that the report was accurate. In addition, there was no evidence of review of the PDE-4035 reports by PDE personnel to ensure the reports were accurate. Effective with the 1993-94 fiscal year, the Division of Data Services will institute procedures for the review and approval of all Public (PDE-4035) and Non-Public (PDE-4036) enrollment reports received from the LEAs for the DFSC Program. The Division of Data Services will require all enrollment reports to be signed by an authorized LEA official, and ensure review by the signing and dating of the reports. PDE indicated in its August 8, 1994 response to ED that the auditors recommendation had been implemented. PDE is waiting for a PDL from ED. Finding closed. ED has accepted PDE's corrective action. No further action required.
FY 1992

87

OB OESE Neither the LECS Comptroller Office nor GDPC maintained an adequate system of accounting for DFSC funds distributed to subgrantees, resulting in questioned costs of $59,072. The GDPC has implemented a system to track discretionary funds. The data in the system is reconciled to the Integrated Central System (ICS) Accounting System on a recurring basis. LECS is awaiting a management decision letter from ED. Finding closed. ED accepted PA's corrective action. No further action required.
FY 1992

88

OB/LECS OESE Costs of $92,827 are questioned since expenditures were not obligated by PDE within the required 27-month period of availability. No additional corrective action has been taken. LECS is awaiting a management decision letter form ED. Finding closed. The statute of limitations precludes ED from pursuing recovery of these funds. No further action required.
1993          
FY 1993

62

PDE OSERS/OSEP Subgrantees were not monitored in accordance with Federal regulations. (A similar condition was noted in the previous single audit.) PDE has made repeated efforts to gain approval from ED and has also taken steps to implement a monitoring process. A description of PDE's monitoring procedures can be found in its State Plan under Appendix N which is available for review in BSE. PDE awaits a PDL from ED. Finding closed for purposes of the FY 1993 audit. OSEP will address this issue through its monitoring activities.
FY 1993

64

OB/PDE OSERS/OSEP Weaknesses in the system of monitoring subgrantee "cash on hand." (A similar condition was noted in the previous single audit.) Additional documentation was submitted July 6, 1995. No response has been received regarding the acceptability of the additional information. LECS is awaiting a management decision letter from ED. Finding closed. ED has accepted the July 6, 1995 documentation. No further information needed.
FY 1993

66

PDE OSERS/OSEP Inadequate documentation to support $63,874 in personnel costs. (A similar condition was noted in the previous single audit.) PDE maintains that the duties performed are 100 percent allowable under IDEA-B and the salary and benefits should be charged accordingly. PDE awaits a PDL from ED. Finding closed. See discussion for similar finding #65 reported in FY 1992. Similar finding reported in FY 1994 (#67). No further action required.
FY 1993

70

PDE OVAE Costs of $48,303 are questioned because PDE did not match TA dollar-for-dollar from nonfederal sources. (A similar condition was noted in a previous single audit.) PDE takes the position that no corrective action is required. The regulations for Voc Ed clearly allow TA in accordance with staffing practices and the payroll expenditures in question. This finding needs to be reviewed and determined by ED. No monitoring is planned until a plan of corrective action is clearly required. PDE awaits a PDL from ED in response to PDE's September 8, 1995 letter to ED.

Also, payroll adjustments are currently being made on a timely basis. Procedures exist for the timely completion of all steps including supervisors' review. PDE will formulate, in writing, the procedure followed to ensure accuracy and timely posting of payroll adjustments. The written procedures will be reviewed by PDE, Bureau of Vocational-Technical Education, Budget Office, Bureau of Commonwealth Payroll Operations, and LECS Comptroller Office. PDE awaits a PDL from ED in response to PDE's September 8, 1995 letter to ED.

Finding closed. See discussion for similar FY 1992 finding #73.
FY 1993

72

PDE OVAE Administrative costs of $2,473 are questioned. (A similar condition was noted in a previous single audit.)

No written procedures in place for supervisory review of payroll expenditure adjustments or correction vouchers to ensure they are accurate and timely.

