Audit 328448

84.011 MIGRANT EDUCATION PROGRAM – DEPARTMENT OF EDUCATION –COLORADO DEPARTMENT OF EDUCATION PASS-THROUGH 2023-001 ACTIVITIES ALLOWED 1. Criteria: - Local educational agencies use funds in accordance with the agreement with the State educational agency to (a) identify eligible migratory children and their needs; (b) provide instructional and support services that address the identified needs of the eligible children; and (c) to support such objectives through related activities such as, but not limited to, professional development, parental involvement, and transfer of student records. (Emphasis added) 2. Condition: The BOCES submitted a budget that was approved by the Colorado Department of Education outlining the expenditure of certain grant dollars for salaries and benefits to support their Migrant Education Program. These funds were ultimately paid to an outside contractor without an approved budget revision being submitted to the State. The costs were allowable under grant guidelines. 3. Context: The BOCES coded these expenditures to salaries, benefits and supplies expense throughout the year as that was how they were being billed by the third-party contractor. Subsequent to year end, the BOCES reclassified the salary and benefit portion to purchased professional services. As this was subsequent to year end, the BOCES could not file a budget revision with the State. Based on discussions with the client they did not appear to be treating these payments similar to their “flowthrough” dollars to their member district’s rather than as an independent contractor. 4. Cause: The BOCES did not correctly account for the third-party activity until subsequent to year end. 5. Effect: The BOCES spent funds for activities that were theoretically, but not actually, approved by the State. 6. Recommendation: The BOCES should properly account for its activities both in the budget process and in its formal accounting. This will also help ensure that any other requirements related to contracting are also appropriately followed. 7. Management Response: Centennial BOCES will review the expected activities to ensure that they are appropriately listed on the budget submitted to CDE for approval and properly coded throughout the year.

84.011 MIGRANT EDUCATION PROGRAM – DEPARTMENT OF EDUCATION –COLORADO DEPARTMENT OF EDUCATION PASS-THROUGH 2023-002 ALLOWABLE COSTS 1. Criteria: The cost principles in 2 CFR Part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of Federal awards by (1) States, local governments, and Indian tribes. 2. Condition: One of the BOCES member districts did not submit reasonable documentation to support the Time and Effort reporting required by the cost accounting requirements. 3. Context: While the BOCES is ultimately responsible for properly accounting for grant eligible costs, the BOCES does ”flowthrough” reimbursement to its member districts for salaries and benefits that are incurred directly by those districts. As such, the BOCES requires the member districts to retain proper support of Time and Effort at the district level which is to be available upon request. In one instance, while the support for the Time and Effort was submitted to the BOCES when requested, auditor review of that documentation lead to questions about the nature of when that documentation was completed. While the employees in question were not subject to specific timekeeping requirements as they were not allocated employees, the actual Time and Effort certifications were not completed timely relative to the underlying grant expenditures. 4. Cause: The specific cause could not be identified, however, the documentation provided evidence that Time and Effort certifications were not completed timely and that both the BOCES and district internal controls did not identify this failure. 5. Effect: While the BOCES was able to provide Time and Effort documentation for the underlying personnel costs, the timing of those certifications is being questioned. 6. Recommendation: Due to the potential of ongoing staffing changes at the member district level, the BOCES will want to reiterate documentation requirements annually. The BOCES may also want to start requesting Time and Effort documentation as it is completed by the member districts to ensure that they are complying with the documentation requirements. We would recommend that the BOCES ensure, as part of their annual grant closeout, that they have all documentation required to support grant expenditures maintained at the BOCES level in lieu of requesting that information on an as needed basis. 7. Management Response: Centennial BOCES will begin monitoring and collecting monthly time and effort for all listed employees of subgrantees. Centennial BOCES will continue to collect time and effort documentation within Centennial BOCES staff. The BOCES will treat subgrantee employees as if they were Centennial BOCES employees regarding collection of time and effort reports following appropriate policies and procedures. At fiscal year-end a reconciliation of all documents required, including time and effort documentation, will be completed.

