REPORT DIGEST REGIONAL OFFICE OF EDUCATION #47: LEE, OGLE AND WHITESIDE COUNTIES FINANCIAL AUDIT (IN ACCORDANCE WITH THE UNIFORM GUIDANCE) FOR THE YEAR ENDED JUNE 30, 2021 Release Date: Aug. 21, 2024 FINDINGS THIS AUDIT: 3 CATEGORY: NEW -- REPEAT – TOTAL Category 1: 0 -- 1 -- 1 Category 2: 0 -- 1 -- 1 Category 3: 0 -- 1 -- 1 TOTAL: 0 -- 3 -- 3 FINDINGS LAST AUDIT: 4 State of Illinois, Office of the Auditor General FRANK J. MAUTINO, AUDITOR GENERAL To obtain a copy of the Report contact: Office of the Auditor General, 400 West Monroe, Suite 306, Springfield, IL 62704-9849 (217) 782-6046 or TTY (888) 261-2887 This Report Digest and Full Report are also available on the worldwide web at www.auditor.illinois.gov SYNOPSIS • (21-1) The Regional Office of Education #47 did not provide completed financial statements in an auditable form by the August 31 deadline. • (21-2) The Regional Office of Education #47 lacked written policies for federal grants. • (21-3) The Regional Office of Education #47 did not have adequate subrecipient monitoring documentation. FINDINGS, CONCLUSIONS, AND RECOMMENDATIONS DELAY OF AUDIT The Regional Office of Education #47 (ROE) did not provide completed financial statements in an auditable form by the August 31, 2021 deadline. Completed financial statements were received on December 8, 2021. The June 30, 2018 and June 30, 2019 audits were released on December 15, 2021 and October 19, 2022, respectively. Additionally, the June 30, 2020 audit was not released until August 30, 2023. The ROE is subject to 105 ILCS 5/2-3.17a which requires the Auditor General’s office to cause an audit to be made, as of June 30th of each year, of the financial statements of all accounts, funds, and other moneys in the care, custody, or control of the regional superintendent of schools of each educational service region in the State and of each educational service center established in the School Code. The audit is to be conducted in accordance with Generally Accepted Government Auditing Standards. The Regional Office of Education or Educational Service Center may utilize a cash basis, modified cash basis, or generally accepted accounting principles (GAAP) basis of accounting to prepare the financial statements for audit. In accordance with 105 ILCS 5/2-3.17a, the Auditor General has promulgated administrative rules and regulations to govern this process. Those rules, 74 Ill. Adm. Code 420.320 (c) (2), state that for audit purposes, each regional office of education and educational service center shall make available to the Auditor General or his designee all books and records deemed necessary to make and complete the required audits. The records shall be in auditable form by August 15 of the succeeding fiscal year. Financial reports are to be available no later than August 31 in order for the annual audit to be completed by an independent auditor selected by the Auditor General. In addition, prudent business practices and transparency require timely preparation and completion of financial statements. Regional Office management indicated they did not provide their books to their outside accountant in time to fully adjust and prepare their financial statements in an auditable form. (Finding 21-001, pages 14a – 14b) This finding was first reported in 2018. The auditors recommended the ROE should implement procedures to ensure compliance with 105 ILCS 5/2-3.17a and 74 Ill. Adm. Code 420.320 (c) (2). Regional Office management should establish policies and procedures which set forth closing schedules, deadline, and accountability for the timely generation of financial statements. These financial statements need to be presented to the Auditor General’s independent auditors for audit by the August 31 deadline. ROE Response: Management agrees with the finding. LACK OF WRITTEN POLICIES FOR FEDERAL GRANTS The Regional Office of Education #47 (ROE) as of April 2021, had developed, but not implemented written procedures concerning cash management, the determination of allowability of costs in accordance with Subpart E – Cost Principles of the Title 2 of the U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and the terms and conditions of the federal award. For the period of July 2020 through March 2021, the ROE utilized informal procedures in which each purchase made or cost allocated to the Individuals with Disabilities Education Act (IDEA) – Improvement Grant – Part D was reviewed for allowability by an individual with knowledge of the budget, allowable costs and activities, and the cash management requirements. The allowability determinations were based on the amounts included in the budgets for the IDEA – Improvement Grant – Part D approved by, and the grant periods set by, the Illinois State Board of Education (ISBE). The Uniform Guidance, contained in 2 CFR Part 200, became effective for all federal award programs administered by the ROE that were issued on or after December 26, 2014. Specifically, the Uniform Guidance (2 CFR 200.302(b)(7)) requires the ROE to have written procedures related to cash management and for determining the allowability of costs in accordance with Subpart E – Cost Principles of the Uniform Guidance and the terms and conditions of the federal award. Regional Office management indicated they developed the written procedures late into the fiscal year, and were unable to fully implement the Uniform Guidance during the full fiscal year. (Finding 21-002, pages 15a – 15b) This finding was first reported in 2017. The auditors recommended the ROE implement written procedures to comply with the requirements related to cash management for determining the allowability of costs in accordance with Subpart E – Cost Principles of the Uniform Guidance and the terms and conditions of the federal award. ROE Response: Effective April 2021, the Regional Office has developed written policies and procedures related to the Uniform Guidance. SUBRECIPIENT MONITORING The Regional Office of Education #47 (ROE) did not have effective internal controls over subrecipient monitoring. Furthermore, the ROE was not properly monitoring subrecipients in accordance with Title 2 of the U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) standards. During audit testing procedures it was determined that the ROE: a. Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. Number of Subrecipients: 2 of 2 b. Did not conduct subrecipient monitoring procedures. Number of Subrecipients: 2 of 2 c. Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single audit. Number of Subrecipients: 2 of 2 The Uniform Guidance requires the Regional Office to ensure any subrecipient monitoring using federal funds be consistent with the standards set forth in the Uniform Guidance at 2 CFR 200.332. Additionally, the Uniform Guidance section 200.303 Internal Controls states the following : “The non-Federal entity must: a. Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Regional Office management indicated the ROE experienced staff turnover and did not formally document policies and procedures that provide controls and structures to ensure all of its subrecipient monitoring accountabilities are conducted and complied with. (Finding 21-003, pages 15c – 15d) This finding was first reported in 2017. The auditors recommended the ROE establish and maintain effective internal control over federal awards to ensure subrecipients are properly monitored as required by 2 CFR 200.332. This includes: a. Evaluating the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward; b. Conducting subrecipient monitoring procedures; and c. Determining whether the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit. ROE Response: Management agrees with this finding. AUDITORS’ OPINION Our auditors state the Regional Office of Education #47’s financial statements as of June 30, 2021 are fairly presented in all material respects. This financial audit was conducted by the firm of Prado & Renteria Certified Public Accountants. JOE BUTCHER Division Director This report is transmitted in accordance with Section 3-14 of the Illinois State Auditing Act. FRANK J. MAUTINO Auditor General FJM:JMM