PDE believes that 34 CFR 403.181 has to be interpreted in conjunction with 403.60 and 403.187 when TA is addressed as it applies to State leadership (SL). The relationship between or prioritization of those two alternative references to TA in the Act itself (34 CFR 403.181) [sic] and in the regulations (34 CFR 403.60 and 403.187) is not explained in the regulations and is therefore subject to each States' interpretation. ED/OVAE will have to rule in the matter of interpretation. PDE believes it has been correctly applied to the regulations relating to SL and TA. No monitoring is possible until a determination has been made that requires corrective action.

Also, payroll adjustments are currently being made on a timely basis. Procedures exist for the timely completion of all steps, including supervisors' review. PDE will formulate, in writing, the procedure followed to ensure accuracy and timely posting of payroll adjustments. The written procedures will be reviewed by PDE, Bureau of Vocational-Technical Education, Budget Office, Bureau of Commonwealth Payroll Operations, and LECS Comptroller Office. PDE awaits a PDL from ED in response to PDE's September 8, 1995 letter to ED.

Finding closed. See discussion for similar FY 1992 finding #70.
FY 1993

73

L&I OSERS/RSA Inaccurate Federal report was submitted to ED. In correspondence with ED, L&I explained corrective action with plans to establish procedures related to the preparation and review of the RSA-2 Report. These procedures will indicate who is responsible for completing the various portions of the report. L&I will attempt to ensure that these figures reconcile with the agency comptroller figures whenever possible and, when not possible, variances will be explained. L&I is waiting for a response from ED. Finding closed. ED accepted L&I's corrective action. No further action required.
FY 1993

74

L&I OSERS/RSA Monitoring of subgrantees was not adequate. Office of Vocational Rehabilitation (OVR) has resumed the use of the standardized grant monitoring instrument, which will incorporate language for compliance with debarment/suspension regulations. With regard to maintaining in excess of three days' cash, L&I has requested clarification from the U.S. Department of Labor (DOL) and RSA to confirm whether or not current subgrantee payment procedures are in compliance. L&I feels monitoring procedures are consistent with those cited in Part [sic] [34 CFR] 80.21(8) in ED's General Administrative Regulations. L&I is waiting for a response from ED. Finding closed. ED accepted L&I's corrective action. No further action required.
FY 1993

75

OB OCFO Excess "cash on hand" at year end. No additional corrective action has been taken. BFM is awaiting further action from ED. Finding closed. See discussion for FY 1991 finding #87 above. No further action is required.
FY 1993

78

L&I OSERS/RSA L&I did not comply with record retention requirements in procuring Federal fund. 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 realizes that unsuccessful applicants' documentation should be retained in the same regard as successful applicants' documentation and L&I has initiated action to insure compliance with Federal guidelines with respect to record retention. L&I is awaiting a response from ED. Finding closed. ED accepted L&I's corrective action. No further action required.
FY 1993

79

L&I OSERS/RSA Inadequate controls over monitoring of fee rates paid and Federal reporting. (A similar condition was noted in the previous single audit.) L&I believes computer system controls are adequate and designed according to established systems procedures. However, systems design can always be improved, and L&I will review systems for improvement as needed. L&I is awaiting a response from ED. Finding closed. RSA accepted PA's response described in FY 1993 audit report. No further action required.
FY 1993

81

OB/ LECS/

PDE

OESE PDE and LECS Comptroller Office did not maintain a system for accumulating ESEA Chapter 2 discretionary funds provided to subgrantees. (A similar condition was noted in the previous single audit.) No additional corrective action has been taken. LECS is awaiting a management decision letter from ED. Finding closed. ED accepted PDE's corrective action described in FY 1993 audit report. No further action required.
FY 1993

82

PDE OESE Internal control structure was not adequate to ensure enrollment data used in allocations of grant awards to LEAs was accurate. (A similar condition was noted in the previous single audit.) The enrollment data is run through several computer edits to ensure accuracy. Copies of these edits will be maintained for future reference. All report forms are annotated with the reviewer's initials and include any comments regarding verification or reasons for adjustments to originally submitted data, LEA official contacted, and date. The Division of Data Services has ensured that an LEA certification procedure, which has been instituted, addresses the problem of no signature. PDE awaits a PDL from ED. Finding closed. ED has accepted PDE's corrective action. No further action required.
FY 1993

