Audit 331265

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditure adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: • Twelve-line items in the Title I grants, totaling $104,453.87. • Seven-line items in the ARP ESSER grant, totaling $259,335.59. • Two-line items in the Special Education IDEA Part B grant, totaling $6,499.58. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $370,289.04 Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditure adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: • Twelve-line items in the Title I grants, totaling $104,453.87. • Seven-line items in the ARP ESSER grant, totaling $259,335.59. • Two-line items in the Special Education IDEA Part B grant, totaling $6,499.58. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $370,289.04 Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditure adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: • Twelve-line items in the Title I grants, totaling $104,453.87. • Seven-line items in the ARP ESSER grant, totaling $259,335.59. • Two-line items in the Special Education IDEA Part B grant, totaling $6,499.58. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $370,289.04 Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Repeat Finding: No Criteria: Under 2 CFR Part 200, entities receiving federal funds must follow the stricter of regulations between state and federal guidelines for purchasing and tracking equipment. Specifically, 2 CFR 313 requires recipients to maintain detailed property records for equipment acquired with federal awards. These records must include descriptions, identification numbers, funding sources, acquisition dates, costs, federal contribution percentages, locations, usage, conditions, and disposal information. Recipients must also update these records whenever the status of the property changes. Specifically, the Mississippi Public School Asset Management Manual requires school districts to maintain current inventories of property items valued at $1,000 or more. Additionally, other items, such as cameras, camera equipment, televisions, computers and computer equipment equal to or greater than $250, must be included in the inventory. Other equipment such as tools, furniture and other assets regardless of their purchase price or fair market value must be included. This also requires thorough tracking and management of school assets. Condition: The District’s internal controls over fixed asset inventory were inadequate to ensure that the District followed its internal control policies on fixed assets, which require all assets above a certain threshold and others regardless of cost to be listed in its fixed asset system. As a result, we observed approximately $260,627 in equipment purchased with federal grant (ESSER II) that was not properly included in the District’s fixed asset system. Context/ Perspective: This finding is a result of our statistically valid random sample of forty fixed assets inventory observation for single audit purposes and the conditions cited appear to be a systematic issue. Cause: The District’s internal control system is inadequate to ensure that the fixed asset system fulfilled the requirements of the current District internal control policy, “Fixed Asset Accountability” is inadequate. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to improve the monitoring activities element of its current internal control system which will ensure that it fulfills the standards for Federal requirements of “Equipment and Real Property Management” contained in the U. S. Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Subpart D, section 200.313(d)(1). Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires 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, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires 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, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires 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, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: Appendix B of 2 CFR Part 225 requires that if an employee works exclusively on a single federal award (a single cost objective), their salary charges must be supported by semi-annual certifications. These certifications must confirm the employee’s sole work on the program and be signed by the employee and approved by their supervisor. The District’s Federal Programs Procedural Handbook specifies the following: “Employees who work solely on a single cost objective will have their time and effort confirmed twice annually through the use of a Semi-Annual Certification. The employee or supervisor with first-hand knowledge of the employee’s work will certify that the time and effort expended in the prior six-month period was in accordance with the cost objective identified on the form. Semi-Annual Certifications will include the names of all individuals paid through a specified federal grant who have worked on a single cost objective in the previous six-month period. These certifications will be distributed by the Federal Programs Director for the period of July 1 through December 31 and January 1 through June 30. The Semi-Annual Certifications will be collected and reviewed by the Federal Programs Director in a timely fashion, on or about the end of the month in which they are distributed.” Condition: The District did not fulfill its present internal control policies and procedures contained in the District’s Federal Programs Procedural Handbook or Appendix B of 2 CFR Part 225. As a result, there were three instances where we were unable to observe all required semi-annual certifications for employees working under a single cost objective. Context/ Perspective: This finding is a result of our statistically valid random sample of forty cash disbursements for single audit purposes and the conditions cited appear to be an isolated issue. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to prepare and review time and effort reporting forms in a timely and accurate manner may lead to improper charges to the federal award which can result in disallowed costs being applied to the program. Question Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that it obtains and maintains the required semi-annual certifications required by employees who work on a single cost objective and are paid through federal grants. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: Appendix B of 2 CFR Part 225 requires that if an employee works exclusively on a single federal award (a single cost objective), their salary charges must be supported by semi-annual certifications. These certifications must confirm the employee’s sole work on the program and be signed by the employee and approved by their supervisor. The District’s Federal Programs Procedural Handbook specifies the following: “Employees who work solely on a single cost objective will have their time and effort confirmed twice annually through the use of a Semi-Annual Certification. The employee or supervisor with first-hand knowledge of the employee’s work will certify that the time and effort expended in the prior six-month period was in accordance with the cost objective identified on the form. Semi-Annual Certifications will include the names of all individuals paid through a specified federal grant who have worked on a single cost objective in the previous six-month period. These certifications will be distributed by the Federal Programs Director for the period of July 1 through December 31 and January 1 through June 30. The Semi-Annual Certifications will be collected and reviewed by the Federal Programs Director in a timely fashion, on or about the end of the month in which they are distributed.” Condition: The District did not fulfill its present internal control policies and procedures contained in the District’s Federal Programs Procedural Handbook or Appendix B of 2 CFR Part 225. As a result, there were three instances where we were unable to observe all required semi-annual certifications for employees working under a single cost objective. Context/ Perspective: This finding is a result of our statistically valid random sample of forty cash disbursements for single audit purposes and the conditions cited appear to be an isolated issue. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to prepare and review time and effort reporting forms in a timely and accurate manner may lead to improper charges to the federal award which can result in disallowed costs being applied to the program. Question Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that it obtains and maintains the required semi-annual certifications required by employees who work on a single cost objective and are paid through federal grants. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: Appendix B of 2 CFR Part 225 requires that if an employee works exclusively on a single federal award (a single cost objective), their salary charges must be supported by semi-annual certifications. These certifications must confirm the employee’s sole work on the program and be signed by the employee and approved by their supervisor. The District’s Federal Programs Procedural Handbook specifies the following: “Employees who work solely on a single cost objective will have their time and effort confirmed twice annually through the use of a Semi-Annual Certification. The employee or supervisor with first-hand knowledge of the employee’s work will certify that the time and effort expended in the prior six-month period was in accordance with the cost objective identified on the form. Semi-Annual Certifications will include the names of all individuals paid through a specified federal grant who have worked on a single cost objective in the previous six-month period. These certifications will be distributed by the Federal Programs Director for the period of July 1 through December 31 and January 1 through June 30. The Semi-Annual Certifications will be collected and reviewed by the Federal Programs Director in a timely fashion, on or about the end of the month in which they are distributed.” Condition: The District did not fulfill its present internal control policies and procedures contained in the District’s Federal Programs Procedural Handbook or Appendix B of 2 CFR Part 225. As a result, there were three instances where we were unable to observe all required semi-annual certifications for employees working under a single cost objective. Context/ Perspective: This finding is a result of our statistically valid random sample of forty cash disbursements for single audit purposes and the conditions cited appear to be an isolated issue. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to prepare and review time and effort reporting forms in a timely and accurate manner may lead to improper charges to the federal award which can result in disallowed costs being applied to the program. Question Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that it obtains and maintains the required semi-annual certifications required by employees who work on a single cost objective and are paid through federal grants. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires 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, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditure adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: • Twelve-line items in the Title I grants, totaling $104,453.87. • Seven-line items in the ARP ESSER grant, totaling $259,335.59. • Two-line items in the Special Education IDEA Part B grant, totaling $6,499.58. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $370,289.04 Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires 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, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditure adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: • Twelve-line items in the Title I grants, totaling $104,453.87. • Seven-line items in the ARP ESSER grant, totaling $259,335.59. • Two-line items in the Special Education IDEA Part B grant, totaling $6,499.58. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $370,289.04 Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditure adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: • Twelve-line items in the Title I grants, totaling $104,453.87. • Seven-line items in the ARP ESSER grant, totaling $259,335.59. • Two-line items in the Special Education IDEA Part B grant, totaling $6,499.58. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $370,289.04 Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditure adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: • Twelve-line items in the Title I grants, totaling $104,453.87. • Seven-line items in the ARP ESSER grant, totaling $259,335.59. • Two-line items in the Special Education IDEA Part B grant, totaling $6,499.58. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $370,289.04 Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Repeat Finding: No Criteria: Under 2 CFR Part 200, entities receiving federal funds must follow the stricter of regulations between state and federal guidelines for purchasing and tracking equipment. Specifically, 2 CFR 313 requires recipients to maintain detailed property records for equipment acquired with federal awards. These records must include descriptions, identification numbers, funding sources, acquisition dates, costs, federal contribution percentages, locations, usage, conditions, and disposal information. Recipients must also update these records whenever the status of the property changes. Specifically, the Mississippi Public School Asset Management Manual requires school districts to maintain current inventories of property items valued at $1,000 or more. Additionally, other items, such as cameras, camera equipment, televisions, computers and computer equipment equal to or greater than $250, must be included in the inventory. Other equipment such as tools, furniture and other assets regardless of their purchase price or fair market value must be included. This also requires thorough tracking and management of school assets. Condition: The District’s internal controls over fixed asset inventory were inadequate to ensure that the District followed its internal control policies on fixed assets, which require all assets above a certain threshold and others regardless of cost to be listed in its fixed asset system. As a result, we observed approximately $260,627 in equipment purchased with federal grant (ESSER II) that was not properly included in the District’s fixed asset system. Context/ Perspective: This finding is a result of our statistically valid random sample of forty fixed assets inventory observation for single audit purposes and the conditions cited appear to be a systematic issue. Cause: The District’s internal control system is inadequate to ensure that the fixed asset system fulfilled the requirements of the current District internal control policy, “Fixed Asset Accountability” is inadequate. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to improve the monitoring activities element of its current internal control system which will ensure that it fulfills the standards for Federal requirements of “Equipment and Real Property Management” contained in the U. S. Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Subpart D, section 200.313(d)(1). Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires 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, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires 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, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires 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, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: Appendix B of 2 CFR Part 225 requires that if an employee works exclusively on a single federal award (a single cost objective), their salary charges must be supported by semi-annual certifications. These certifications must confirm the employee’s sole work on the program and be signed by the employee and approved by their supervisor. The District’s Federal Programs Procedural Handbook specifies the following: “Employees who work solely on a single cost objective will have their time and effort confirmed twice annually through the use of a Semi-Annual Certification. The employee or supervisor with first-hand knowledge of the employee’s work will certify that the time and effort expended in the prior six-month period was in accordance with the cost objective identified on the form. Semi-Annual Certifications will include the names of all individuals paid through a specified federal grant who have worked on a single cost objective in the previous six-month period. These certifications will be distributed by the Federal Programs Director for the period of July 1 through December 31 and January 1 through June 30. The Semi-Annual Certifications will be collected and reviewed by the Federal Programs Director in a timely fashion, on or about the end of the month in which they are distributed.” Condition: The District did not fulfill its present internal control policies and procedures contained in the District’s Federal Programs Procedural Handbook or Appendix B of 2 CFR Part 225. As a result, there were three instances where we were unable to observe all required semi-annual certifications for employees working under a single cost objective. Context/ Perspective: This finding is a result of our statistically valid random sample of forty cash disbursements for single audit purposes and the conditions cited appear to be an isolated issue. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to prepare and review time and effort reporting forms in a timely and accurate manner may lead to improper charges to the federal award which can result in disallowed costs being applied to the program. Question Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that it obtains and maintains the required semi-annual certifications required by employees who work on a single cost objective and are paid through federal grants. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: Appendix B of 2 CFR Part 225 requires that if an employee works exclusively on a single federal award (a single cost objective), their salary charges must be supported by semi-annual certifications. These certifications must confirm the employee’s sole work on the program and be signed by the employee and approved by their supervisor. The District’s Federal Programs Procedural Handbook specifies the following: “Employees who work solely on a single cost objective will have their time and effort confirmed twice annually through the use of a Semi-Annual Certification. The employee or supervisor with first-hand knowledge of the employee’s work will certify that the time and effort expended in the prior six-month period was in accordance with the cost objective identified on the form. Semi-Annual Certifications will include the names of all individuals paid through a specified federal grant who have worked on a single cost objective in the previous six-month period. These certifications will be distributed by the Federal Programs Director for the period of July 1 through December 31 and January 1 through June 30. The Semi-Annual Certifications will be collected and reviewed by the Federal Programs Director in a timely fashion, on or about the end of the month in which they are distributed.” Condition: The District did not fulfill its present internal control policies and procedures contained in the District’s Federal Programs Procedural Handbook or Appendix B of 2 CFR Part 225. As a result, there were three instances where we were unable to observe all required semi-annual certifications for employees working under a single cost objective. Context/ Perspective: This finding is a result of our statistically valid random sample of forty cash disbursements for single audit purposes and the conditions cited appear to be an isolated issue. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to prepare and review time and effort reporting forms in a timely and accurate manner may lead to improper charges to the federal award which can result in disallowed costs being applied to the program. Question Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that it obtains and maintains the required semi-annual certifications required by employees who work on a single cost objective and are paid through federal grants. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: Appendix B of 2 CFR Part 225 requires that if an employee works exclusively on a single federal award (a single cost objective), their salary charges must be supported by semi-annual certifications. These certifications must confirm the employee’s sole work on the program and be signed by the employee and approved by their supervisor. The District’s Federal Programs Procedural Handbook specifies the following: “Employees who work solely on a single cost objective will have their time and effort confirmed twice annually through the use of a Semi-Annual Certification. The employee or supervisor with first-hand knowledge of the employee’s work will certify that the time and effort expended in the prior six-month period was in accordance with the cost objective identified on the form. Semi-Annual Certifications will include the names of all individuals paid through a specified federal grant who have worked on a single cost objective in the previous six-month period. These certifications will be distributed by the Federal Programs Director for the period of July 1 through December 31 and January 1 through June 30. The Semi-Annual Certifications will be collected and reviewed by the Federal Programs Director in a timely fashion, on or about the end of the month in which they are distributed.” Condition: The District did not fulfill its present internal control policies and procedures contained in the District’s Federal Programs Procedural Handbook or Appendix B of 2 CFR Part 225. As a result, there were three instances where we were unable to observe all required semi-annual certifications for employees working under a single cost objective. Context/ Perspective: This finding is a result of our statistically valid random sample of forty cash disbursements for single audit purposes and the conditions cited appear to be an isolated issue. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to prepare and review time and effort reporting forms in a timely and accurate manner may lead to improper charges to the federal award which can result in disallowed costs being applied to the program. Question Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that it obtains and maintains the required semi-annual certifications required by employees who work on a single cost objective and are paid through federal grants. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires 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, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires the tracing of funds to a level of expenditure adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts: • Twelve-line items in the Title I grants, totaling $104,453.87. • Seven-line items in the ARP ESSER grant, totaling $259,335.59. • Two-line items in the Special Education IDEA Part B grant, totaling $6,499.58. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $370,289.04 Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies (Title I, Part A of the ESEA) Assistance Listing: 84.027/84.173 – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing 84.425U – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Repeat Finding: No Criteria: 2 CFR 200.302 requires that a non-federal entity’s financial management system must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions. This section further requires 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, including a comparison of expenditures with budget amounts for each federal award. 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. Condition: As part of our audit procedures over expenditures, we observed approximately ten instances where the required supporting documentation to support an expenditure was missing or unavailable. Furthermore, we observed one instance where an expenditure was incorrectly charged to a function and object code, was not budgeted for in related grant budget. Context/ Perspective: This finding is based on our statistically valid random sample of forty cash disbursements totaling $890,529 charged to major programs for single audit purposes and the conditions cited appear to be a systematic issue. Questioned Costs: Projected Questioned Costs: $1,323,439.41 - 84.425D/U – Elementary and Secondary School Emergency Relief $441,065.61 - 84.027/84.173 – Special Education Cluster (IDEA) $1,526.67 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Questioned Cost of Sampled Items: $35,425.09 - 84.425D/U – Elementary and Secondary School Emergency Relief $11,325.72 - 84.027/84.173 – Special Education Cluster (IDEA) $7.33 - 84.010A - Title I Grants To Local Educational Agencies (Title I, Part of the ESEA) Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to document its expenditures charged to federal grant programs. We also recommend that the District implement additional internal controls as necessary to ensure that expenditures are charged to the appropriate budget categories in the Mississippi Comprehensive Automated Performance-based System (MCAPS) of the District which is administered through the Mississippi Department of Education. Views of Responsible Officials: The Auditee’s Corrective Action Plan on pages 99-100 lists the District’s response to the findings.