Finding Number: 2022-005
Prior Year Finding Number: N/A
Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Year: 03/03/2021 – 12/31/2024
Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must:
• Be incorporated into the organization’s official records;
• Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and
• Support the distribution of employee salary across multiple activities or cost objectives.
Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – Payroll expense were not properly calculated and captured in the accounting system.
Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-006
Prior Year Finding Number: N/A
Compliance Requirement: Procurement and Suspension and Debarment
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Period: 03/03/2021- 12/31/2024
Criteria – Recipients of Federal awards must have adequate policies and controls in place to ensure that the procedures are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborate compliance with these requirements.
Condition – We sampled and selected 12 out of 20 procurement transactions during the fiscal year and noted the following:
• For 2 samples out of 12 transactions, the first invoice was issued before the contract was signed. In one of these exceptions, the purchase order was also issued before the contract was signed. Details of these two contracts are below:
o One contract was dated September 2, 2021, whereas the first invoice processed for the contract was
dated June 17, 2021, and the purchase order related to the contract was dated July 20, 2021.
o The second contract was dated December 20, 2021, whereas the first invoice processed for the contract
was dated December 8, 2021.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System’s compliance with the provisions of the Procurement compliance requirement using a statistically valid sample. The total amount of procurement transactions for the program during the fiscal year was $26,823,561. The amount of the 12 samples selected was $23,665,988. The known amount of the two transactions was $4,241,558.
Effect – The School System is not in compliance with the stated provisions.
Cause - The School System does not appear to have a process in place to adequately monitor and maintain completed contract files comprising of all supporting documents.
Recommendation - We recommend that the School System improves internal controls to ensure adherence to Federal relations relating to the procurements of goods and services and review current records retention policies to ensure that the required documentation is properly maintained.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The district is evaluating a centralized contract management solution that would maintain all contracts and agreements upon execution, as well as manage renewals and amendments. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-005
Prior Year Finding Number: N/A
Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Year: 03/03/2021 – 12/31/2024
Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must:
• Be incorporated into the organization’s official records;
• Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and
• Support the distribution of employee salary across multiple activities or cost objectives.
Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – Payroll expense were not properly calculated and captured in the accounting system.
Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-006
Prior Year Finding Number: N/A
Compliance Requirement: Procurement and Suspension and Debarment
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Period: 03/03/2021- 12/31/2024
Criteria – Recipients of Federal awards must have adequate policies and controls in place to ensure that the procedures are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborate compliance with these requirements.
Condition – We sampled and selected 12 out of 20 procurement transactions during the fiscal year and noted the following:
• For 2 samples out of 12 transactions, the first invoice was issued before the contract was signed. In one of these exceptions, the purchase order was also issued before the contract was signed. Details of these two contracts are below:
o One contract was dated September 2, 2021, whereas the first invoice processed for the contract was
dated June 17, 2021, and the purchase order related to the contract was dated July 20, 2021.
o The second contract was dated December 20, 2021, whereas the first invoice processed for the contract
was dated December 8, 2021.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System’s compliance with the provisions of the Procurement compliance requirement using a statistically valid sample. The total amount of procurement transactions for the program during the fiscal year was $26,823,561. The amount of the 12 samples selected was $23,665,988. The known amount of the two transactions was $4,241,558.
Effect – The School System is not in compliance with the stated provisions.
Cause - The School System does not appear to have a process in place to adequately monitor and maintain completed contract files comprising of all supporting documents.
Recommendation - We recommend that the School System improves internal controls to ensure adherence to Federal relations relating to the procurements of goods and services and review current records retention policies to ensure that the required documentation is properly maintained.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The district is evaluating a centralized contract management solution that would maintain all contracts and agreements upon execution, as well as manage renewals and amendments. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-005
Prior Year Finding Number: N/A
Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Year: 03/03/2021 – 12/31/2024
Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must:
• Be incorporated into the organization’s official records;
• Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and
• Support the distribution of employee salary across multiple activities or cost objectives.
Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – Payroll expense were not properly calculated and captured in the accounting system.
Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-006
Prior Year Finding Number: N/A
Compliance Requirement: Procurement and Suspension and Debarment
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Period: 03/03/2021- 12/31/2024
Criteria – Recipients of Federal awards must have adequate policies and controls in place to ensure that the procedures are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborate compliance with these requirements.
