Audit 331266

FY End
2024-06-30
Total Expended
$172.23M
Findings
6
Programs
26
Year: 2024 Accepted: 2024-12-06

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
513433 2024-002 Significant Deficiency - I
513434 2024-002 Significant Deficiency - I
513435 2024-002 Significant Deficiency - I
1089875 2024-002 Significant Deficiency - I
1089876 2024-002 Significant Deficiency - I
1089877 2024-002 Significant Deficiency - I

Programs

ALN Program Spent Major Findings
93.600 Head Start $11.78M - 0
10.553 School Breakfast Program $6.91M - 0
84.411 Education Innovation and Research (formerly Investing in Innovation (i3) Fund) $2.19M - 0
84.027 Special Education Grants to States $2.14M Yes 0
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $1.98M - 0
84.424 Student Support and Academic Enrichment Program $1.68M - 0
84.287 Twenty-First Century Community Learning Centers $1.59M - 0
10.558 Child and Adult Care Food Program $1.38M - 0
10.555 National School Lunch Program $1.28M - 0
84.184 School Safely National Activities $1.07M - 0
12.000 Rotc $870,445 - 0
10.582 Fresh Fruit and Vegetable Program $530,503 - 0
84.027 Covid-19 - Special Education Grants to States $481,605 Yes 0
84.010 Title I Grants to Local Educational Agencies $405,706 - 0
84.425 Covid-19 - Education Stabilization Fund $398,403 Yes 1
84.365 English Language Acquisition State Grants $341,117 - 0
84.002 Adult Education - Basic Grants to States $319,048 - 0
84.041 Impact Aid $112,102 - 0
84.196 Education for Homeless Children and Youth $109,843 - 0
97.030 Community Disaster Loans $84,653 - 0
84.173 Covid-19 - Special Education Preschool Grants $64,774 Yes 0
84.048 Career and Technical Education -- Basic Grants to States $64,054 - 0
10.579 Child Nutrition Discretionary Grants Limited Availability $62,660 - 0
84.011 Migrant Education State Grant Program $37,205 - 0
10.575 Farm to School Grant Program $35,058 - 0
84.173 Special Education Preschool Grants $22,668 Yes 0

Contacts

Name Title Type
DPD7S7LGFB53 Jessica Carraher Auditee
8435668198 Emily Sobczak Auditor
No contacts on file

Notes to SEFA

Accounting Policies: GENERAL: The accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) presents the activity of all federal award programs of Charleston County School District (the “School District”) for the year ended June 30, 2024. All federal awards received directly from the federal agencies, as well as those passed through other government agencies, are included on the Schedule. BASIS OF ACCOUNTING: The accompanying Schedule is presented using the modified accrual basis of accounting, which is described in the notes to the School District’s financial statements. RELATIONSHIP TO FINANCIAL STATEMENTS: Federal award expenditures are reported in the School District’s financial statements as expenditures in the General Fund, Special Revenue Fund and the Special Revenue – Food Service Fund. RELATIONSHIP TO FEDERAL FINANCIAL REPORTS: Amounts reported in the accompanying Schedule agree with the amounts reported in the related federal financial reports except for timing differences relating to expenditures made subsequent to the filing of the federal financial reports. SUB-RECIPIENTS: Of the federal expenditures presented in the accompanying schedule, the School District provided federal awards of $1,804,379 to sub-recipients from Title I, $1,065,406 from the IDEA cluster, and $80,605 from the ROTC program. De Minimis Rate Used: N Rate Explanation: The School District elected not to use the de minimis indirect cost rate of 10%.

