The US Department of Education (USDOE) found that financial management duties for Consolidated Grants for the American Samoa DOE have largely been delegated to the American Samoa Treasury.
USDOE said this is reflected in an AS Treasury Standard Operating Procedures that outlines their oversight of major aspects of the federal grant and identifies their key personnel with respect to grant management duties.
USDOE says, in its monitoring report of ASDOE’s management of the Consolidated Grant of Fiscal Year 2022, AS treasury often used local funds to fund purchases related to project activities and then reimburse those funds with federal monies.
“This process is administered with minimal involvement from ASDOE. However, as the grantee, ASDOE is responsible for management and use of funds and, therefore, should review and approve Consolidated Grant funds used before AS Treasury draws down funds,” says the report.
USDOE found that ASDOE and Treasury have previously treated Consolidated Grant funds as interchangeable with other federal funds. Specifically, the COVID–relief funds. “AS Treasury and ASDOE staff were unable to articulate the cause of these actions suggesting such transactions may be a common practice,” said USDOE.
As corrective action, ASDOE must provide documentation of the internal controls that ASDOE follows with respect to fiscal control and fund accounting procedures that assure the proper disbursement of and accounting of Consolidated Grant funds. The documentation should also include an SOP that clearly states that ASDOE is responsible for reviewing and approving the use of Consolidated Grant funds from appropriate funding source, prior to AS Treasury drawing down funds.
It must also provide evidence of weekly internal meetings and every-other-week external meetings conducted with AS Treasury to discuss grant financial management and drawdown procedures.