84.011 MIGRANT EDUCATION PROGRAM – DEPARTMENT OF EDUCATION –COLORADO DEPARTMENT OF EDUCATION PASS-THROUGH 2023-001 ACTIVITIES ALLOWED 1. Criteria: - Local educational agencies use funds in accordance with the agreement with the State educational agency to (a) identify eligible migratory children and their needs; (b) provide instructional and support services that address the identified needs of the eligible children; and (c) to support such objectives through related activities such as, but not limited to, professional development, parental involvement, and transfer of student records. (Emphasis added) 2. Condition: The BOCES submitted a budget that was approved by the Colorado Department of Education outlining the expenditure of certain grant dollars for salaries and benefits to support their Migrant Education Program. These funds were ultimately paid to an outside contractor without an approved budget revision being submitted to the State. The costs were allowable under grant guidelines. 3. Context: The BOCES coded these expenditures to salaries, benefits and supplies expense throughout the year as that was how they were being billed by the third-party contractor. Subsequent to year end, the BOCES reclassified the salary and benefit portion to purchased professional services. As this was subsequent to year end, the BOCES could not file a budget revision with the State. Based on discussions with the client they did not appear to be treating these payments similar to their “flowthrough” dollars to their member district’s rather than as an independent contractor. 4. Cause: The BOCES did not correctly account for the third-party activity until subsequent to year end. 5. Effect: The BOCES spent funds for activities that were theoretically, but not actually, approved by the State. 6. Recommendation: The BOCES should properly account for its activities both in the budget process and in its formal accounting. This will also help ensure that any other requirements related to contracting are also appropriately followed. 7. Management Response: Centennial BOCES will review the expected activities to ensure that they are appropriately listed on the budget submitted to CDE for approval and properly coded throughout the year.

84.011 MIGRANT EDUCATION PROGRAM – DEPARTMENT OF EDUCATION –COLORADO DEPARTMENT OF EDUCATION PASS-THROUGH 2023-002 ALLOWABLE COSTS 1. Criteria: The cost principles in 2 CFR Part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of Federal awards by (1) States, local governments, and Indian tribes. 2. Condition: One of the BOCES member districts did not submit reasonable documentation to support the Time and Effort reporting required by the cost accounting requirements. 3. Context: While the BOCES is ultimately responsible for properly accounting for grant eligible costs, the BOCES does ”flowthrough” reimbursement to its member districts for salaries and benefits that are incurred directly by those districts. As such, the BOCES requires the member districts to retain proper support of Time and Effort at the district level which is to be available upon request. In one instance, while the support for the Time and Effort was submitted to the BOCES when requested, auditor review of that documentation lead to questions about the nature of when that documentation was completed. While the employees in question were not subject to specific timekeeping requirements as they were not allocated employees, the actual Time and Effort certifications were not completed timely relative to the underlying grant expenditures. 4. Cause: The specific cause could not be identified, however, the documentation provided evidence that Time and Effort certifications were not completed timely and that both the BOCES and district internal controls did not identify this failure. 5. Effect: While the BOCES was able to provide Time and Effort documentation for the underlying personnel costs, the timing of those certifications is being questioned. 6. Recommendation: Due to the potential of ongoing staffing changes at the member district level, the BOCES will want to reiterate documentation requirements annually. The BOCES may also want to start requesting Time and Effort documentation as it is completed by the member districts to ensure that they are complying with the documentation requirements. We would recommend that the BOCES ensure, as part of their annual grant closeout, that they have all documentation required to support grant expenditures maintained at the BOCES level in lieu of requesting that information on an as needed basis. 7. Management Response: Centennial BOCES will begin monitoring and collecting monthly time and effort for all listed employees of subgrantees. Centennial BOCES will continue to collect time and effort documentation within Centennial BOCES staff. The BOCES will treat subgrantee employees as if they were Centennial BOCES employees regarding collection of time and effort reports following appropriate policies and procedures. At fiscal year-end a reconciliation of all documents required, including time and effort documentation, will be completed.