Audit 328983

Condition: The total number of children reported on the Impact Aid application was correct for children residing on Indian lands, both with and without disabilities, and it was also correct for total membership enrolled with disabilities. However, the supporting data provided for children with disabilities did not agree with the information used to prepare and report on the Impact Aid application as follows: Criteria: The District is responsible for reporting a correct count of federally connected children in various categories on their Impact Aid application, including children with disabilities. Cause: When preparing the Impact Aid application, the District used an incorrect report that was not updated for children with disabilities as of the survey date. The procedures in place to monitor accuracy of the final application before submission were not sufficient to avoid undetected errors. Effect: The District may receive incorrect Impact Aid under the grant application than is appropriate for federally connected children and those receiving special services based if an incorrect number of children is reported. Recommendation: District personnel should enhance control procedures to monitor the application process to ensure correct information is being reported.

Condition: The District did not amend budgets with the grantor agency prior to spending and did not take into account prior fiscal year spending before spending in the current fiscal year and filing reimbursement claims. The District did not consider prior year spending by budget category incurred and reported on the schedule of federal awards (SEFA) in fiscal years 2021, 2022, and 2023. As such they posted additional similarly eligible, but different categorical, expenses in fiscal 2024 to their general ledger in an effort to claim the remaining reimbursement in line with budget categories. However, from a cumulative approach, audit adjustments of ($167,945) for ESSERS II and ($90,128) for ESSERS III were required in fiscal 2024 to properly state the remaining expenditures of the multi-year grants on the fiscal 2024 SEFA. After the required adjustments, cumulatively, ESSERS II overspent supplies by $84,902 and ESSERS III overspent salaries by $28,633. Similar findings for overspending on budgets were noted in fiscal 2022 and 2023. The District also did not take into consideration the prior year spending when submitting reimbursement claims in fiscal 2024 so the claims submitted did not match the actual spending as incurred and reported by the District, in succession, over the multi-year period. However, the claims for reimbursements did substantially agree both for grant total and by grant budget line and therefore, the grantor agency fully paid for the reimbursements submitted. Criteria: The District is responsible for having a system of controls to ensure compliance with budget requirements of the grantor agency and for monitoring of expenditures against approved budgets and total grant amounts. The District is also responsible for monitoring that expenditures claimed for reimbursement for multi-year grants agree to the expenditures that were reported in the general ledgers as they were incurred over multiple fiscal years. Cause: The District did not have a control process to summarize grants expended over multiple fiscal years against original budgets. The District’s business manager also passed away suddenly in the middle of the multi-year grant period which contributed to the difficulty of monitoring the multiyear grant. Grant budgets were not amended to represent prior spending reported, so they did not correctly represent the remainder of spending by budget line. As such, the District believed their spending was within allowed budgets. The District was also working with the grantor agency on both current year reporting and remaining reimbursement claims, but the focus was on total eligible expenses, not on fiscal year reporting. Both the ESSERS II and ESSERS III reimbursement claims for grant totals have been fully paid by the granting agency. Effect: Federal expenditures for disallowed activities could occur if budgets are not approved in advance and spent accordingly. Federal expenditures may also be disallowed if they do not agree with the amounts reported in the fiscal year. Recommendation: The District should implement controls to prevent obligation or spending that would cause the categorical budget to be exceeded without first securing an approved budget amendment. The District should implement controls to monitor that only costs to be claimed on federal grants are being coded to those functions. Further, the District should implement controls to monitor that the costs claimed for reimbursement agree to the fiscal year that were reported on the financial statements.

Condition: The District did not monitor completeness of weekly certified payroll submission for federally funded construction contracts. Criteria: Construction projects paid with Education Stabilization Funds are subject to wage rate requirements. The District is responsible for monitoring that all weekly certified payrolls are received. Cause: The contractor did not provide a subcontractor list to the District and did not provide weekly reports to the District indicating which subcontractors were onsite. Further, weekly certified payrolls were not sent to the District until we requested them during our audit procedures. Effect: It is possible that not all contractors required to certify weekly payroll submitted their wage rate certifications. Recommendation: The District should enhance control procedures to monitor completeness of the documents provided by the general contractor.

