Audit 299211

FY End
2023-06-30
Total Expended
$712.67M
Findings
4
Programs
52
Organization: School District of Philadelphia (PA)
Year: 2023 Accepted: 2024-03-28

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
386907 2023-002 Significant Deficiency - N
386908 2023-001 Significant Deficiency Yes L
963349 2023-002 Significant Deficiency - N
963350 2023-001 Significant Deficiency Yes L

Programs

ALN Program Spent Major Findings
84.425 Arpa Esser III $175.12M Yes 0
84.010 Title I Grants to Local Educational Agencies $161.94M Yes 1
84.425 Crrsa Esser II $63.74M Yes 0
84.425 Arpa Esser 7% $62.65M Yes 0
93.600 Head Start $48.91M Yes 1
84.027 Special Education_grants to States $47.31M - 0
10.553 School Breakfast Program $16.97M - 0
84.425 Geer II Iu26 $12.67M Yes 0
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $10.55M - 0
84.367 Supporting Effective Instruction State Grants $9.12M - 0
84.425 Arpa Esser Set Aside Iu 025 $7.27M Yes 0
84.048 Career and Technical Education -- Basic Grants to States $6.05M - 0
10.558 Child and Adult Care Food Program $5.69M - 0
93.558 Temporary Assistance for Needy Families $3.76M - 0
10.555 National School Lunch Program $2.91M - 0
84.365 English Language Acquisition State Grants $2.80M - 0
84.425 Education Stabilization Fund $2.51M Yes 0
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $1.85M - 0
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $1.63M - 0
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.11M - 0
84.425 Arp Homeless Children Youth II $1.09M Yes 0
84.425 Eans II Non Public Assistance Program $1.07M Yes 0
84.215 Fund for the Improvement of Education $858,492 - 0
12.002 Procurement Technical Assistance for Business Firms $848,732 - 0
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $599,113 - 0
84.425 Arpa Esser 2.5% $589,639 Yes 0
84.196 Education for Homeless Children and Youth $526,413 - 0
84.184 Safe and Drug-Free Schools and Communities_national Programs $453,730 - 0
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $394,278 - 0
84.013 Title I State Agency Program for Neglected and Delinquent Children and Youth $318,337 - 0
84.425 Geer Continuity of Education and Equity Grant $244,339 Yes 0
84.041 Impact Aid $224,563 - 0
84.425 Geer II Cte $214,013 Yes 0
84.425 Arp Homeless Children Youth I $124,098 Yes 0
10.582 Fresh Fruit and Vegetable Program $109,386 - 0
84.411 Investing in Innovation (i3) Fund $92,876 - 0
84.173 Special Education_preschool Grants $81,540 - 0
16.839 Stop School Violence $76,222 - 0
93.079 Pash Cares $66,558 - 0
16.710 Public Safety Partnership and Community Policing Grants $19,600 - 0
10.649 Pandemic Ebt Administrative Costs $5,950 - 0
84.425 Geer Atsi Sd $2,020 Yes 0
84.377 School Improvement Grants $0 - 0
84.424 Student Support and Academic Enrichment Program $0 Yes 0
84.425 Geer Special Ed Covid 19 $0 Yes 0
84.425 Continuity of Education and Equity Grant $0 Yes 0
84.425 Cares Pccd Health Safety $0 Yes 0
84.425 Statewide System of Support Iu 26 $0 Yes 0
21.019 Coronavirus Relief Fund $0 - 0
93.137 Community Programs to Improve Minority Health Grant Program $0 - 0
66.039 National Clean Diesel Emissions Reduction Program $0 - 0
84.366 Mathematics and Science Partnerships $0 - 0

Contacts

Name Title Type
DJ5CZ47C7RB9 Marcy Blender Auditee
2154005435 Charles Edacheril Auditor
No contacts on file