85

PDE OESE Administrative expenditures exceeded 2.5% limit, resulting in questioned costs of $20,569. GDPC no longer exists as a separate agency. Program responsibilities have been assigned to and reorganized within PDE. PDE awaits a final determination from ED. Finding closed. OESE accepted GDPC's corrective action described in the FY 1993 audit report. No further action required.
FY 1993

86

Department of Health (DOH) OESE DOH did not comply with 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 $968,302. (A similar condition was noted in the previous single audit.) This finding was repeated in the June 30, 1995 Single Audit as finding 63. Please see comments included in that status. Finding closed. On 5/20/96, ED issued PDL requiring correction of process of monitoring subgrantee expenditures. ED accepted corrective action described in letter from PA dated 7/17/96. No further corrective action required.
1994          
FY 1994

30

OB OESE LECS Comptroller Office procedures for preparation of the schedule of Federal financial assistance (SFFA) need improvement. Review and reconciliation procedures were strengthened as of June 30, 1995 to include an additional review of SFFA work papers and verification of CFDA numbers. Finding closed. By letter dated August 29, 1996, ED/OESE gave PDE an extension to liquidate obligations for 1992-1993 and 1993-1994. PDE responded on October 23, 1996. No further action required.
FY 1994

64

PDE OSERS/OSEP LEAs were not monitored in accordance with Federal regulations. (A similar condition was noted in prior year finding #62.) PDE will continue to respond to all of OSEP's requests for information, including changes, modifications, deletions and additions to the monitoring system within all time lines imposed by OSEP or, where time lines are not imposed, as soon as possible. These actions will be taken until OSEP renders a decision of approval of the monitoring system.

In lieu of OSEP failing to respond or failing to respond on a timely basis such that a delay or suspensions of monitoring might occur, the BSE will notify OSEP. PDE will maintain the current monitoring system, and where improvements can be made to the system, such will be done with prior notification of OSEP rendered at least two weeks prior to implementation.

OSEP was scheduled to return to PDE the week of November 13, 1995 to continue monitoring. If OSEP remains silent, PDE will move forward in preparation to continue monitoring the 1995-96 school year. PDE awaits a PDL from ED.

Finding closed for purposes of the FY 1994 audit. OSEP will address this issue through its monitoring activities.
FY 1994

65

OB OCFO Weaknesses in the system of monitoring subgrantee "cash on hand." (A similar condition was noted in prior year finding #64.) A letter from ED dated September 25, 1995 states that since PA's system is to pay subrecipients by check, 30 days' "cash on hand" at the subrecipient level is reasonable. LECS is awaiting final closure from ED. Finding closed. See discussion for FY 1991 finding #87 above. No further action is required.
FY 1994

66

PDE OESE Lack of procedures to ensure obligations liquidated on a timely basis resulted in $251,503 of questioned costs. PA did not list this finding. Finding closed. ED has accepted documentation submitted by PDE. No further action required.
FY 1994

67

PDE OSERS/OSEP Inadequate documentation to support $64,599 in personnel costs. (A similar condition was noted in prior year finding #66.) PDE continues to believe that the salary and fringe benefits for the questioned employee should not have been disallowed in that PDE has acted in accordance with 34 CFR 300.600. A similar condition has existed since 1986, which is further indication of PDE's continuing position regarding this matter. It is important to note that single audit finding 73 from SFY 1991 (July 1, 1990 to June 30, 1991), to which the auditors have referred, has been resolved by ED, and ED has withdrawn its request for recovery of funds.

Although the employee's role in the administration of the Chapter 1- Handicapped Program is minimal and solely to ensure compliance with the requirements of 34 CFR 300, management will immediately begin to monitor the situation to ensure continued compliance with Federal requirements. PDE awaits a PDL from ED.