Finding Details

CONDITION: The School District used local exemptions in procuring certain costs related to goods and services funded through the ESSER program. CRITERIA: The South Carolina Department of Education (“SDE”) had issued a memorandum (“Memorandum”) in August 2023 notifying school districts that local exemptions could not be used in procurement activities related to federal programs. If a school district wanted to use noncompetitive procurements, they would need to (a) meet the exceptions noted in this Memorandum and as more fully detailed in Office of Management and Budget (“OMB”) 2 CFR 200.320 or (b) request and receive an approved waiver from the SDE on the “Request for Noncompetitive Procurement Approval” form. CRITERIA, CONTEXT AND EFFECT: The Office of Management and Budget’s (“OMB”) 2024 compliance supplement did not list in the compliance matrix a requirement to test the “Procurement and Suspension and Debarment” compliance requirement for this program. However, the SDE required that this compliance requirement be tested. The School District followed its approved procurement code which allowed the use of local exemptions for certain procurement activities. The School District’s auditors tested approximately $1,748,000 in key items related to the ESSER program and noted no exceptions. The School District’s auditors tested a random sample of 27 other ESSER expenditures and noted three procurements totaling approximately $137,000 that were procured using local exemptions. This known noncompliance extrapolated to the remaining random population resulted in projected noncompliance of approximately $892,000. The actual known or likely questioned costs is not determinable – as it would be difference between the costs paid and the costs that would have been paid if the contracts were competitively bid. CAUSE: The School District was not fully aware that using its local exemptions as provided for in its procurement code was not allowable for federal procurements. RECOMMENDATION: We recommend that the School District ensure that procurements related to federal programs do not use local exemptions and that these procurements provide for full and open competition. RESPONSE: The School District agrees with this finding and will adhere to the corrective action plan on page 15 in this compliance report. The District discovered this issue prior to the end of the Fiscal Year and made adjustments to the Procurement process between the Office of Federal Programs and Financial Services which now follows the SCDE's accepted practice for federal funds.
CONDITION: The School District used local exemptions in procuring certain costs related to goods and services funded through the ESSER program. CRITERIA: The South Carolina Department of Education (“SDE”) had issued a memorandum (“Memorandum”) in August 2023 notifying school districts that local exemptions could not be used in procurement activities related to federal programs. If a school district wanted to use noncompetitive procurements, they would need to (a) meet the exceptions noted in this Memorandum and as more fully detailed in Office of Management and Budget (“OMB”) 2 CFR 200.320 or (b) request and receive an approved waiver from the SDE on the “Request for Noncompetitive Procurement Approval” form. CRITERIA, CONTEXT AND EFFECT: The Office of Management and Budget’s (“OMB”) 2024 compliance supplement did not list in the compliance matrix a requirement to test the “Procurement and Suspension and Debarment” compliance requirement for this program. However, the SDE required that this compliance requirement be tested. The School District followed its approved procurement code which allowed the use of local exemptions for certain procurement activities. The School District’s auditors tested approximately $1,748,000 in key items related to the ESSER program and noted no exceptions. The School District’s auditors tested a random sample of 27 other ESSER expenditures and noted three procurements totaling approximately $137,000 that were procured using local exemptions. This known noncompliance extrapolated to the remaining random population resulted in projected noncompliance of approximately $892,000. The actual known or likely questioned costs is not determinable – as it would be difference between the costs paid and the costs that would have been paid if the contracts were competitively bid. CAUSE: The School District was not fully aware that using its local exemptions as provided for in its procurement code was not allowable for federal procurements. RECOMMENDATION: We recommend that the School District ensure that procurements related to federal programs do not use local exemptions and that these procurements provide for full and open competition. RESPONSE: The School District agrees with this finding and will adhere to the corrective action plan on page 15 in this compliance report. The District discovered this issue prior to the end of the Fiscal Year and made adjustments to the Procurement process between the Office of Federal Programs and Financial Services which now follows the SCDE's accepted practice for federal funds.
CONDITION: The School District used local exemptions in procuring certain costs related to goods and services funded through the ESSER program. CRITERIA: The South Carolina Department of Education (“SDE”) had issued a memorandum (“Memorandum”) in August 2023 notifying school districts that local exemptions could not be used in procurement activities related to federal programs. If a school district wanted to use noncompetitive procurements, they would need to (a) meet the exceptions noted in this Memorandum and as more fully detailed in Office of Management and Budget (“OMB”) 2 CFR 200.320 or (b) request and receive an approved waiver from the SDE on the “Request for Noncompetitive Procurement Approval” form. CRITERIA, CONTEXT AND EFFECT: The Office of Management and Budget’s (“OMB”) 2024 compliance supplement did not list in the compliance matrix a requirement to test the “Procurement and Suspension and Debarment” compliance requirement for this program. However, the SDE required that this compliance requirement be tested. The School District followed its approved procurement code which allowed the use of local exemptions for certain procurement activities. The School District’s auditors tested approximately $1,748,000 in key items related to the ESSER program and noted no exceptions. The School District’s auditors tested a random sample of 27 other ESSER expenditures and noted three procurements totaling approximately $137,000 that were procured using local exemptions. This known noncompliance extrapolated to the remaining random population resulted in projected noncompliance of approximately $892,000. The actual known or likely questioned costs is not determinable – as it would be difference between the costs paid and the costs that would have been paid if the contracts were competitively bid. CAUSE: The School District was not fully aware that using its local exemptions as provided for in its procurement code was not allowable for federal procurements. RECOMMENDATION: We recommend that the School District ensure that procurements related to federal programs do not use local exemptions and that these procurements provide for full and open competition. RESPONSE: The School District agrees with this finding and will adhere to the corrective action plan on page 15 in this compliance report. The District discovered this issue prior to the end of the Fiscal Year and made adjustments to the Procurement process between the Office of Federal Programs and Financial Services which now follows the SCDE's accepted practice for federal funds.