Condition – We sampled and selected 12 out of 20 procurement transactions during the fiscal year and noted the following:
• For 2 samples out of 12 transactions, the first invoice was issued before the contract was signed. In one of these exceptions, the purchase order was also issued before the contract was signed. Details of these two contracts are below:
o One contract was dated September 2, 2021, whereas the first invoice processed for the contract was
dated June 17, 2021, and the purchase order related to the contract was dated July 20, 2021.
o The second contract was dated December 20, 2021, whereas the first invoice processed for the contract
was dated December 8, 2021.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System’s compliance with the provisions of the Procurement compliance requirement using a statistically valid sample. The total amount of procurement transactions for the program during the fiscal year was $26,823,561. The amount of the 12 samples selected was $23,665,988. The known amount of the two transactions was $4,241,558.
Effect – The School System is not in compliance with the stated provisions.
Cause - The School System does not appear to have a process in place to adequately monitor and maintain completed contract files comprising of all supporting documents.
Recommendation - We recommend that the School System improves internal controls to ensure adherence to Federal relations relating to the procurements of goods and services and review current records retention policies to ensure that the required documentation is properly maintained.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The district is evaluating a centralized contract management solution that would maintain all contracts and agreements upon execution, as well as manage renewals and amendments. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-005
Prior Year Finding Number: N/A
Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Year: 03/03/2021 – 12/31/2024
Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must:
• Be incorporated into the organization’s official records;
• Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and
• Support the distribution of employee salary across multiple activities or cost objectives.
Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – Payroll expense were not properly calculated and captured in the accounting system.
Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-006
Prior Year Finding Number: N/A
Compliance Requirement: Procurement and Suspension and Debarment
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Period: 03/03/2021- 12/31/2024
Criteria – Recipients of Federal awards must have adequate policies and controls in place to ensure that the procedures are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborate compliance with these requirements.
Condition – We sampled and selected 12 out of 20 procurement transactions during the fiscal year and noted the following:
• For 2 samples out of 12 transactions, the first invoice was issued before the contract was signed. In one of these exceptions, the purchase order was also issued before the contract was signed. Details of these two contracts are below:
o One contract was dated September 2, 2021, whereas the first invoice processed for the contract was
dated June 17, 2021, and the purchase order related to the contract was dated July 20, 2021.
o The second contract was dated December 20, 2021, whereas the first invoice processed for the contract
was dated December 8, 2021.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System’s compliance with the provisions of the Procurement compliance requirement using a statistically valid sample. The total amount of procurement transactions for the program during the fiscal year was $26,823,561. The amount of the 12 samples selected was $23,665,988. The known amount of the two transactions was $4,241,558.
Effect – The School System is not in compliance with the stated provisions.
Cause - The School System does not appear to have a process in place to adequately monitor and maintain completed contract files comprising of all supporting documents.
Recommendation - We recommend that the School System improves internal controls to ensure adherence to Federal relations relating to the procurements of goods and services and review current records retention policies to ensure that the required documentation is properly maintained.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The district is evaluating a centralized contract management solution that would maintain all contracts and agreements upon execution, as well as manage renewals and amendments. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-005
Prior Year Finding Number: N/A
Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Year: 03/03/2021 – 12/31/2024
Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must:
• Be incorporated into the organization’s official records;
• Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and
• Support the distribution of employee salary across multiple activities or cost objectives.
Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – Payroll expense were not properly calculated and captured in the accounting system.
Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-006
Prior Year Finding Number: N/A
Compliance Requirement: Procurement and Suspension and Debarment
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Period: 03/03/2021- 12/31/2024
Criteria – Recipients of Federal awards must have adequate policies and controls in place to ensure that the procedures are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborate compliance with these requirements.
Condition – We sampled and selected 12 out of 20 procurement transactions during the fiscal year and noted the following:
• For 2 samples out of 12 transactions, the first invoice was issued before the contract was signed. In one of these exceptions, the purchase order was also issued before the contract was signed. Details of these two contracts are below:
o One contract was dated September 2, 2021, whereas the first invoice processed for the contract was
dated June 17, 2021, and the purchase order related to the contract was dated July 20, 2021.
o The second contract was dated December 20, 2021, whereas the first invoice processed for the contract
was dated December 8, 2021.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System’s compliance with the provisions of the Procurement compliance requirement using a statistically valid sample. The total amount of procurement transactions for the program during the fiscal year was $26,823,561. The amount of the 12 samples selected was $23,665,988. The known amount of the two transactions was $4,241,558.