Finding closed. See discussion for similar finding #65 reported in FY 1992. Similar finding reported in FY 1993 (#66). No further action required.
FY 1994

68

PDE OSERS/OSEP Administrative expenditures of $1,499 were charged outside of the applicable grant period. In September 1994 an adjustment voucher (CV21375) was entered on the ICS system to correct program measure 45511 for all the charges. This action eliminates the audit exception. The BSE's administrative officer has issued a directive dated January 20, 1995 to all bureau staff to ensure their understanding of the audit finding and the procedures to be followed, thereby, precluding any future occurrence. The administrative officer will review all expenses and account codes used on all documents to ensure the proper codes are being used for the proper fiscal year. PDE awaits a PDL from ED. Finding closed. OSERS/OSEP has accepted corrective action. No further corrective action required.
FY 1994

69

PDE OSERS/OSEP Subgrantee child count report was not certified. (A similar condition was noted in prior year finding #67.) PDE believes that it has taken all of the appropriate steps necessary to ensure that the weakness found in the prior year will not recur. This belief is substantiated by the auditors' finding which states in part "However, our testing of the 1993-94 pass through grant award allocation . . . for all 15 of the 29 Intermediate Units (IUS) tested, properly certified . . . reports were on file. PDE's new allocation procedures appear to be designed adequately and are functioning as designed. Therefore, the internal control weakness . . . appears to have been corrected." PDE reviews all Child Care Reports to ensure that they are properly certified and will continue to do so. PDE awaits a PDL from ED. Finding closed. ED has accepted that PDE is unable to obtain a certified December 1, 1991 child count report from Intermediate Unit (IU) #20. In addition, ED has accepted PDE's corrective action described in the FY 1994 audit report. No further action is required.
FY 1994

70

PDE OSERS/OSEP PDE did not distribute 75% of grant #H027A30093 to LEAs in accordance with program regulations. Beginning with the 1995-96 program year, the reviewer of the LEA allocation schedule will recalculate 75 percent of the total grant award and compare it to the amount actually allocated. The calculations will be reviewed prior to the distribution of funds. PDE awaits a PDL from ED. Finding closed. ED has accepted PDE's corrective action described in the FY 1994 audit report. No further action required.
FY 1994

74

PDE OVAE The 1993-94 PA Council on Voc Ed (PACVE) did not meet membership requirements. PACVE has advised the Governor that he should appoint a member, representatives of business, industry, trade organizations, or agriculture, to serve on the State Job Training Coordinating Council. On May 6, 1996 the Governor made the required appointment. In response to ED's March 4, 1997 letter, PDE will inform ED of this appointment. Finding closed. Pursuant to recent changes made to the Perkins Act, the State is not required to maintain a State Council on Voc Ed with particular membership. Similar finding #51 reported in FY 1995 audit report. No further action required.
FY 1994

75

PDE OVAE An internal control weakness exists for PDE's system for ensuring State match is met resulting in questioned costs of $4,235. (Similar conditions were noted in prior year findings #70 and #71.) No specific steps of corrective action will be taken until ED has made a determination of this finding. PDE has cited regulations that allow TA costs for Single Parent Homemaker, Criminal Offenders and Sex Equity and which separates them from the requirement of 34 CFR Section 403.180 (b)(4). Monitoring would occur only if ED sustains this finding. In response to ED's March 4, 1997 request for additional information, PDE will inform ED that CFR 403.187 is the applicable regulation and that the State plan which included line items for TA were approved by ED. Finding closed. See discussion for similar FY 1992 finding #73. Similar findings reported in FYs 1993 (#70), 1995 (#52) and 1996 (#31).
FY 1994

76

L&I OSERS/RSA L&I did not comply with record retention requirements in procuring Federal funds. (A similar condition was noted in prior year finding #78.) No additional corrective action has been taken. L&I is awaiting determination from ED. Finding closed. ED has accepted L&I's corrective action described in FY 1994 audit report. No further action is required.
FY 1994

77

L&I OSERS/RSA Monitoring of subgrantee cash management systems and L&I subgrantee payment system needs improvement. (A similar condition was noted in prior year finding #74.) No additional corrective action has been taken. L&I is awaiting determination from ED. Finding closed. See finding #74 for FY 1993 above. No further action required.
FY 1994

80

OB OCFO Vocational Rehabilitation - Basic State Grants (VR) cash management system needs improvement to comply with Cash Management Improvement Act (CMIA). An additional interest calculation has been completed and submitted to BFM November 15, 1996. LECS is awaiting a management decision letter from ED. Finding is closed for purposes of closing audit findings for which ED is responsible. However, this audit finding remains open and unresolved and has been referred to the U.S. Department of Treasury for resolution.
FY 1994

