Audit 2958

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-003 The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, and restricted purpose requirements. Assistance Listing Number and Title: 32.009, COVID-19 – Emergency Connectivity Fund Program Federal Grantor Name: Federal Communications Commission Federal Award/Contract Number: N/A Pass-through Entity Name: N/A Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $850,897 Background The Emergency Connectivity Fund (ECF) Program provides funding to meet the needs of students and school staff who would otherwise lack access to connected devices and broadband connections sufficient to engage in remote learning. This is referred to as “unmet need.” In fiscal year 2022, the District spent $850,897 in ECF Program funds to purchase laptops and tablet computers for students and school staff. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Allowable activities and costs ECF Program recipients may only seek reimbursement for the eligible devices and services provided to students and staff with unmet need. Recipients are prohibited from seeking reimbursement for eligible equipment and services purchased for use solely at the school or held for future use (i.e., warehousing). Restricted purpose – unmet need When submitting applications to the Federal Communications Commission (FCC), schools only had to provide an estimate of their students’ unmet need. However, when requesting reimbursement, the District could only request program funds for eligible equipment and services provided to students and school staff with actual unmet need. Restricted purpose – per-location and per-user limitations The FCC imposed per-location and per-user limitations to maximize the use of limited funds. Under the program, eligible schools could only be reimbursed for one connected device and Wi-Fi hotspot per student or school employee with unmet need, and no more than one fixed broadband connection per location, such as a student’s or employee’s residence. Description of Condition Allowable activities and costs/restricted purpose – unmet need The District estimated unmet need for eligible equipment when it applied for ECF Program funds. However, our audit found the District’s internal controls were ineffective for ensuring it documented the determination of actual unmet need and only requested reimbursement for equipment provided to students with unmet need. Specifically, the District purchased laptops and tablet computers, based on its estimate of unmet need, and it requested reimbursement for these purchases totaling $850,897. However, the District did not maintain documentation showing it provided each laptop and tablet computer paid with program funds to a student with unmet need. Restricted purpose – per-location and per-user limitations Our audit found the District’s internal controls were ineffective for demonstrating it complied with the FCC’s per-location and per-user limitations. Specifically, the District did not maintain documentation showing it monitored or had a tracking process in place to ensure it only provided one device per user and location. We consider these deficiencies in internal controls to be material weaknesses that led to material noncompliance. This issue was not reported as a finding in the prior audit. Cause of Condition Allowable activities and costs/restricted purpose – unmet need Employees in the District’s finance department did not know the ECF Program was federally funded and, therefore, were unaware of all of its regulations. Further, District staff did not know about the requirement to request reimbursement only for actual unmet need and thought the estimate of unmet need provided during the application process was sufficient to comply with this requirement. Restricted purpose – per-location and per-user limitations Staff did not know the District could not provide more than one device per student and, therefore, did not establish a process to ensure each student would only receive one computer purchased with ECF Program funds. Effect of Condition and Questioned Costs Allowable activities and costs/restricted purpose – unmet need Because the District did not have documentation supporting whether it provided eligible equipment to students with actual unmet need, it cannot demonstrate compliance with the program’s requirements. Given the nature of the program and circumstances, it is likely that at least some of the equipment the District charged to the award addressed unmet needs. However, the lack of a documented assessment of students’ actual unmet need means that all costs are unsupported. Since we do not have a reasonable basis for estimating how much of the District’s expenditures are allowable, we are questioning all unsupported costs. Federal regulations require the State Auditor’s Office to report known questioned costs that are greater than $25,000 for each type of compliance requirement. We question costs when we find the District does not have adequate documentation to support expenditures. Restricted purpose – per-location and per-user limitations Because the District provided some students with more than one device and received reimbursement for them, it did not comply with the FCC’s requirement. As noted in the allowable activities and costs section above, we are questioning the costs for these devices. Recommendation We recommend the District work with the granting agency to determine audit resolution. We further recommend the District establish and follow internal controls to ensure staff fully understand the requirements for ECF awards. Specifically, the District should: • Request reimbursement