CONDITION: The School District used local exemptions in procuring certain costs related to goods and services funded through the ESSER program. CRITERIA: The South Carolina Department of Education (“SDE”) had issued a memorandum (“Memorandum”) in August 2023 notifying school districts that local exemptions could not be used in procurement activities related to federal programs. If a school district wanted to use noncompetitive procurements, they would need to (a) meet the exceptions noted in this Memorandum and as more fully detailed in Office of Management and Budget (“OMB”) 2 CFR 200.320 or (b) request and receive an approved waiver from the SDE on the “Request for Noncompetitive Procurement Approval” form. CRITERIA, CONTEXT AND EFFECT: The Office of Management and Budget’s (“OMB”) 2024 compliance supplement did not list in the compliance matrix a requirement to test the “Procurement and Suspension and Debarment” compliance requirement for this program. However, the SDE required that this compliance requirement be tested. The School District followed its approved procurement code which allowed the use of local exemptions for certain procurement activities. The School District’s auditors tested approximately $1,748,000 in key items related to the ESSER program and noted no exceptions. The School District’s auditors tested a random sample of 27 other ESSER expenditures and noted three procurements totaling approximately $137,000 that were procured using local exemptions. This known noncompliance extrapolated to the remaining random population resulted in projected noncompliance of approximately $892,000. The actual known or likely questioned costs is not determinable – as it would be difference between the costs paid and the costs that would have been paid if the contracts were competitively bid. CAUSE: The School District was not fully aware that using its local exemptions as provided for in its procurement code was not allowable for federal procurements. RECOMMENDATION: We recommend that the School District ensure that procurements related to federal programs do not use local exemptions and that these procurements provide for full and open competition. RESPONSE: The School District agrees with this finding and will adhere to the corrective action plan on page 15 in this compliance report. The District discovered this issue prior to the end of the Fiscal Year and made adjustments to the Procurement process between the Office of Federal Programs and Financial Services which now follows the SCDE's accepted practice for federal funds.
CONDITION: The School District used local exemptions in procuring certain costs related to goods and services funded through the ESSER program. CRITERIA: The South Carolina Department of Education (“SDE”) had issued a memorandum (“Memorandum”) in August 2023 notifying school districts that local exemptions could not be used in procurement activities related to federal programs. If a school district wanted to use noncompetitive procurements, they would need to (a) meet the exceptions noted in this Memorandum and as more fully detailed in Office of Management and Budget (“OMB”) 2 CFR 200.320 or (b) request and receive an approved waiver from the SDE on the “Request for Noncompetitive Procurement Approval” form. CRITERIA, CONTEXT AND EFFECT: The Office of Management and Budget’s (“OMB”) 2024 compliance supplement did not list in the compliance matrix a requirement to test the “Procurement and Suspension and Debarment” compliance requirement for this program. However, the SDE required that this compliance requirement be tested. The School District followed its approved procurement code which allowed the use of local exemptions for certain procurement activities. The School District’s auditors tested approximately $1,748,000 in key items related to the ESSER program and noted no exceptions. The School District’s auditors tested a random sample of 27 other ESSER expenditures and noted three procurements totaling approximately $137,000 that were procured using local exemptions. This known noncompliance extrapolated to the remaining random population resulted in projected noncompliance of approximately $892,000. The actual known or likely questioned costs is not determinable – as it would be difference between the costs paid and the costs that would have been paid if the contracts were competitively bid. CAUSE: The School District was not fully aware that using its local exemptions as provided for in its procurement code was not allowable for federal procurements. RECOMMENDATION: We recommend that the School District ensure that procurements related to federal programs do not use local exemptions and that these procurements provide for full and open competition. RESPONSE: The School District agrees with this finding and will adhere to the corrective action plan on page 15 in this compliance report. The District discovered this issue prior to the end of the Fiscal Year and made adjustments to the Procurement process between the Office of Federal Programs and Financial Services which now follows the SCDE's accepted practice for federal funds.
CONDITION: The School District used local exemptions in procuring certain costs related to goods and services funded through the ESSER program. CRITERIA: The South Carolina Department of Education (“SDE”) had issued a memorandum (“Memorandum”) in August 2023 notifying school districts that local exemptions could not be used in procurement activities related to federal programs. If a school district wanted to use noncompetitive procurements, they would need to (a) meet the exceptions noted in this Memorandum and as more fully detailed in Office of Management and Budget (“OMB”) 2 CFR 200.320 or (b) request and receive an approved waiver from the SDE on the “Request for Noncompetitive Procurement Approval” form. CRITERIA, CONTEXT AND EFFECT: The Office of Management and Budget’s (“OMB”) 2024 compliance supplement did not list in the compliance matrix a requirement to test the “Procurement and Suspension and Debarment” compliance requirement for this program. However, the SDE required that this compliance requirement be tested. The School District followed its approved procurement code which allowed the use of local exemptions for certain procurement activities. The School District’s auditors tested approximately $1,748,000 in key items related to the ESSER program and noted no exceptions. The School District’s auditors tested a random sample of 27 other ESSER expenditures and noted three procurements totaling approximately $137,000 that were procured using local exemptions. This known noncompliance extrapolated to the remaining random population resulted in projected noncompliance of approximately $892,000. The actual known or likely questioned costs is not determinable – as it would be difference between the costs paid and the costs that would have been paid if the contracts were competitively bid. CAUSE: The School District was not fully aware that using its local exemptions as provided for in its procurement code was not allowable for federal procurements. RECOMMENDATION: We recommend that the School District ensure that procurements related to federal programs do not use local exemptions and that these procurements provide for full and open competition. RESPONSE: The School District agrees with this finding and will adhere to the corrective action plan on page 15 in this compliance report. The District discovered this issue prior to the end of the Fiscal Year and made adjustments to the Procurement process between the Office of Federal Programs and Financial Services which now follows the SCDE's accepted practice for federal funds.