82

PDE OESE Internal control structure was not adequate to ensure enrollment data used in allocation of grant awards to LEAs was accurate. (A similar condition was noted in prior year finding #82.) The Division of Data Services in Bureau of Information Systems (BIS) is responsible for the collection of enrollment data used in the distribution of grant awards for the Drug-Free Schools program. Corrective action was taken to require LEA officials to sign their forms, PDE-4035 Public School Enrollment Report or PDE-4036 Private and Nonpublic School Enrollment Report, beginning with enrollment year 1993/94. Allocations payable for SFY 1994 (July 1, 1993 to June 30, 1994) were generated using 1992/93 enrollments. This addresses the issue raised and shows action taken by BIS to alleviate future occurrences. Identical steps and a timetable have been instituted for Federal, State and Local Partnerships for Educational Improvement. Survey sponsors will ensure all forms are signed by LEA chief administrators. PDE awaits a PDL from ED in response to their October 23, 1996 letter to ED. Finding closed. ED has accepted PDE's corrective action. No further action required.
FY 1994

83

PDE OESE PDE monitoring of ESEA Chapter 2 discretionary fund subgrants needs improvement. (A similar condition was noted in prior year finding #81.) The acting Chapter 2 Manager in the Chapter 2 program office will have a detailed listing of subgrantees which have received discretionary money. This list will also be maintained by the administrative assistant in the Chapter 2 program office. The list was in place by March 31, 1995. Fiscal officers and/or Federal programs' regional coordinators will review financial records and will review programs as part of their on-site visits. Projects were reviewed by June 30, 1995. PDE awaits a PDL from ED in response to their October 23, 1996 letter to ED. Finding closed. ED has accepted PDE's corrective action. No further action required.
FY 1994

84

OB OESE

OSERS

Public Health and Human Services (PHHS) Comptroller Office procedures for preparation of the SFFA need improvement. No additional corrective action has been taken. PHHS is awaiting further communication from ED. Finding closed. ED (OESE/OSERS) has accepted PDE's adjustments to costs that had been erroneously assigned to ED programs. No further action required.
FY 1994

85

PDE OCFO Cash management system is not adequate with respect to Governor's discretionary funds under DFSC Act. (A similar condition was noted in FY 1994 finding #84.) Due to stricter requirements imposed by the LECS Comptroller Office regarding advance payments, payment procedures were again changed for grants administered by PDE's Bureau of Community and Student Services for SFY 1994/95. Presently, PDE is allowing a 10 percent working capital payment with subsequent monthly payments based on actual expenditures. Expenditure reports are submitted monthly. GDPC's revised payment procedures allow for up to a 25 percent advance payment upon approval with subsequent payments being made based on actual expenditures. This procedure was not implemented until July 1994, subsequent to this audit period. PDE's and GDPC's position continues to be that subgrantees are nonprofit agencies and must have working capital to begin the program. Also, PDE and GDPC receive expenditure reports from all subgrantees which are reviewed by the appropriate fiscal personnel. Also, effective with SFY 1995/96, PDE assumed responsibility of activities formerly associated with GDPC. Finding closed. See discussion for FY 1991 finding #87 above. No further action is required.
FY 1994

87

PDE OCFO Cash management system is not adequate with respect to PDE's discretionary funding under DFSC Act. (A similar condition was noted in prior year finding #83.) Payment terms were changed for the 1994-95 fiscal year. PDE allows a 10 percent working capital payment with subsequent monthly payments based on actual expenditures. Expenditure reports are submitted on a monthly basis and reviewed by the appropriate fiscal personnel. After the initial payment of 10 percent, remaining payments are made based on actual monthly expenditures reported. Finding closed. See discussion for FY 1991 finding #87 above. No further action is required.
1995          
FY 1995

6

PDE/OB/ LECS OCFO General computer controls over the PDE Data Center need to be strengthened or manual compensating controls need to be enhanced by PDE and the LECS Comptroller Office to ensure compliance with significant Federal requirements. (A similar condition was noted in prior year finding #10.) A management decision has been made regarding the USDA portion of this finding. In accordance with USDA's March 20, 1997 letter, no further action is required for USDA programs. PDE awaits a final determination from ED. Finding closed. ED has accepted corrective action described in FY 1995 audit report. No further action required.
FY 1995