only for eligible equipment and services provided to students with unmet need, and maintain documentation demonstrating compliance • Provide no more than one device per student in compliance with the ECF Program’s requirements District’s Response In reference to the recent audit conducted by the State Auditor's Office (SAO) concerning our District's Emergency Connectivity Fund (ECF) expenditures, we write to formally dispute the findings, particularly the ones related to questioned costs (QC). After a thorough review of the findings and the corresponding references to the Federal Communications Commission (FCC) guidelines, we assert that the audit conclusions are misaligned with the established federal provisions. The audit pointed out certain inadequacies in our internal control mechanisms, a condition we acknowledge had room for improvement, especially during the challenging pandemic period. Nevertheless, it is our contention that a lower level of reporting would have sufficed in addressing these issues since all the expenditures were justified, and devices were distributed strictly based on ascertained unmet needs. The audit erroneously insinuated that our controls failed to ensure reimbursement requests were solely for students with documented unmet needs, further mentioning that due to an indication with some inventory records for about 10% of the equipment procured with ECF funds were amiss. We do not understand where SAO came to this conclusion as the data provided did not indicate this. We insist that all expenditures were legitimate, necessary, and aimed at addressing the dire needs of students, as outlined by the FCC guidelines. The broad definition of unmet needs, as experienced by our district, encompassed various scenarios including shared, outdated, or inadequately secured home devices, which hindered effective remote learning. Moreover, the audit's critique ignores the dynamic and unpredictable nature of the pandemic, which necessitated a flexible and responsive approach to remote learning readiness, as corroborated by FCC's directives. The FCC, in its guidance, clearly emphasized the discretion of schools in determining the unmet needs for remote learning resources, without imposing any rigid metrics or processes. The SAO's approach in disregarding the provided documentation, and not applying any reasonable measures to reduce questioned costs, starkly contrasts with FCC's understanding and allowances during these uncertain times. The SAO's stance to challenge all costs appears to deviate from the FCC's empathetic and flexible guidelines designed to aid districts in navigating through the pandemic's challenges. In light of these circumstances, we are earnestly engaging with the FCC to rectify this matter and ensure our compliance with all pertinent regulations, while continuously enhancing our internal controls and processes. We highly value the FCC's guidance and remain committed to implementing any recommended corrective actions to satisfy both the SAO's and FCC’s requirements. Auditor’s Remarks The State Auditor’s Office is sympathetic to the significant challenges the District faced during the COVID-19 pandemic, and deeply respects its commitment to student learning despite these challenges. SAO knows that in many cases, governments across Washington received significant pandemic-era federal funds without also receiving clear guidance on how to use them. Then, and now, SAO continues to advocate for clear, timely guidance from federal agencies to make sure Washington governments are not put in a difficult position at audit time. However, when auditing federal programs of any kind, governments must provide documentation to substantiate that they met the award requirements. As is our practice and audit standards require, we will review the status of this finding during our next audit. We value our partnership with the District in striving for transparency in public service Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 47 CFR Part 54, Universal Service, Subpart Q, Emergency Connectivity Fund, describes the ECF Program requirements.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 – Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425D-120367 COVID-19, 84.425U-138204 COVID-19, 84.425U-137142 COVID-19, 84.425U-9810 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent $18,872,744 of its ESF awards. This included $3,566,208 of its Elementary and Secondary School Emergency Relief (ESSER II) Fund subprogram (84.425D), $15,258,978 of its American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U), and $47,558 of ESSER subprogram award for Safe School Meals Grant (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor’s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021-22 school year, the District paid $3,285,549 from its ESSER III award to seven contractors for 35 projects to update the existing heating, ventilation and air conditioning (HVAC) systems’ controls, repair insulation, and install new HVAC equipment (heat pumps) in school buildings. These projects were part of the District’s school facility capital improvement efforts to prevent the spread of COVID-19 and enable school operations by facilitating greater air flow and filtration. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not collect weekly certified payroll reports from three contractors tested to confirm they paid laborers proper prevailing wages. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition While District officials knew about state prevailing wage requirements, they did not know about the federal requirements because the District does not usually apply federal funds to construction projects. Effect of Condition Without adequate internal controls that ensure it collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal prevailing wage rate requirements. Additionally, we recommend the District implement effective monitoring processes to collect and review all weekly certified payroll reports from contractors and subcontractors. District’s Response As stated in the “Cause of Condition” section, the district is aware of prevailing wage requirements, but the district does not typically use federal funds for construction projects. The district was unaware of the requirement to review weekly certified payroll reports from the vendors. The district received prior approval from OSPI and has guidance and procedures as it related to Intents, Affidavits, and payments to vendors. The district has implemented internal controls to ensure compliance with federal prevailing wage requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 – Weekly statement with respect to payment of wages, and Section 3.4 – Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 – Contract provisions and related matters establishes the requirements for the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 – Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425D-120367 COVID-19, 84.425U-138204 COVID-19, 84.425U-137142 COVID-19, 84.425U-9810 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent $18,872,744 of its ESF awards. This included $3,566,208 of its Elementary and Secondary School Emergency Relief (ESSER II) Fund subprogram (84.425D), $15,258,978 of its American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U), and $47,558 of ESSER subprogram award for Safe School Meals Grant (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor’s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021-22 school year, the District paid $3,285,549 from its ESSER III award to seven contractors for 35 projects to update the existing heating, ventilation and air conditioning (HVAC) systems’ controls, repair insulation, and install new HVAC equipment (heat pumps) in school buildings. These projects were part of the District’s school facility capital improvement efforts to prevent the spread of COVID-19 and enable school operations by facilitating greater air flow and filtration. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not collect weekly certified payroll reports from three contractors tested to confirm they paid laborers proper prevailing wages. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition While District officials knew about state prevailing wage requirements, they did not know about the federal requirements because the District does not usually apply federal funds to construction projects. Effect of Condition Without adequate internal controls that ensure it collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal prevailing wage rate requirements. Additionally, we recommend the District implement effective monitoring processes to collect and review all weekly certified payroll reports from contractors and subcontractors. District’s Response As stated in the “Cause of Condition” section, the district is aware of prevailing wage requirements, but the district does not typically use federal funds for construction projects. The district was unaware of the requirement to review weekly certified payroll reports from the vendors. The district received prior approval from OSPI and has guidance and procedures as it related to Intents, Affidavits, and payments to vendors. The district has implemented internal controls to ensure compliance with federal prevailing wage requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 – Weekly statement with respect to payment of wages, and Section 3.4 – Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 – Contract provisions and related matters establishes the requirements for the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 – Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425D-120367 COVID-19, 84.425U-138204 COVID-19, 84.425U-137142 COVID-19, 84.425U-9810 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent $18,872,744 of its ESF awards. This included $3,566,208 of its Elementary and Secondary School Emergency Relief (ESSER II) Fund subprogram (84.425D), $15,258,978 of its American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U), and $47,558 of ESSER subprogram award for Safe School Meals Grant (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor’s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021-22 school year, the District paid $3,285,549 from its ESSER III award to seven contractors for 35 projects to update the existing heating, ventilation and air conditioning (HVAC) systems’ controls, repair insulation, and install new HVAC equipment (heat pumps) in school buildings. These projects were part of the District’s school facility capital improvement efforts to prevent the spread of COVID-19 and enable school operations by facilitating greater air flow and filtration. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not collect weekly certified payroll reports from three contractors tested to confirm they paid laborers proper prevailing wages. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition While District officials knew about state prevailing wage requirements, they did not know about the federal requirements because the District does not usually apply federal funds to construction projects. Effect of Condition Without adequate internal controls that ensure it collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal prevailing wage rate requirements. Additionally, we recommend the District implement effective monitoring processes to collect and review all weekly certified payroll reports from contractors and subcontractors. District’s Response As stated in the “Cause of Condition” section, the district is aware of prevailing wage requirements, but the district does not typically use federal funds for construction projects. The district was unaware of the requirement to review weekly certified payroll reports from the vendors. The district received prior approval from OSPI and has guidance and procedures as it related to Intents, Affidavits, and payments to vendors. The district has implemented internal controls to ensure compliance with federal prevailing wage requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 – Weekly statement with respect to payment of wages, and Section 3.4 – Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 – Contract provisions and related matters establishes the requirements for the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 – Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425D-120367 COVID-19, 84.425U-138204 COVID-19, 84.425U-137142 COVID-19, 84.425U-9810 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent $18,872,744 of its ESF awards. This included $3,566,208 of its Elementary and Secondary School Emergency Relief (ESSER II) Fund subprogram (84.425D), $15,258,978 of its American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U), and $47,558 of ESSER subprogram award for Safe School Meals Grant (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor’s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021-22 school year, the District paid $3,285,549 from its ESSER III award to seven contractors for 35 projects to update the existing heating, ventilation and air conditioning (HVAC) systems’ controls, repair insulation, and install new HVAC equipment (heat pumps) in school buildings. These projects were part of the District’s school facility capital improvement efforts to prevent the spread of COVID-19 and enable school operations by facilitating greater air flow and filtration. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not collect weekly certified payroll reports from three contractors tested to confirm they paid laborers proper prevailing wages. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition While District officials knew about state prevailing wage requirements, they did not know about the federal requirements because the District does not usually apply federal funds to construction projects. Effect of Condition Without adequate internal controls that ensure it collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal prevailing wage rate requirements. Additionally, we recommend the District implement effective monitoring processes to collect and review all weekly certified payroll reports from contractors and subcontractors. District’s Response As stated in the “Cause of Condition” section, the district is aware of prevailing wage requirements, but the district does not typically use federal funds for construction projects. The district was unaware of the requirement to review weekly certified payroll reports from the vendors. The district received prior approval from OSPI and has guidance and procedures as it related to Intents, Affidavits, and payments to vendors. The district has implemented internal controls to ensure compliance with federal prevailing wage requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 – Weekly statement with respect to payment of wages, and Section 3.4 – Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 – Contract provisions and related matters establishes the requirements for the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-003 The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, and restricted purpose requirements. Assistance Listing Number and Title: 32.009, COVID-19 – Emergency Connectivity Fund Program Federal Grantor Name: Federal Communications Commission Federal Award/Contract Number: N/A Pass-through Entity Name: N/A Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $850,897 Background The Emergency Connectivity Fund (ECF) Program provides funding to meet the needs of students and school staff who would otherwise lack access to connected devices and broadband connections sufficient to engage in remote learning. This is referred to as “unmet need.” In fiscal year 2022, the District spent $850,897 in ECF Program funds to purchase laptops and tablet computers for students and school staff. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Allowable activities and costs ECF Program recipients may only seek reimbursement for the eligible devices and services provided to students and staff with unmet need. Recipients are prohibited from seeking reimbursement for eligible equipment and services purchased for use solely at the school or held for future use (i.e., warehousing). Restricted purpose – unmet need When submitting applications to the Federal Communications Commission (FCC), schools only had to provide an estimate of their students’ unmet need. However, when requesting reimbursement, the District could only request program funds for eligible equipment and services provided to students and school staff with actual unmet need. Restricted purpose – per-location and per-user limitations The FCC imposed per-location and per-user limitations to maximize the use of limited funds. Under the program, eligible schools could only be reimbursed for one connected device and Wi-Fi hotspot per student or school employee with unmet need, and no more than one fixed broadband connection