Notes to SEFA

Title: 1. Government of the School District Accounting Policies: Information contained in the Schedule of Expenditures of Federal Awards (SEFA) is derived from the School District’s accounting systems. For reporting purposes, the School District adheres to the significant accounting policies that are in conformance with generally accepted accounting principles (GAAP) for local governmental units as prescribed by the Governmental Accounting Standards Board. Program expenditures recorded in the SEFA are presented on the modified accrual basis of accounting De Minimis Rate Used: N Rate Explanation: The amount expended includes amounts claimed as indirect cost recovery using an approved indirect cost rate percent calculated by the Pennsylvania Department of Education or as per the funding agencies approved budget. The School District of Philadelphia (the “School District”) is a separate and independent home rule school district of the first class established by the Education Supplement to the Philadelphia Home Rule Charter (the “Charter”) in December 1965. It is the largest school district in the Commonwealth of Pennsylvania (the “Commonwealth”), serving over 196,200 students, including Charter Schools. The School District is the tenth largest in the United States in enrollment and employs more than 19,700 full-time professional and non- professional persons. The boundaries of the School District are coterminous with the boundaries of the City of Philadelphia (the “City”). The School District is a political subdivision of the Commonwealth created to assist in the administration of the General Assembly’s duties under the Constitution of the Commonwealth to “provide for the maintenance and support of a thorough and efficient system of public education to serve the needs of the Commonwealth”. Although the School District is an independent legal entity, it is considered to be a component unit of the City of Philadelphia for reporting purposes and is included in the City’s Annual Comprehensive Financial Report. Local governance by a Board of Education (Board) consisting of nine members appointed by the Mayor of the City of Philadelphia began on July 1, 2018. The board is responsible for the School District's overall operation, management, and educational programs, including all budgetary and financial matters presented herein. The duties of the Board generally include, but are not limited to, the formulation of educational policy, the adoption of an annual budget, the development of a comprehensive capital improvement budget and program, and the incurrence of indebtedness. The Superintendent of Schools reports to the Board. Tony B. Watlington, Sr. ED.D. assumed leadership of the District for the Fiscal Year 2023 reporting period. In addition, a new Chief Financial Officer, Michael Herbstman was appointed in February 2023 when the previous Chief Financial Officer, Uri Z. Monson was appointed as the Budget Secretary for the new Governor of Pennsylvania. There were new School Board leaders for Fiscal Year 2023 with Reginald L. Streator, J.D., appointed President, and Mallory Fix-Lopez as Vice President. The School District also serves as the agent for the Intermediate Unit No. 26, an entity established by the Commonwealth to provide special education, special education transportation, and related management services.
Title: 2. Organization and Scope Accounting Policies: Information contained in the Schedule of Expenditures of Federal Awards (SEFA) is derived from the School District’s accounting systems. For reporting purposes, the School District adheres to the significant accounting policies that are in conformance with generally accepted accounting principles (GAAP) for local governmental units as prescribed by the Governmental Accounting Standards Board. Program expenditures recorded in the SEFA are presented on the modified accrual basis of accounting De Minimis Rate Used: N Rate Explanation: The amount expended includes amounts claimed as indirect cost recovery using an approved indirect cost rate percent calculated by the Pennsylvania Department of Education or as per the funding agencies approved budget. For the fiscal year ending June 30, 2023, the School District of Philadelphia is presenting a Single Audit Report on expenditures of federal awards. This report is issued in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The U.S. Department of Health and Human Services, National External Audit Review Center has been designated the organization-wide cognizant agency for the School District of Philadelphia’s single audit.
Title: 3. Major Programs Accounting Policies: Information contained in the Schedule of Expenditures of Federal Awards (SEFA) is derived from the School District’s accounting systems. For reporting purposes, the School District adheres to the significant accounting policies that are in conformance with generally accepted accounting principles (GAAP) for local governmental units as prescribed by the Governmental Accounting Standards Board. Program expenditures recorded in the SEFA are presented on the modified accrual basis of accounting De Minimis Rate Used: N Rate Explanation: The amount expended includes amounts claimed as indirect cost recovery using an approved indirect cost rate percent calculated by the Pennsylvania Department of Education or as per the funding agencies approved budget. Major federal programs are identified in the Summary of Auditor’s Results section of the Schedule of Findings and Questioned Costs.