Effect – The School System is not in compliance with the stated provisions.
Cause - The School System does not appear to have a process in place to adequately monitor and maintain completed contract files comprising of all supporting documents.
Recommendation - We recommend that the School System improves internal controls to ensure adherence to Federal relations relating to the procurements of goods and services and review current records retention policies to ensure that the required documentation is properly maintained.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The district is evaluating a centralized contract management solution that would maintain all contracts and agreements upon execution, as well as manage renewals and amendments. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-007
Prior Year Finding Number N/A
Compliance Requirement: Period of Performance
Program:
U.S. Department of Education
Special Education-Grants for Infants and Families
ALN #: 84.181A
Award #: 210299, 220134
Award Period: 07/01/2020 – 09/30/2021
07/01/2021 - 09/30/2022
Criteria – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency.
A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h)).
Condition – We sampled and selected 7 out of 21 expenditures and noted 3 expenditures were not properly reviewed. For compliance with period of performance requirements; the three transactions were incurred before the beginning of the period of performance for the respective grants.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System compliance with the specified requirements using a statistically valid sample. The known amount of the 3 transactions incurred outside the grant period amounted to $16,302. The total amount of the 7 samples selected was $52,039. The total amount of the 21 expenditures was $229,430.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – The School System does not appear to have adequate policies and procedures in place to ensure compliance with the required period of performance stipulations.
Recommendation – We recommend that the School System strengthen its processes with respect to setting up and charging expenditures between various grant awards. We also recommend that DOE enhance its review process to properly determine the activities of each grant relative to the appropriate period of performance.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The Infants and Toddlers Supervisor will conduct monthly reviews of outstanding purchase orders in Oracle, addressing issues promptly with the Business Operation Officer/Financial Analyst. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-007
Prior Year Finding Number N/A
Compliance Requirement: Period of Performance
Program:
U.S. Department of Education
Special Education-Grants for Infants and Families
ALN #: 84.181A
Award #: 210299, 220134
Award Period: 07/01/2020 – 09/30/2021
07/01/2021 - 09/30/2022
Criteria – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency.
A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h)).
Condition – We sampled and selected 7 out of 21 expenditures and noted 3 expenditures were not properly reviewed. For compliance with period of performance requirements; the three transactions were incurred before the beginning of the period of performance for the respective grants.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System compliance with the specified requirements using a statistically valid sample. The known amount of the 3 transactions incurred outside the grant period amounted to $16,302. The total amount of the 7 samples selected was $52,039. The total amount of the 21 expenditures was $229,430.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – The School System does not appear to have adequate policies and procedures in place to ensure compliance with the required period of performance stipulations.
Recommendation – We recommend that the School System strengthen its processes with respect to setting up and charging expenditures between various grant awards. We also recommend that DOE enhance its review process to properly determine the activities of each grant relative to the appropriate period of performance.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The Infants and Toddlers Supervisor will conduct monthly reviews of outstanding purchase orders in Oracle, addressing issues promptly with the Business Operation Officer/Financial Analyst. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-005
Prior Year Finding Number: N/A
Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Year: 03/03/2021 – 12/31/2024
Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must:
• Be incorporated into the organization’s official records;
• Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and
• Support the distribution of employee salary across multiple activities or cost objectives.
Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – Payroll expense were not properly calculated and captured in the accounting system.
Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-006
Prior Year Finding Number: N/A
Compliance Requirement: Procurement and Suspension and Debarment
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Period: 03/03/2021- 12/31/2024
Criteria – Recipients of Federal awards must have adequate policies and controls in place to ensure that the procedures are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborate compliance with these requirements.
Condition – We sampled and selected 12 out of 20 procurement transactions during the fiscal year and noted the following:
• For 2 samples out of 12 transactions, the first invoice was issued before the contract was signed. In one of these exceptions, the purchase order was also issued before the contract was signed. Details of these two contracts are below:
o One contract was dated September 2, 2021, whereas the first invoice processed for the contract was
dated June 17, 2021, and the purchase order related to the contract was dated July 20, 2021.
o The second contract was dated December 20, 2021, whereas the first invoice processed for the contract
was dated December 8, 2021.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System’s compliance with the provisions of the Procurement compliance requirement using a statistically valid sample. The total amount of procurement transactions for the program during the fiscal year was $26,823,561. The amount of the 12 samples selected was $23,665,988. The known amount of the two transactions was $4,241,558.