Condition: The total number of children reported on the Impact Aid application was correct for children residing on Indian lands, both with and without disabilities, and it was also correct for total membership enrolled with disabilities. However, the supporting data provided for children with disabilities did not agree with the information used to prepare and report on the Impact Aid application as follows: Criteria: The District is responsible for reporting a correct count of federally connected children in various categories on their Impact Aid application, including children with disabilities. Cause: When preparing the Impact Aid application, the District used an incorrect report that was not updated for children with disabilities as of the survey date. The procedures in place to monitor accuracy of the final application before submission were not sufficient to avoid undetected errors. Effect: The District may receive incorrect Impact Aid under the grant application than is appropriate for federally connected children and those receiving special services based if an incorrect number of children is reported. Recommendation: District personnel should enhance control procedures to monitor the application process to ensure correct information is being reported.

Condition: The District did not amend budgets with the grantor agency prior to spending and did not take into account prior fiscal year spending before spending in the current fiscal year and filing reimbursement claims. The District did not consider prior year spending by budget category incurred and reported on the schedule of federal awards (SEFA) in fiscal years 2021, 2022, and 2023. As such they posted additional similarly eligible, but different categorical, expenses in fiscal 2024 to their general ledger in an effort to claim the remaining reimbursement in line with budget categories. However, from a cumulative approach, audit adjustments of ($167,945) for ESSERS II and ($90,128) for ESSERS III were required in fiscal 2024 to properly state the remaining expenditures of the multi-year grants on the fiscal 2024 SEFA. After the required adjustments, cumulatively, ESSERS II overspent supplies by $84,902 and ESSERS III overspent salaries by $28,633. Similar findings for overspending on budgets were noted in fiscal 2022 and 2023. The District also did not take into consideration the prior year spending when submitting reimbursement claims in fiscal 2024 so the claims submitted did not match the actual spending as incurred and reported by the District, in succession, over the multi-year period. However, the claims for reimbursements did substantially agree both for grant total and by grant budget line and therefore, the grantor agency fully paid for the reimbursements submitted. Criteria: The District is responsible for having a system of controls to ensure compliance with budget requirements of the grantor agency and for monitoring of expenditures against approved budgets and total grant amounts. The District is also responsible for monitoring that expenditures claimed for reimbursement for multi-year grants agree to the expenditures that were reported in the general ledgers as they were incurred over multiple fiscal years. Cause: The District did not have a control process to summarize grants expended over multiple fiscal years against original budgets. The District’s business manager also passed away suddenly in the middle of the multi-year grant period which contributed to the difficulty of monitoring the multiyear grant. Grant budgets were not amended to represent prior spending reported, so they did not correctly represent the remainder of spending by budget line. As such, the District believed their spending was within allowed budgets. The District was also working with the grantor agency on both current year reporting and remaining reimbursement claims, but the focus was on total eligible expenses, not on fiscal year reporting. Both the ESSERS II and ESSERS III reimbursement claims for grant totals have been fully paid by the granting agency. Effect: Federal expenditures for disallowed activities could occur if budgets are not approved in advance and spent accordingly. Federal expenditures may also be disallowed if they do not agree with the amounts reported in the fiscal year. Recommendation: The District should implement controls to prevent obligation or spending that would cause the categorical budget to be exceeded without first securing an approved budget amendment. The District should implement controls to monitor that only costs to be claimed on federal grants are being coded to those functions. Further, the District should implement controls to monitor that the costs claimed for reimbursement agree to the fiscal year that were reported on the financial statements.

Condition: The District did not monitor completeness of weekly certified payroll submission for federally funded construction contracts. Criteria: Construction projects paid with Education Stabilization Funds are subject to wage rate requirements. The District is responsible for monitoring that all weekly certified payrolls are received. Cause: The contractor did not provide a subcontractor list to the District and did not provide weekly reports to the District indicating which subcontractors were onsite. Further, weekly certified payrolls were not sent to the District until we requested them during our audit procedures. Effect: It is possible that not all contractors required to certify weekly payroll submitted their wage rate certifications. Recommendation: The District should enhance control procedures to monitor completeness of the documents provided by the general contractor.