per location, such as a student’s or employee’s residence. Description of Condition Allowable activities and costs/restricted purpose – unmet need The District estimated unmet need for eligible equipment when it applied for ECF Program funds. However, our audit found the District’s internal controls were ineffective for ensuring it documented the determination of actual unmet need and only requested reimbursement for equipment provided to students with unmet need. Specifically, the District purchased laptops and tablet computers, based on its estimate of unmet need, and it requested reimbursement for these purchases totaling $850,897. However, the District did not maintain documentation showing it provided each laptop and tablet computer paid with program funds to a student with unmet need. Restricted purpose – per-location and per-user limitations Our audit found the District’s internal controls were ineffective for demonstrating it complied with the FCC’s per-location and per-user limitations. Specifically, the District did not maintain documentation showing it monitored or had a tracking process in place to ensure it only provided one device per user and location. We consider these deficiencies in internal controls to be material weaknesses that led to material noncompliance. This issue was not reported as a finding in the prior audit. Cause of Condition Allowable activities and costs/restricted purpose – unmet need Employees in the District’s finance department did not know the ECF Program was federally funded and, therefore, were unaware of all of its regulations. Further, District staff did not know about the requirement to request reimbursement only for actual unmet need and thought the estimate of unmet need provided during the application process was sufficient to comply with this requirement. Restricted purpose – per-location and per-user limitations Staff did not know the District could not provide more than one device per student and, therefore, did not establish a process to ensure each student would only receive one computer purchased with ECF Program funds. Effect of Condition and Questioned Costs Allowable activities and costs/restricted purpose – unmet need Because the District did not have documentation supporting whether it provided eligible equipment to students with actual unmet need, it cannot demonstrate compliance with the program’s requirements. Given the nature of the program and circumstances, it is likely that at least some of the equipment the District charged to the award addressed unmet needs. However, the lack of a documented assessment of students’ actual unmet need means that all costs are unsupported. Since we do not have a reasonable basis for estimating how much of the District’s expenditures are allowable, we are questioning all unsupported costs. Federal regulations require the State Auditor’s Office to report known questioned costs that are greater than $25,000 for each type of compliance requirement. We question costs when we find the District does not have adequate documentation to support expenditures. Restricted purpose – per-location and per-user limitations Because the District provided some students with more than one device and received reimbursement for them, it did not comply with the FCC’s requirement. As noted in the allowable activities and costs section above, we are questioning the costs for these devices. Recommendation We recommend the District work with the granting agency to determine audit resolution. We further recommend the District establish and follow internal controls to ensure staff fully understand the requirements for ECF awards. Specifically, the District should: • Request reimbursement only for eligible equipment and services provided to students with unmet need, and maintain documentation demonstrating compliance • Provide no more than one device per student in compliance with the ECF Program’s requirements District’s Response In reference to the recent audit conducted by the State Auditor's Office (SAO) concerning our District's Emergency Connectivity Fund (ECF) expenditures, we write to formally dispute the findings, particularly the ones related to questioned costs (QC). After a thorough review of the findings and the corresponding references to the Federal Communications Commission (FCC) guidelines, we assert that the audit conclusions are misaligned with the established federal provisions. The audit pointed out certain inadequacies in our internal control mechanisms, a condition we acknowledge had room for improvement, especially during the challenging pandemic period. Nevertheless, it is our contention that a lower level of reporting would have sufficed in addressing these issues since all the expenditures were justified, and devices were distributed strictly based on ascertained unmet needs. The audit erroneously insinuated that our controls failed to ensure reimbursement requests were solely for students with documented unmet needs, further mentioning that due to an indication with some inventory records for about 10% of the equipment procured with ECF funds were amiss. We do not understand where SAO came to this conclusion as the data provided did not indicate this. We insist that all expenditures were legitimate, necessary, and aimed at addressing the dire needs of students, as outlined by the FCC guidelines. The broad definition of unmet needs, as experienced by our district, encompassed various scenarios including shared, outdated, or inadequately secured home devices, which hindered effective remote learning. Moreover, the audit's critique ignores the dynamic and unpredictable nature of the