Effect – The School System is not in compliance with the stated provisions.
Cause - The School System does not appear to have a process in place to adequately monitor and maintain completed contract files comprising of all supporting documents.
Recommendation - We recommend that the School System improves internal controls to ensure adherence to Federal relations relating to the procurements of goods and services and review current records retention policies to ensure that the required documentation is properly maintained.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The district is evaluating a centralized contract management solution that would maintain all contracts and agreements upon execution, as well as manage renewals and amendments. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-005
Prior Year Finding Number: N/A
Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Year: 03/03/2021 – 12/31/2024
Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must:
• Be incorporated into the organization’s official records;
• Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and
• Support the distribution of employee salary across multiple activities or cost objectives.
Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – Payroll expense were not properly calculated and captured in the accounting system.
Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-006
Prior Year Finding Number: N/A
Compliance Requirement: Procurement and Suspension and Debarment
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Period: 03/03/2021- 12/31/2024
Criteria – Recipients of Federal awards must have adequate policies and controls in place to ensure that the procedures are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborate compliance with these requirements.
Condition – We sampled and selected 12 out of 20 procurement transactions during the fiscal year and noted the following:
• For 2 samples out of 12 transactions, the first invoice was issued before the contract was signed. In one of these exceptions, the purchase order was also issued before the contract was signed. Details of these two contracts are below:
o One contract was dated September 2, 2021, whereas the first invoice processed for the contract was
dated June 17, 2021, and the purchase order related to the contract was dated July 20, 2021.
o The second contract was dated December 20, 2021, whereas the first invoice processed for the contract
was dated December 8, 2021.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System’s compliance with the provisions of the Procurement compliance requirement using a statistically valid sample. The total amount of procurement transactions for the program during the fiscal year was $26,823,561. The amount of the 12 samples selected was $23,665,988. The known amount of the two transactions was $4,241,558.
Effect – The School System is not in compliance with the stated provisions.
Cause - The School System does not appear to have a process in place to adequately monitor and maintain completed contract files comprising of all supporting documents.
Recommendation - We recommend that the School System improves internal controls to ensure adherence to Federal relations relating to the procurements of goods and services and review current records retention policies to ensure that the required documentation is properly maintained.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The district is evaluating a centralized contract management solution that would maintain all contracts and agreements upon execution, as well as manage renewals and amendments. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-005
Prior Year Finding Number: N/A
Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Year: 03/03/2021 – 12/31/2024
Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must:
• Be incorporated into the organization’s official records;
• Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and
• Support the distribution of employee salary across multiple activities or cost objectives.
Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – Payroll expense were not properly calculated and captured in the accounting system.
Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-006
Prior Year Finding Number: N/A
Compliance Requirement: Procurement and Suspension and Debarment
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Period: 03/03/2021- 12/31/2024
Criteria – Recipients of Federal awards must have adequate policies and controls in place to ensure that the procedures are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborate compliance with these requirements.
Condition – We sampled and selected 12 out of 20 procurement transactions during the fiscal year and noted the following:
• For 2 samples out of 12 transactions, the first invoice was issued before the contract was signed. In one of these exceptions, the purchase order was also issued before the contract was signed. Details of these two contracts are below:
o One contract was dated September 2, 2021, whereas the first invoice processed for the contract was
dated June 17, 2021, and the purchase order related to the contract was dated July 20, 2021.
o The second contract was dated December 20, 2021, whereas the first invoice processed for the contract
was dated December 8, 2021.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System’s compliance with the provisions of the Procurement compliance requirement using a statistically valid sample. The total amount of procurement transactions for the program during the fiscal year was $26,823,561. The amount of the 12 samples selected was $23,665,988. The known amount of the two transactions was $4,241,558.
Effect – The School System is not in compliance with the stated provisions.
Cause - The School System does not appear to have a process in place to adequately monitor and maintain completed contract files comprising of all supporting documents.
