Audit 289401

2022-003 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4672-10502-101, 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund I, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 9/30/2020 through 9/30/2022. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2022. Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund III, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 3/31/2022 through 9/30/2024. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2024. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Expenditures reported in the quarterly financial status reports did not agree to supporting documentation. Questioned Costs: None. Context: For the ESSER I quarterly financial status report for the quarter ending 9/30/2021, expenditures reported did not agree to supporting schedules. For the ESSER III quarterly financial status report for the quarter ending 6/30/2022, expenditures reported did not agree to supporting schedules. Cause: The City's procedures were not sufficient to ensure that reports were submitted accurately and proper documentation maintained. Effect: Reported expenditures were not properly supported. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that all reports are prepared and reviewed for accuracy and supporting documentation maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-003 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4672-10502-101, 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund I, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 9/30/2020 through 9/30/2022. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2022. Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund III, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 3/31/2022 through 9/30/2024. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2024. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Expenditures reported in the quarterly financial status reports did not agree to supporting documentation. Questioned Costs: None. Context: For the ESSER I quarterly financial status report for the quarter ending 9/30/2021, expenditures reported did not agree to supporting schedules. For the ESSER III quarterly financial status report for the quarter ending 6/30/2022, expenditures reported did not agree to supporting schedules. Cause: The City's procedures were not sufficient to ensure that reports were submitted accurately and proper documentation maintained. Effect: Reported expenditures were not properly supported. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that all reports are prepared and reviewed for accuracy and supporting documentation maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-003 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4672-10502-101, 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund I, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 9/30/2020 through 9/30/2022. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2022. Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund III, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 3/31/2022 through 9/30/2024. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2024. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Expenditures reported in the quarterly financial status reports did not agree to supporting documentation. Questioned Costs: None. Context: For the ESSER I quarterly financial status report for the quarter ending 9/30/2021, expenditures reported did not agree to supporting schedules. For the ESSER III quarterly financial status report for the quarter ending 6/30/2022, expenditures reported did not agree to supporting schedules. Cause: The City's procedures were not sufficient to ensure that reports were submitted accurately and proper documentation maintained. Effect: Reported expenditures were not properly supported. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that all reports are prepared and reviewed for accuracy and supporting documentation maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-003 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4672-10502-101, 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund I, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 9/30/2020 through 9/30/2022. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2022. Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund III, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 3/31/2022 through 9/30/2024. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2024. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Expenditures reported in the quarterly financial status reports did not agree to supporting documentation. Questioned Costs: None. Context: For the ESSER I quarterly financial status report for the quarter ending 9/30/2021, expenditures reported did not agree to supporting schedules. For the ESSER III quarterly financial status report for the quarter ending 6/30/2022, expenditures reported did not agree to supporting schedules. Cause: The City's procedures were not sufficient to ensure that reports were submitted accurately and proper documentation maintained. Effect: Reported expenditures were not properly supported. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that all reports are prepared and reviewed for accuracy and supporting documentation maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-004 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR § 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non- Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:  Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated,  Be incorporated into the official records of the non-Federal entity,  Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities,  Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy,  Comply with the established accounting policies and practices of the non-Federal entity,  Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: Payroll costs charged to the grant showed no evidence of approval. Questioned Costs: Below the reportable limit. Context: For 16 out of 60 payroll costs charged to the grant, time sheets or other documentation was not available to support evidence of approval for time worked. Cause: The City's procedures were not sufficient to ensure that payroll charges were appropriately approved and documented. Effect: Payroll costs charged to the grant may not be allowable. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that approval for payroll charges is documented and maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-004 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR § 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non- Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:  Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated,  Be incorporated into the official records of the non-Federal entity,  Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities,  Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy,  Comply with the established accounting policies and practices of the non-Federal entity,  Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: Payroll costs charged to the grant showed no evidence of approval. Questioned Costs: Below the reportable limit. Context: For 16 out of 60 payroll costs charged to the grant, time sheets or other documentation was not available to support evidence of approval for time worked. Cause: The City's procedures were not sufficient to ensure that payroll charges were appropriately approved and documented. Effect: Payroll costs charged to the grant may not be allowable. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that approval for payroll charges is documented and maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-004 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR § 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non- Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:  Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated,  Be incorporated into the official records of the non-Federal entity,  Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities,  Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy,  Comply with the established accounting policies and practices of the non-Federal entity,  Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: Payroll costs charged to the grant showed no evidence of approval. Questioned Costs: Below the reportable limit. Context: For 16 out of 60 payroll costs charged to the grant, time sheets or other documentation was not available to support evidence of approval for time worked. Cause: The City's procedures were not sufficient to ensure that payroll charges were appropriately approved and documented. Effect: Payroll costs charged to the grant may not be allowable. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that approval for payroll charges is documented and maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-004 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR § 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non- Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:  Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated,  Be incorporated into the official records of the non-Federal entity,  Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities,  Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy,  Comply with the established accounting policies and practices of the non-Federal entity,  Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: Payroll costs charged to the grant showed no evidence of approval. Questioned Costs: Below the reportable limit. Context: For 16 out of 60 payroll costs charged to the grant, time sheets or other documentation was not available to support evidence of approval for time worked. Cause: The City's procedures were not sufficient to ensure that payroll charges were appropriately approved and documented. Effect: Payroll costs charged to the grant may not be allowable. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that approval for payroll charges is documented and maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-003 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4672-10502-101, 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund I, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 9/30/2020 through 9/30/2022. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2022. Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund III, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 3/31/2022 through 9/30/2024. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2024. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Expenditures reported in the quarterly financial status reports did not agree to supporting documentation. Questioned Costs: None. Context: For the ESSER I quarterly financial status report for the quarter ending 9/30/2021, expenditures reported did not agree to supporting schedules. For the ESSER III quarterly financial status report for the quarter ending 6/30/2022, expenditures reported did not agree to supporting schedules. Cause: The City's procedures were not sufficient to ensure that reports were submitted accurately and proper documentation maintained. Effect: Reported expenditures were not properly supported. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that all reports are prepared and reviewed for accuracy and supporting documentation maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-003 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4672-10502-101, 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund I, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 9/30/2020 through 9/30/2022. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2022. Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund III, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 3/31/2022 through 9/30/2024. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2024. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Expenditures reported in the quarterly financial status reports did not agree to supporting documentation. Questioned Costs: None. Context: For the ESSER I quarterly financial status report for the quarter ending 9/30/2021, expenditures reported did not agree to supporting schedules. For the ESSER III quarterly financial status report for the quarter ending 6/30/2022, expenditures reported did not agree to supporting schedules. Cause: The City's procedures were not sufficient to ensure that reports were submitted accurately and proper documentation maintained. Effect: Reported expenditures were not properly supported. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that all reports are prepared and reviewed for accuracy and supporting documentation maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-003 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4672-10502-101, 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund I, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 9/30/2020 through 9/30/2022. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2022. Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund III, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 3/31/2022 through 9/30/2024. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2024. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Expenditures reported in the quarterly financial status reports did not agree to supporting documentation. Questioned Costs: None. Context: For the ESSER I quarterly financial status report for the quarter ending 9/30/2021, expenditures reported did not agree to supporting schedules. For the ESSER III quarterly financial status report for the quarter ending 6/30/2022, expenditures reported did not agree to supporting schedules. Cause: The City's procedures were not sufficient to ensure that reports were submitted accurately and proper documentation maintained. Effect: Reported expenditures were not properly supported. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that all reports are prepared and reviewed for accuracy and supporting documentation maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-003 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4672-10502-101, 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund I, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 9/30/2020 through 9/30/2022. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2022. Per the Rhode Island Department of Elementary and Secondary Education Grant Award Notification, specifically related to ESSER Fund III, Special Grant Award Conditions, "Interim financial status reports are due quarterly for the periods ending 3/31/2022 through 9/30/2024. Final financial status reports are due 15 days after the liquidation of all obligations, but no later than 11/15/2024. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Expenditures reported in the quarterly financial status reports did not agree to supporting documentation. Questioned Costs: None. Context: For the ESSER I quarterly financial status report for the quarter ending 9/30/2021, expenditures reported did not agree to supporting schedules. For the ESSER III quarterly financial status report for the quarter ending 6/30/2022, expenditures reported did not agree to supporting schedules. Cause: The City's procedures were not sufficient to ensure that reports were submitted accurately and proper documentation maintained. Effect: Reported expenditures were not properly supported. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that all reports are prepared and reviewed for accuracy and supporting documentation maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-004 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR § 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non- Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:  Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated,  Be incorporated into the official records of the non-Federal entity,  Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities,  Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy,  Comply with the established accounting policies and practices of the non-Federal entity,  Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: Payroll costs charged to the grant showed no evidence of approval. Questioned Costs: Below the reportable limit. Context: For 16 out of 60 payroll costs charged to the grant, time sheets or other documentation was not available to support evidence of approval for time worked. Cause: The City's procedures were not sufficient to ensure that payroll charges were appropriately approved and documented. Effect: Payroll costs charged to the grant may not be allowable. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that approval for payroll charges is documented and maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-004 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR § 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non- Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:  Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated,  Be incorporated into the official records of the non-Federal entity,  Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities,  Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy,  Comply with the established accounting policies and practices of the non-Federal entity,  Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: Payroll costs charged to the grant showed no evidence of approval. Questioned Costs: Below the reportable limit. Context: For 16 out of 60 payroll costs charged to the grant, time sheets or other documentation was not available to support evidence of approval for time worked. Cause: The City's procedures were not sufficient to ensure that payroll charges were appropriately approved and documented. Effect: Payroll costs charged to the grant may not be allowable. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that approval for payroll charges is documented and maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-004 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR § 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non- Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:  Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated,  Be incorporated into the official records of the non-Federal entity,  Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities,  Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy,  Comply with the established accounting policies and practices of the non-Federal entity,  Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: Payroll costs charged to the grant showed no evidence of approval. Questioned Costs: Below the reportable limit. Context: For 16 out of 60 payroll costs charged to the grant, time sheets or other documentation was not available to support evidence of approval for time worked. Cause: The City's procedures were not sufficient to ensure that payroll charges were appropriately approved and documented. Effect: Payroll costs charged to the grant may not be allowable. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that approval for payroll charges is documented and maintained. Views of Responsible Officials: There is no disagreement with the audit finding.

2022-004 Federal Agency: U.S. Department of Education Federal Programs: Education Stabilization Fund Assistance Listing Number: 84.425U Pass-Through Agency: Rhode Island Department of Elementary and Secondary Education Pass-Through Number: 4872-505020-201 Award Period: July 1, 2021 – June 30, 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per 2 CFR § 200.430 (a), costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non- Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. Per 2 CFR § 200.430 (i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must:  Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated,  Be incorporated into the official records of the non-Federal entity,  Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities,  Encompass both federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy,  Comply with the established accounting policies and practices of the non-Federal entity,  Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non- Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: 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. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." Condition: Payroll costs charged to the grant showed no evidence of approval. Questioned Costs: Below the reportable limit. Context: For 16 out of 60 payroll costs charged to the grant, time sheets or other documentation was not available to support evidence of approval for time worked. Cause: The City's procedures were not sufficient to ensure that payroll charges were appropriately approved and documented. Effect: Payroll costs charged to the grant may not be allowable. Recommendation: We recommend the City review and enhance internal controls and procedures to ensure that approval for payroll charges is documented and maintained. Views of Responsible Officials: There is no disagreement with the audit finding.