pandemic, which necessitated a flexible and responsive approach to remote learning readiness, as corroborated by FCC's directives. The FCC, in its guidance, clearly emphasized the discretion of schools in determining the unmet needs for remote learning resources, without imposing any rigid metrics or processes. The SAO's approach in disregarding the provided documentation, and not applying any reasonable measures to reduce questioned costs, starkly contrasts with FCC's understanding and allowances during these uncertain times. The SAO's stance to challenge all costs appears to deviate from the FCC's empathetic and flexible guidelines designed to aid districts in navigating through the pandemic's challenges. In light of these circumstances, we are earnestly engaging with the FCC to rectify this matter and ensure our compliance with all pertinent regulations, while continuously enhancing our internal controls and processes. We highly value the FCC's guidance and remain committed to implementing any recommended corrective actions to satisfy both the SAO's and FCC’s requirements. Auditor’s Remarks The State Auditor’s Office is sympathetic to the significant challenges the District faced during the COVID-19 pandemic, and deeply respects its commitment to student learning despite these challenges. SAO knows that in many cases, governments across Washington received significant pandemic-era federal funds without also receiving clear guidance on how to use them. Then, and now, SAO continues to advocate for clear, timely guidance from federal agencies to make sure Washington governments are not put in a difficult position at audit time. However, when auditing federal programs of any kind, governments must provide documentation to substantiate that they met the award requirements. As is our practice and audit standards require, we will review the status of this finding during our next audit. We value our partnership with the District in striving for transparency in public service Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 47 CFR Part 54, Universal Service, Subpart Q, Emergency Connectivity Fund, describes the ECF Program requirements.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-002 The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 – Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 270255 (5189/2030), 270277 (5189/2020), 270572 (5189/5040), 270925 (5189/2070), 270929 (5189/1380), 270931 (5189/1480), 270932 (5189/2060), 204003 (5100-5185) Known Questioned Cost Amount: $48,646 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. The District spent $4,222,764 in federal funds through its Title I program during fiscal year 2022. Employee salaries and benefits made up about 86 percent of program expenditures. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding award requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as required by federal regulations, the awarding agency, and the Office of Superintendent of Public Instruction (OSPI). Depending on the number and type of activities employees perform, time-and-effort documentation can be a semiannual certification or monthly personnel activity report, such as a detailed timesheet. Time-and-effort documentation must also be signed and dated after the work has been completed. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the federal Title I program with appropriate time-and-effort documentation as required. The District could not provide time-and-effort documentation for two employees, a portion of whose salaries and benefits were erroneously charged to the program. We consider this deficiency in internal control to be a significant deficiency. This issue was not reported as a finding in the prior audit. Cause of Condition The District did not dedicate the necessary time and resources to reconciling and ensuring time charged to the program was supported with time-and-effort documentation. District staff responsible for collecting time-and-effort documentation relied on staff assignments and budget allocations established at the beginning of the year to identify employees requiring time-and-effort documentation. Effect of Condition and Questioned Costs Without adequate time-and-effort records, the District cannot assure federal grantors that payroll costs charged to the program were accurate and valid. We used statistical sampling to select and test 41 employees whose salaries and benefits made up about 58 percent of total payroll expenditures charged to the program. We found two employees whose salaries and benefits were not supported by time-andeffort documentation. These charges totaled $47,229 in known questioned costs and $1,417 in related indirect costs. From this, we identified an additional $277,644 in estimated overpayments. Recommendation We recommend the District establish and follow internal controls to ensure it complies with federal and OSPI requirements for time-and-effort documentation. Specifically, we recommend the District obtain and review all time-and-effort documentation to ensure time reported agrees to actual hours worked in the program for all Title I staff and supports payroll costs charged to the program, as OSPI requires. District’s Response The District understands the importance of internal controls in regards to time and effort reporting using federal funds. Our internal controls were not sufficient enough to identify errors in time and effort reporting. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Office of Superintendent of Public Instruction (OSPI) Addendum to Bulletin 048-17, Federal Fiscal Policy, establishes requirements for documenting time-and-effort for employees that work in federal programs.