Recommendation - We recommend that the School System improves internal controls to ensure adherence to Federal relations relating to the procurements of goods and services and review current records retention policies to ensure that the required documentation is properly maintained.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The district is evaluating a centralized contract management solution that would maintain all contracts and agreements upon execution, as well as manage renewals and amendments. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-005
Prior Year Finding Number: N/A
Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Year: 03/03/2021 – 12/31/2024
Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must:
• Be incorporated into the organization’s official records;
• Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and
• Support the distribution of employee salary across multiple activities or cost objectives.
Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – Payroll expense were not properly calculated and captured in the accounting system.
Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-006
Prior Year Finding Number: N/A
Compliance Requirement: Procurement and Suspension and Debarment
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Period: 03/03/2021- 12/31/2024
Criteria – Recipients of Federal awards must have adequate policies and controls in place to ensure that the procedures are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborate compliance with these requirements.
Condition – We sampled and selected 12 out of 20 procurement transactions during the fiscal year and noted the following:
• For 2 samples out of 12 transactions, the first invoice was issued before the contract was signed. In one of these exceptions, the purchase order was also issued before the contract was signed. Details of these two contracts are below:
o One contract was dated September 2, 2021, whereas the first invoice processed for the contract was
dated June 17, 2021, and the purchase order related to the contract was dated July 20, 2021.
o The second contract was dated December 20, 2021, whereas the first invoice processed for the contract
was dated December 8, 2021.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System’s compliance with the provisions of the Procurement compliance requirement using a statistically valid sample. The total amount of procurement transactions for the program during the fiscal year was $26,823,561. The amount of the 12 samples selected was $23,665,988. The known amount of the two transactions was $4,241,558.
Effect – The School System is not in compliance with the stated provisions.
Cause - The School System does not appear to have a process in place to adequately monitor and maintain completed contract files comprising of all supporting documents.
Recommendation - We recommend that the School System improves internal controls to ensure adherence to Federal relations relating to the procurements of goods and services and review current records retention policies to ensure that the required documentation is properly maintained.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The district is evaluating a centralized contract management solution that would maintain all contracts and agreements upon execution, as well as manage renewals and amendments. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-005
Prior Year Finding Number: N/A
Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Year: 03/03/2021 – 12/31/2024
Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must:
• Be incorporated into the organization’s official records;
• Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100% effort); and
• Support the distribution of employee salary across multiple activities or cost objectives.
Condition – We sampled and selected 60 out of 10,079 payroll transactions and noted two instances where employee’s salary for the period recorded in the general ledger did not reconcile with statement of earnings that supports the time and effort for the time charged to the program. As a result, payroll expense charged for the period were overstated.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of School System’s compliance with the specified requirements using a statistically valid sample. Total amount of payroll expenditures charged to the program in fiscal year 2022 were $11,603,462 and the known amount of the overstated payroll expenses were $14,525. The total amount of the 60 samples selected was $261,550.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – Payroll expense were not properly calculated and captured in the accounting system.
Recommendation – We recommend that School System improve internal controls to ensure adherence to Federal regulations related to the fiscal and administrative requirements for expending and accounting for payroll expenditures. In additions, OMB should review and reconcile cost to ensure accuracy.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. As an on-going effort, the process for creating pay elements for specialized compensation will be monitored for accuracy during the creation stages. Electronic alerts generated in the oracle system will be re-employed to notify appropriate finance personnel of changes. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-006
Prior Year Finding Number: N/A
Compliance Requirement: Procurement and Suspension and Debarment
Program:
U.S. Department of Treasury
COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN #: 21.027
Award #: Various
Award Period: 03/03/2021- 12/31/2024
Criteria – Recipients of Federal awards must have adequate policies and controls in place to ensure that the procedures are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborate compliance with these requirements.
Condition – We sampled and selected 12 out of 20 procurement transactions during the fiscal year and noted the following:
• For 2 samples out of 12 transactions, the first invoice was issued before the contract was signed. In one of these exceptions, the purchase order was also issued before the contract was signed. Details of these two contracts are below:
o One contract was dated September 2, 2021, whereas the first invoice processed for the contract was
dated June 17, 2021, and the purchase order related to the contract was dated July 20, 2021.
o The second contract was dated December 20, 2021, whereas the first invoice processed for the contract
was dated December 8, 2021.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System’s compliance with the provisions of the Procurement compliance requirement using a statistically valid sample. The total amount of procurement transactions for the program during the fiscal year was $26,823,561. The amount of the 12 samples selected was $23,665,988. The known amount of the two transactions was $4,241,558.