Title: 4. Schedule of Expenditures of Federal Awards Accounting Policies: Information contained in the Schedule of Expenditures of Federal Awards (SEFA) is derived from the School District’s accounting systems. For reporting purposes, the School District adheres to the significant accounting policies that are in conformance with generally accepted accounting principles (GAAP) for local governmental units as prescribed by the Governmental Accounting Standards Board. Program expenditures recorded in the SEFA are presented on the modified accrual basis of accounting De Minimis Rate Used: N Rate Explanation: The amount expended includes amounts claimed as indirect cost recovery using an approved indirect cost rate percent calculated by the Pennsylvania Department of Education or as per the funding agencies approved budget. Information contained in the Schedule of Expenditures of Federal Awards (SEFA) is derived from the School District’s accounting systems. For reporting purposes, the School District adheres to the significant accounting policies that are in conformance with generally accepted accounting principles (GAAP) for local governmental units as prescribed by the Governmental Accounting Standards Board. Program expenditures recorded in the SEFA are presented on the modified accrual basis of accounting. The accompanying SEFA includes the federal grant activity of the School District under federal financial assistance programs for the year ended June 30, 2023. The information in this schedule is presented in accordance with the requirements of the Uniform Guidance. Because the schedule presents only a selected portion of the operations of the School District, it is not intended to present the financial position or changes in net position. Federal programs considered active during the year ended June 30, 2023, are reflected in the SEFA. An active federal program is defined as a federal program that incurred expenditures (adjustments) of funds or accrued (deferred) grant revenue adjustments during the fiscal year or a federal program considered as not completed or closed out at the beginning of the fiscal year. Accrued and Unearned Grant Revenue — various worksheet schedules are used for the federal awards received by the School District. Consequently, timing differences between the recognition of revenues and related cash receipts can exist at the beginning and end of the fiscal year. Accrued grant revenue balances represent the excess of revenue recognized over cash received to date. Unearned grant revenue balances represent the excess of cash received over revenue recognized to date.
Title: 5. Schedule of Expenditures of Federal Awards – National School Lunch Program – AL #10.555 Accounting Policies: Information contained in the Schedule of Expenditures of Federal Awards (SEFA) is derived from the School District’s accounting systems. For reporting purposes, the School District adheres to the significant accounting policies that are in conformance with generally accepted accounting principles (GAAP) for local governmental units as prescribed by the Governmental Accounting Standards Board. Program expenditures recorded in the SEFA are presented on the modified accrual basis of accounting De Minimis Rate Used: N Rate Explanation: The amount expended includes amounts claimed as indirect cost recovery using an approved indirect cost rate percent calculated by the Pennsylvania Department of Education or as per the funding agencies approved budget. Information contained in the Schedule of Expenditures of Federal Awards (SEFA) for AL #10.555 – National School Lunch Program – includes Non-Cash Assistance pertaining to food commodities distributed by the United States Department of Agriculture (USDA). Commodities are identified with the programs under which USDA donated the commodities.
Title: 6. Indirect Cost Rate Accounting Policies: Information contained in the Schedule of Expenditures of Federal Awards (SEFA) is derived from the School District’s accounting systems. For reporting purposes, the School District adheres to the significant accounting policies that are in conformance with generally accepted accounting principles (GAAP) for local governmental units as prescribed by the Governmental Accounting Standards Board. Program expenditures recorded in the SEFA are presented on the modified accrual basis of accounting De Minimis Rate Used: N Rate Explanation: The amount expended includes amounts claimed as indirect cost recovery using an approved indirect cost rate percent calculated by the Pennsylvania Department of Education or as per the funding agencies approved budget. The amount expended includes amounts claimed as indirect cost recovery using an approved indirect cost rate percent calculated by the Pennsylvania Department of Education or as per the funding agency’s approved budget. The School District has not elected to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance.
Title: 7. COVID 19 FEMA Grant – AL # 97.036 Accounting Policies: Information contained in the Schedule of Expenditures of Federal Awards (SEFA) is derived from the School District’s accounting systems. For reporting purposes, the School District adheres to the significant accounting policies that are in conformance with generally accepted accounting principles (GAAP) for local governmental units as prescribed by the Governmental Accounting Standards Board. Program expenditures recorded in the SEFA are presented on the modified accrual basis of accounting De Minimis Rate Used: N Rate Explanation: The amount expended includes amounts claimed as indirect cost recovery using an approved indirect cost rate percent calculated by the Pennsylvania Department of Education or as per the funding agencies approved budget. Expenditures related to the COVID 19 FEMA Grant (AL 97.036) that occurred in Fiscal Year 2023 are $1,105,107.89. The grant amount approved in Fiscal Year 2023 are included in this SEFA.

Finding Details

2023-002 SPECIAL TESTS AND PROVISIONS - ANNUAL REPORT CARD, HIGH SCHOOL GRADUATION RATE– SIGNIFICANT DEFICIENCY AND COMPLIANCE FINDING Assistance Listing 84.010 Title I, Part A Condition: In our testing for compliance with Special Tests and Provisions - Annual Report Card, High School Graduation Rate, we noted that School District personnel did not maintain appropriate written documentation to support the transfers of 8 out of 10 sampled students from the adjusted 2019-2020 cohort. Funding for this program is from the Pennsylvania Department of Education (PDE). Criteria: Per the OMB’s Uniform Guidance 34 CFR 200.19 (b)(1)(ii)(B), to remove a student from the cohort, the local educational agency (LEA) must confirm in writing that the student transferred out, emigrated to another country, or is deceased. The LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. According to the PDE’s guide for reporting the Graduation, Dropout and Cohort Data Set, an LEA may not consider a student a transfer unless it knows with certainty that the student has enrolled in another secondary educational institution that offers a regular high school diploma. Effect: Failure to maintain appropriate written documentation to support the removal of students from the 2019-2020 cohort may cause an inaccurate reporting of the 2022-2023 graduation rate and noncompliance with federal and state regulations. Cause: School District personnel stated that they either did not maintain documentation because several years had passed since the students left or they only received verbal confirmation of the students’ transfers. Recommendation: School District management should develop written policies and procedures which require that personnel maintain the appropriate written documentation to support student transfers in accordance with the above criteria to ensure an accurate cohort graduation rate. Views of Responsible Officials and Corrective Action Plan: There is an established School District of Philadelphia (“school district”) Board of Education adopted policy number 208 “Withdrawal From School” last revised in June 2020 which establishes requirements governing the withdrawal of students from school that complies with the Pennsylvania School Code and Department of Education requirements and OMB’s Uniform Guidance 34 CFR 200.19 (b)(1)(ii)(B). To comply with regulatory requirements, the school district is required to obtain written documentation for students who transferred to a private or nonpublic school system or out of the state of PA or out of the United States. According to Pennsylvania Department of Education’s (PDE) guide for reporting graduation, dropouts and cohort data, the school district is required to receive and maintain documentation of transfers. The purpose of School District of Philadelphia Board of Education's Policy 208 is to establish requirements governing withdrawal from school that encourage students to complete an educational program that will equip them with required skills and increase their chances for a successful life beyond school. The policy requires parents/guardians withdrawing a student from school, to enroll in another Local Education Agency, to withdraw the student in person at the school where the student is enrolled. The policy states that, “No student of compulsory school age shall be permitted to withdraw without the written consent of a person in parental relation and supporting documentation.” Although the policy is communicated, not all schools have maintained the written documentation required. Moving forward the school district will provide periodic reminders of the policy to all school leaders and secretaries who enroll and withdraw students. In addition, the Office of Student Support Services administrators will validate with principals that they are maintaining the records for withdrawing students in a safe and central location at their school offices. These strengthened procedures to include a reminder notification to school leaders and secretaries and random audits of WD03 transfers will be implemented by the end of the School Year 2024. Karyn Lynch, Chief of Student Support Services, Office of Student Support Services, School District of Philadelphia, 215-400-6092
2023-001 REPORTING – SIGNIFICANT DEFICIENCY AND COMPLIANCE FINDING Assistance Listing 93.600 Head Start Condition: During our test for compliance with the Federal Funding Accountability and Transparency Act (FFATA), we noted that the School District of Philadelphia (School District) did not have a process in place to report subawards made under the federal Head Start program in accordance with the FFATA and award agreement. Consequently, auditors could not test for FFATA reporting compliance for this grant program. This condition was reported as finding number 2022-002 in the prior year report. Funding for this program is from the Department of Health and Human Services. Criteria: Per the OMB’s Uniform Guidance 2 CFR Part 170, the prime recipient of a federal award must report information regarding first-tier subawards of $30,000 or more utilizing the FFATA Subaward Reporting System (FSRS), and states that the subaward reporting requirement applies to all types of first-tier subawards. The reporting is required by the end of the month following the month in which the award is made. Effect: Federal grantors may not have complete and accurate information to make fiscal decisions on federal awards. Additionally, there could be a lack of transparency and accountability to the public on how federal dollars are spent. Cause: The School District of Philadelphia did not have a systematic process in place to report subawards made under the federal Head Start program in accordance with FFATA. Recommendation: School District’s management should develop written policies and procedures which ensure that it complies with the FFATA requirement to file first-tier subaward reports. Views of Responsible Officials and Corrective Action Plan: The School District of Philadelphia concurs with the finding and recommendation. The District has implemented a systematic process for reporting Fiscal Year 2024 subawards under the Federal Head Start Program which is required to report under FFATA. Moving forward, the process established to ensure reporting will be maintained. Diane Castelbuono, Deputy Chief, Office of Early Childhood Education, School District of Philadelphia, 215-400-6242
2023-002 SPECIAL TESTS AND PROVISIONS - ANNUAL REPORT CARD, HIGH SCHOOL GRADUATION RATE– SIGNIFICANT DEFICIENCY AND COMPLIANCE FINDING Assistance Listing 84.010 Title I, Part A Condition: In our testing for compliance with Special Tests and Provisions - Annual Report Card, High School Graduation Rate, we noted that School District personnel did not maintain appropriate written documentation to support the transfers of 8 out of 10 sampled students from the adjusted 2019-2020 cohort. Funding for this program is from the Pennsylvania Department of Education (PDE). Criteria: Per the OMB’s Uniform Guidance 34 CFR 200.19 (b)(1)(ii)(B), to remove a student from the cohort, the local educational agency (LEA) must confirm in writing that the student transferred out, emigrated to another country, or is deceased. The LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. According to the PDE’s guide for reporting the Graduation, Dropout and Cohort Data Set, an LEA may not consider a student a transfer unless it knows with certainty that the student has enrolled in another secondary educational institution that offers a regular high school diploma. Effect: Failure to maintain appropriate written documentation to support the removal of students from the 2019-2020 cohort may cause an inaccurate reporting of the 2022-2023 graduation rate and noncompliance with federal and state regulations. Cause: School District personnel stated that they either did not maintain documentation because several years had passed since the students left or they only received verbal confirmation of the students’ transfers. Recommendation: School District management should develop written policies and procedures which require that personnel maintain the appropriate written documentation to support student transfers in accordance with the above criteria to ensure an accurate cohort graduation rate. Views of Responsible Officials and Corrective Action Plan: There is an established School District of Philadelphia (“school district”) Board of Education adopted policy number 208 “Withdrawal From School” last revised in June 2020 which establishes requirements governing the withdrawal of students from school that complies with the Pennsylvania School Code and Department of Education requirements and OMB’s Uniform Guidance 34 CFR 200.19 (b)(1)(ii)(B). To comply with regulatory requirements, the school district is required to obtain written documentation for students who transferred to a private or nonpublic school system or out of the state of PA or out of the United States. According to Pennsylvania Department of Education’s (PDE) guide for reporting graduation, dropouts and cohort data, the school district is required to receive and maintain documentation of transfers. The purpose of School District of Philadelphia Board of Education's Policy 208 is to establish requirements governing withdrawal from school that encourage students to complete an educational program that will equip them with required skills and increase their chances for a successful life beyond school. The policy requires parents/guardians withdrawing a student from school, to enroll in another Local Education Agency, to withdraw the student in person at the school where the student is enrolled. The policy states that, “No student of compulsory school age shall be permitted to withdraw without the written consent of a person in parental relation and supporting documentation.” Although the policy is communicated, not all schools have maintained the written documentation required. Moving forward the school district will provide periodic reminders of the policy to all school leaders and secretaries who enroll and withdraw students. In addition, the Office of Student Support Services administrators will validate with principals that they are maintaining the records for withdrawing students in a safe and central location at their school offices. These strengthened procedures to include a reminder notification to school leaders and secretaries and random audits of WD03 transfers will be implemented by the end of the School Year 2024. Karyn Lynch, Chief of Student Support Services, Office of Student Support Services, School District of Philadelphia, 215-400-6092
2023-001 REPORTING – SIGNIFICANT DEFICIENCY AND COMPLIANCE FINDING Assistance Listing 93.600 Head Start Condition: During our test for compliance with the Federal Funding Accountability and Transparency Act (FFATA), we noted that the School District of Philadelphia (School District) did not have a process in place to report subawards made under the federal Head Start program in accordance with the FFATA and award agreement. Consequently, auditors could not test for FFATA reporting compliance for this grant program. This condition was reported as finding number 2022-002 in the prior year report. Funding for this program is from the Department of Health and Human Services. Criteria: Per the OMB’s Uniform Guidance 2 CFR Part 170, the prime recipient of a federal award must report information regarding first-tier subawards of $30,000 or more utilizing the FFATA Subaward Reporting System (FSRS), and states that the subaward reporting requirement applies to all types of first-tier subawards. The reporting is required by the end of the month following the month in which the award is made. Effect: Federal grantors may not have complete and accurate information to make fiscal decisions on federal awards. Additionally, there could be a lack of transparency and accountability to the public on how federal dollars are spent. Cause: The School District of Philadelphia did not have a systematic process in place to report subawards made under the federal Head Start program in accordance with FFATA. Recommendation: School District’s management should develop written policies and procedures which ensure that it complies with the FFATA requirement to file first-tier subaward reports. Views of Responsible Officials and Corrective Action Plan: The School District of Philadelphia concurs with the finding and recommendation. The District has implemented a systematic process for reporting Fiscal Year 2024 subawards under the Federal Head Start Program which is required to report under FFATA. Moving forward, the process established to ensure reporting will be maintained. Diane Castelbuono, Deputy Chief, Office of Early Childhood Education, School District of Philadelphia, 215-400-6242