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 – Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425D-120367 COVID-19, 84.425U-138204 COVID-19, 84.425U-137142 COVID-19, 84.425U-9810 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent $18,872,744 of its ESF awards. This included $3,566,208 of its Elementary and Secondary School Emergency Relief (ESSER II) Fund subprogram (84.425D), $15,258,978 of its American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U), and $47,558 of ESSER subprogram award for Safe School Meals Grant (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor’s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021-22 school year, the District paid $3,285,549 from its ESSER III award to seven contractors for 35 projects to update the existing heating, ventilation and air conditioning (HVAC) systems’ controls, repair insulation, and install new HVAC equipment (heat pumps) in school buildings. These projects were part of the District’s school facility capital improvement efforts to prevent the spread of COVID-19 and enable school operations by facilitating greater air flow and filtration. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not collect weekly certified payroll reports from three contractors tested to confirm they paid laborers proper prevailing wages. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition While District officials knew about state prevailing wage requirements, they did not know about the federal requirements because the District does not usually apply federal funds to construction projects. Effect of Condition Without adequate internal controls that ensure it collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal prevailing wage rate requirements. Additionally, we recommend the District implement effective monitoring processes to collect and review all weekly certified payroll reports from contractors and subcontractors. District’s Response As stated in the “Cause of Condition” section, the district is aware of prevailing wage requirements, but the district does not typically use federal funds for construction projects. The district was unaware of the requirement to review weekly certified payroll reports from the vendors. The district received prior approval from OSPI and has guidance and procedures as it related to Intents, Affidavits, and payments to vendors. The district has implemented internal controls to ensure compliance with federal prevailing wage requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 – Weekly statement with respect to payment of wages, and Section 3.4 – Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 – Contract provisions and related matters establishes the requirements for the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 – Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425D-120367 COVID-19, 84.425U-138204 COVID-19, 84.425U-137142 COVID-19, 84.425U-9810 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent $18,872,744 of its ESF awards. This included $3,566,208 of its Elementary and Secondary School Emergency Relief (ESSER II) Fund subprogram (84.425D), $15,258,978 of its American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U), and $47,558 of ESSER subprogram award for Safe School Meals Grant (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor’s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021-22 school year, the District paid $3,285,549 from its ESSER III award to seven contractors for 35 projects to update the existing heating, ventilation and air conditioning (HVAC) systems’ controls, repair insulation, and install new HVAC equipment (heat pumps) in school buildings. These projects were part of the District’s school facility capital improvement efforts to prevent the spread of COVID-19 and enable school operations by facilitating greater air flow and filtration. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not collect weekly certified payroll reports from three contractors tested to confirm they paid laborers proper prevailing wages. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition While District officials knew about state prevailing wage requirements, they did not know about the federal requirements because the District does not usually apply federal funds to construction projects. Effect of Condition Without adequate internal controls that ensure it collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal prevailing wage rate requirements. Additionally, we recommend the District implement effective monitoring processes to collect and review all weekly certified payroll reports from contractors and subcontractors. District’s Response As stated in the “Cause of Condition” section, the district is aware of prevailing wage requirements, but the district does not typically use federal funds for construction projects. The district was unaware of the requirement to review weekly certified payroll reports from the vendors. The district received prior approval from OSPI and has guidance and procedures as it related to Intents, Affidavits, and payments to vendors. The district has implemented internal controls to ensure compliance with federal prevailing wage requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 – Weekly statement with respect to payment of wages, and Section 3.4 – Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 – Contract provisions and related matters establishes the requirements for the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 – Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425D-120367 COVID-19, 84.425U-138204 COVID-19, 84.425U-137142 