Effect – The School System is not in compliance with the stated provisions.
Cause - The School System does not appear to have a process in place to adequately monitor and maintain completed contract files comprising of all supporting documents.
Recommendation - We recommend that the School System improves internal controls to ensure adherence to Federal relations relating to the procurements of goods and services and review current records retention policies to ensure that the required documentation is properly maintained.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The district is evaluating a centralized contract management solution that would maintain all contracts and agreements upon execution, as well as manage renewals and amendments. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-007
Prior Year Finding Number N/A
Compliance Requirement: Period of Performance
Program:
U.S. Department of Education
Special Education-Grants for Infants and Families
ALN #: 84.181A
Award #: 210299, 220134
Award Period: 07/01/2020 – 09/30/2021
07/01/2021 - 09/30/2022
Criteria – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency.
A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h)).
Condition – We sampled and selected 7 out of 21 expenditures and noted 3 expenditures were not properly reviewed. For compliance with period of performance requirements; the three transactions were incurred before the beginning of the period of performance for the respective grants.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System compliance with the specified requirements using a statistically valid sample. The known amount of the 3 transactions incurred outside the grant period amounted to $16,302. The total amount of the 7 samples selected was $52,039. The total amount of the 21 expenditures was $229,430.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – The School System does not appear to have adequate policies and procedures in place to ensure compliance with the required period of performance stipulations.
Recommendation – We recommend that the School System strengthen its processes with respect to setting up and charging expenditures between various grant awards. We also recommend that DOE enhance its review process to properly determine the activities of each grant relative to the appropriate period of performance.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The Infants and Toddlers Supervisor will conduct monthly reviews of outstanding purchase orders in Oracle, addressing issues promptly with the Business Operation Officer/Financial Analyst. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-007
Prior Year Finding Number N/A
Compliance Requirement: Period of Performance
Program:
U.S. Department of Education
Special Education-Grants for Infants and Families
ALN #: 84.181A
Award #: 210299, 220134
Award Period: 07/01/2020 – 09/30/2021
07/01/2021 - 09/30/2022
Criteria – A non-federal entity may charge to the Federal award allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award, only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency.
A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308, 200.309, and 200.403(h)).
Condition – We sampled and selected 7 out of 21 expenditures and noted 3 expenditures were not properly reviewed. For compliance with period of performance requirements; the three transactions were incurred before the beginning of the period of performance for the respective grants.
Questioned Costs – Not determinable.
Context – This is a condition identified per review of the School System compliance with the specified requirements using a statistically valid sample. The known amount of the 3 transactions incurred outside the grant period amounted to $16,302. The total amount of the 7 samples selected was $52,039. The total amount of the 21 expenditures was $229,430.
Effect – The School System is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding.
Cause – The School System does not appear to have adequate policies and procedures in place to ensure compliance with the required period of performance stipulations.
Recommendation – We recommend that the School System strengthen its processes with respect to setting up and charging expenditures between various grant awards. We also recommend that DOE enhance its review process to properly determine the activities of each grant relative to the appropriate period of performance.
Views of Responsible Officials – The School System concurs with the auditor’s findings and recommendations. The Infants and Toddlers Supervisor will conduct monthly reviews of outstanding purchase orders in Oracle, addressing issues promptly with the Business Operation Officer/Financial Analyst. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number 2022-008
Prior Year Finding Number N/A
Compliance Requirement: Allowable Costs/Costs Principles
Program:
U.S. Department of Education
Title I Grants to Local Educational Agencies
ALN #: 84.010
Award #: Various
Award Period: Various
COVID-19 – Governor’s Emergency Education Relief (GEER)
ALN #: 84.425C
Award #: Various
Award Period: Various
COVID-19 – Elementary and Secondary School Emergency Relief (ESSR) Fund
ALN #: 84.425D
Award #: Various
Award Period: Various
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP ESSR)
ALN #: 84.425U
Award #: 211941
Award Period: 03/24/2021 – 09/30/2023
COVID-19 – American Rescue Plan - Elementary and Secondary School Emergency Relief – Homeless Children and Youth
ALN #: 84.425W
Award #: Various
Award Period: Various
Criteria – In accordance with §200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. The financial management system of each non-federal entity must provide for the following:
1. Identification, in its accounts, of all federal awards received and expended and the federal programs under which they were received.