42

PDE OSERS/OSEP LEAs were not monitored in accordance with Federal regulations, resulting in questioned costs of $3,087. (A similar condition was noted in prior year finding #64.) During the 1995/96 single audit review of PDE, the auditors have indicated resolution of this finding. However, PDE awaits a PDL from ED. Finding closed for purposes of the FY 1995 audit. OSEP will address this issue through its monitoring activities.
FY 1995

46

OB OCFO Weaknesses in the system of monitoring subgrantee "cash on hand." (A similar condition was noted in prior year finding #65.) No additional corrective action has been taken. LECS is awaiting a management decision letter from ED Finding closed. See discussion for FY 1991 finding #87 above. No further action is required.
FY 1995

47

PDE OESE PDE did not follow PA travel policy, resulting in questioned hotel charges of $3,578. During the 1995/96 single audit review of PDE, the auditors have indicated resolution of this finding. However, PDE awaits a PDL from ED in response to PDE's January 17, 1997 letter. Finding closed. PDE's January 17, 1997 letter provided adequate documentation to support the questioned hotel charges to the Title I program. No further information required.
FY 1995

49

PDE OSERS/OSEP PDE and LECS Comptroller Office did not have procedures to ensure that obligations were liquidated on a timely basis, resulting in questioned costs of $52,550. (A similar condition was noted in prior year finding #73.) During the 1995/96 single audit review of PDE, the auditors have indicated resolution of this finding. However, PDE awaits a PDL from ED. Finding closed. According to FY 1996 audit report, finding resolved. No further action required.
FY 1995

51

PDE OVAE The 1993-94 PACVE did not meet membership requirements. On May 6, 1996 the Governor made the required appointment. In response to ED's March 4, 1997 letter, PDE will inform ED of this appointment. Finding closed. See discussion for similar FY 1994 finding #74. No further action required.
FY 1995

52

PDE OVAE An internal control weakness exists for PDE's system for ensuring State match is met, resulting in questioned costs of $83,450. (A similar condition was noted in a prior year finding #75.) In response to ED's March 4, 1997 letter, PDE will reiterate their position and will wait for a final determination by ED. Fining closed. See discussion for similar FY 1992 finding #73.
FY 1995

53

PDE OVAE PDE on-site program monitoring of subrecipients needs improvement.

There were no formal monitoring procedures or standardized on-site evaluation reports developed for monitoring the projects listed in the audit report.

In response to ED's March 4, 1997 letter, PDE will inform ED of the corrective action in place since June of 1996. During the 1995/96 single audit review of PDE, the auditors have indicated resolution of this finding. However, PDE will wait for a final determination by ED. Finding closed. See discussion for similar FY 1992 finding #69.
FY 1995

57

OB OCFO VR cash management system needs improvement to comply with CMIA. (A similar condition was noted in prior year finding #80.) No additional corrective action has been taken. LECS is awaiting a management decision letter from ED. Finding is closed for purposes of closing audit findings for which ED is responsible. However, this audit finding remains open and unresolved and has been referred to the U.S. Department of Treasury for resolution.
FY 1995

59

L&I OSERS/RSA General computer controls at OVR need to be strengthened to ensure compliance with significant Federal requirements. No additional corrective action has been taken. L&I is awaiting a determination from ED. Finding closed. ED has accepted PA's corrective action described in FY 1995 audit report. No further action required.
FY 1995

60

PDE OESE PDE monitoring of Chapter 2 discretionary fund subgrants needs improvement. (A similar condition was noted in prior year finding #83.) PDE agrees with the auditors' conclusion. All Chapter 2 discretionary programs will be monitored annually. This information was provided in PDE's January 17, 1997 response to ED's December 17, 1996 letter. During the 1995/96 single audit review of PDE, the auditors have indicated resolution of this finding. However, PDE awaits a response from ED. Finding closed. ED has accepted Corrective action plan provided in response to FY 1994 audit report. No further action required.
FY 1995

62

PDE OCFO Cash management system is not adequate with respect to Governor's discretionary funds under DFSC Act. (A similar condition was noted in prior year finding #85.) Effective with SFY 1995/96, the former GDPC subgrantee payment schedule was revised to provide a ten percent working capital payment and subsequent payments quarterly, based on actual expenditures. Quarterly reviews of expenditure reports are performed before payment of quarterly invoices. PDE awaits a PDL from ED. Finding closed. See discussion for FY 1991 finding #87 above. No further action is required.
1996          
FY 1996

27

OB/LECS OCFO Weaknesses in the system of monitoring subgrantee cash on hand. (A similar condition was noted in prior year finding #46.) As explained in the finding, revised procedures, which appear adequate to the auditors, were implemented in January 1996. However, the auditors were required to question the cash on hand amounts of $3,034 and $1,120 in the Single Audit Report because these transactions occurred within the audit period (July 1, 1995 through June 30, 1996). As recommended by the auditors, LECS will continue to monitor subrecipient cash in accordance with the procedures implemented in January 1996. This will ensure that subgrantee cash on hand is limited to 30 days cash needs in accordance with guidance from ED. Finding closed. See discussion for FY 1991 finding #87 above. No further action is required.
FY 1996

35

L&I RSA General computer controls over OVR need to be strengthened to ensure compliance with significant Federal requirements. (A similar condition was noted in prior year finding #59.) The following addresses each point as listed in the Condition section of the findings:

Change Control Authority - In reviewing the documentation on file in the Change Control Section with the supervisor of that section, we found documentation to support all individuals from OVR with change control authority. We removed the one person's name from the list who had retired.

Inadequate Segregation of Duties - OVR has realigned staff and reorganized its supervisory/management staff so that change control authority is better defined. The approval sequence always required a supervisor/manager to sign the request before it goes to Change Control.

Management Level Approval of Project Request Forms - OVR requires supervisory/management sign-off approval at the beginning of a project, during testing and at the end of the project.

User Signature - The system that is in place in OVR MISD [Management Information System Division] required that the requester sign off when the project is tested and completed.

Disaster Recovery - In direct response to the Audit Finding from the previous year, OVR, in cooperation with the Department and Commonwealth processes, developed a disaster recovery plan and have actively participated in the process since April 1996. However, it should be noted that the department is comfortable with the current DP organizational structure. The department has determined it would be most efficient to decentralize bureau specific DP responsibilities, utilizing the Bureau of Management Information Systems [BMIS] to serve as a consultant for other bureau's specific issues, especially if P/C related. To centralize all BMIS functions could become counter productive, negatively affecting the prioritization of bureau specific assignments and inhibiting the production curve if the DP developer had to learn the integral workings of the bureau prior to each application development project.

Finding closed. ED has accepted L&I's corrective action described in FY 1996 audit report. See finding #59 in FY 1995 above. No further action required.
FY 1996

36

PDE OESE DOH did not comply with Safe and Drug-Free School - State Grants Program subgrantee monitoring requirements (A similar condition was noted in prior year finding #63.) The new Student Assistance Program Fiscal Report, Statistical Report, and Treatment Service Report are to be submitted quarterly by the Single County Authorities (SCAs) to DOH beginning in State Fiscal Year (SFY) 1996-1997. Also, a letter DOH forwarded to SCAs on June 5, 1996, addressed language to be incorporated into forthcoming amendments to the SCA contracts, relative to funds received under the Safe and Drug-Free Schools and Communities (SDFSC) Act of 1986, as amended. Finding closed. On 5/20/96, ED issued PDL requiring correction of process for monitoring subgrantee expenditures. ED has accepted PDE/DOH's corrective action provided on 7/17/96. No further action required.
FY 1996

37

PDE OCFO Cash management system is not adequate with respect to the Governor's discretionary funds under the DFSC Act. (A similar condition was noted in prior year finding #62.) The 10 percent advance payment was greater than 30 days cash needs for one out of 33 subgrantees. This subgrantee appeared to be maintaining excess cash since at the time of the audit PDE had not received expenditure reports. The fiscal officer in the BCSS has contacted the subgrantee and will obtain the required quarterly reports by December 31, 1996. As stated in the agency response, PCCD has assumed responsibility for these funds as of July 1, 1996. PCCD has been notified of the finding so they can ensure continued compliance with ED guidelines. Finding closed. See discussion for FY 1991 finding #87 above. No further action required.

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