COVID-19, 84.425U-9810 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent $18,872,744 of its ESF awards. This included $3,566,208 of its Elementary and Secondary School Emergency Relief (ESSER II) Fund subprogram (84.425D), $15,258,978 of its American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U), and $47,558 of ESSER subprogram award for Safe School Meals Grant (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor’s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021-22 school year, the District paid $3,285,549 from its ESSER III award to seven contractors for 35 projects to update the existing heating, ventilation and air conditioning (HVAC) systems’ controls, repair insulation, and install new HVAC equipment (heat pumps) in school buildings. These projects were part of the District’s school facility capital improvement efforts to prevent the spread of COVID-19 and enable school operations by facilitating greater air flow and filtration. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not collect weekly certified payroll reports from three contractors tested to confirm they paid laborers proper prevailing wages. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition While District officials knew about state prevailing wage requirements, they did not know about the federal requirements because the District does not usually apply federal funds to construction projects. Effect of Condition Without adequate internal controls that ensure it collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal prevailing wage rate requirements. Additionally, we recommend the District implement effective monitoring processes to collect and review all weekly certified payroll reports from contractors and subcontractors. District’s Response As stated in the “Cause of Condition” section, the district is aware of prevailing wage requirements, but the district does not typically use federal funds for construction projects. The district was unaware of the requirement to review weekly certified payroll reports from the vendors. The district received prior approval from OSPI and has guidance and procedures as it related to Intents, Affidavits, and payments to vendors. The district has implemented internal controls to ensure compliance with federal prevailing wage requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 – Weekly statement with respect to payment of wages, and Section 3.4 – Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 – Contract provisions and related matters establishes the requirements for the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).

Auburn School District No. 408 September 1, 2021 through August 31, 2022 2022-001 The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 – Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425D-120367 COVID-19, 84.425U-138204 COVID-19, 84.425U-137142 COVID-19, 84.425U-9810 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent $18,872,744 of its ESF awards. This included $3,566,208 of its Elementary and Secondary School Emergency Relief (ESSER II) Fund subprogram (84.425D), $15,258,978 of its American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U), and $47,558 of ESSER subprogram award for Safe School Meals Grant (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor’s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021-22 school year, the District paid $3,285,549 from its ESSER III award to seven contractors for 35 projects to update the existing heating, ventilation and air conditioning (HVAC) systems’ controls, repair insulation, and install new HVAC equipment (heat pumps) in school buildings. These projects were part of the District’s school facility capital improvement efforts to prevent the spread of COVID-19 and enable school operations by facilitating greater air flow and filtration. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not collect weekly certified payroll reports from three contractors tested to confirm they paid laborers proper prevailing wages. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition While District officials knew about state prevailing wage requirements, they did not know about the federal requirements because the District does not usually apply federal funds to construction projects. Effect of Condition Without adequate internal controls that ensure it collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal prevailing wage rate requirements. Additionally, we recommend the District implement effective monitoring processes to collect and review all weekly certified payroll reports from contractors and subcontractors. District’s Response As stated in the “Cause of Condition” section, the district is aware of prevailing wage requirements, but the district does not typically use federal funds for construction projects. The district was unaware of the requirement to review weekly certified payroll reports from the vendors. The district received prior approval from OSPI and has guidance and procedures as it related to Intents, Affidavits, and payments to vendors. The district has implemented internal controls to ensure compliance with federal prevailing wage requirements. Auditor’s Remarks We appreciate the District’s commitment to resolving the issue. We will review the condition during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 – Weekly statement with respect to payment of wages, and Section 3.4 – Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 – Contract provisions and related matters establishes the requirements for the contracting officer to insert in full in any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).