2. Accurate, current, and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in §200.327 Financial Reporting and §200.328 Monitoring and Reporting Program Performance.
3. Records that identify adequately the source and application of funds for federally funded activities.
4. Effective control over, and accountability for, all funds, property, and other assets.
The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award.
Further, CFR Section 200.510 (b) requires the auditee must also prepare a Schedule of Expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502, Basis for determining Federal awards expended.
Condition – The amounts recorded in the Schedule of Expenditures of Federal Awards (SEFA) agree to the total amount recorded in the general ledger. The summary level payroll transactions recorded in the general ledger could not be reconciled to the transaction level detail provided from the payroll system. When comparing the two populations, we identified the following differences:
• ALN 84.425 - For ALN 84.425 sub-program D, we noted a variance of $1,828,609. Total payroll expenditures per the payroll system details amounted to $18,437,724 whereas payroll expenditures per SEFA amounted to $16,609,116.
In addition to the above, for ALN 84.425 sub-program U, we noted a variance of $301,432. Total payroll expenditures per the payroll system details amounted to $3,607,738 whereas payroll expenditures per the SEFA amounted to $3,909,170.
• ALN 84.010 - We noted a variance of $752,503. Total payroll expenditures per the payroll system details amounted to $40,549,584 whereas payroll expenditures per the SEFA amounted to $39,797,081.
Questioned Costs – Not Determinable.
Context – This is a condition identified per review of the School System’s population completeness over the compliance requirements for each program. The prevalence of these findings is detailed in the condition section above.
Effect – The SEFA may not be completely and accurately stated. In addition, the lack of established internal controls policies and procedures to ensure the SEFA is completely and accurately stated can lead to noncompliance with federal statutes, regulations, and provisions of grant agreements.
Cause – The School System did not adhere to their internal policies and procedures to ensure the accuracy of the SEFA.
Recommendation – We recommend that the School System develop policies and procedures and enhance their existing reconciliation process to ensure the completeness and accuracy of the SEFA, and that amounts reported on the SEFA are supported by transaction level detail.
Views of Responsible Officials – The School System does not concur with the auditor’s findings and recommendations. The total expenditures for all federal programs recorded in the Schedule of Expenditures for Federal Awards are accurately presented and tie to the general ledger. The payroll sub-ledger is corrected before posting to the general ledger every two weeks.
The resulting differences are most often immaterial but can be traced to corrections made by the Accounting Office after payroll is reviewed by the grants Restricted Funds Supervisor to ensure payroll is not posted to expired grants. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, since we could not validate the details of the differences.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Finding Number: 2022-009
Prior Year Finding Number: N/A
Compliance Requirement: Data Collection Form and Single Audit Reporting Package
Program:
ALN # 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
ALN # 84.010 Title I Grants to Local Educational Agencies
ALN # 84.181A Special Education-Grants for Infants and Families
ALN # 84.365A English Language Acquisition State Grants
ALN # 84.367 Supporting Effective Instruction State Grants
ALN # 84.425 COVID-19 - Education Stabilization Fund
Criteria – The Uniform Guidance in 2 CFR Section 200.512, Report Submission, establishes that the audit shall be completed and the data collection form and reporting package shall be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit.
The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition – The School System did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended June 30, 2022.
Questioned Costs – Not applicable.
Context – This is a condition identified per review of the School System’s compliance with the specified requirements.
Effect – The School System could be exposed to a reduction or elimination of funds by the Federal awarding agencies.
Cause – The School System did not have controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe.
Recommendation – We recommend that the School System establishes controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.
Views of Responsible Officials - The School System does not concur with the auditor’s findings and recommendations. The fiscal year 2022 single audit was not completed for the auditors to provide a final report to certify in the Federal Audit Clearinghouse within the specified timeframe as noted in the Uniform Guidance in 2 CFR Section 200.512. The planned corrective actions are presented in the School System’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
BDO Response – We have reviewed management’s response and our finding remains as indicated, the School System did not have the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe.