Audit 344878

Information on the Federal Program :Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria : All service plans should be authorized by a designated individual with the appropriate experience or certification and accordingly be documented within the child's file. This authorization represents approval for the specific services indicated in the child's plan. The plan is considered authorized when the designated individual electronically locks the plan within CINC. Service plans should be maintained for children enrolled in programs and copies retained in accordance with the State of Maine's document retention policy. Condition Found : In consideration of prior year findings, CDS developed a prior year corrective action plan which addressed the importance of documenting the authorization of children's service plans by working to establish an acceptable time frame protocol for the time between the date a plan is written and the date the plan is locked. During our testing in the current year we noted several instances were noted in which a plan was unlocked or not locked within the acceptable timeframe. Additionally, it was noted that there were several instances of plans locked by unauthorized individuals. We noted the service plans were not properly maintained for 14 out of 40 children under the Part B program. We understand the individual plans are transferred to other school districts when children either age out or transfer districts, however copies of documentation is not retained by CDS for audit purposes. Context: A nonstatistical sample of 40 children was tested under the Part B program and a nonstatistical sample of 40 children was tested under the Part C program. Cause and Effect: Inconsistent controls and lack of available authorized staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created upon determination of the child's eligibility for services and others whereby modifications were made to the plan requiring the file to be re-approved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-002 and 2021-002 Recommendation: We continue to recommend CDS clearly communicate the acceptable time frame policy between the date a plan is written and the date the plan is locked. Furthermore, although program managers at the Regional Site levels are reviewing the unfinalized plan report from CINC on a regular basis, at the State level, we recommend that the quality assurance director continue to perform inspection of the unfinalized plan report from CINC on a regular basis to review the status of all unlocked plans beyond the established time and contact the Regional Sites as needed. In addition, we recommend that it is clearly communicated that individuals possess the appropriate qualifications to lock plans and that user access rights for locking plans be restricted to only those with the proper qualifications. Alternatively, if management determines that locking children’s plans may no longer be the most effective and efficient means of documenting approval, we recommend that another approach be determined and implemented. If so, we recommend that management consult with the database provider to consider feasibility of other options, such as implementing a field for electronic signature of the authorized individual, or auto-flow updates for plans pending approval. We also recommend management create a policy to maintain copies of documentation for students when they transition to another school district. We understand these documents follow the students to the new district, however this leaves CDS without proper support to undergo audits and other program reviews. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program :Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria : All service plans should be authorized by a designated individual with the appropriate experience or certification and accordingly be documented within the child's file. This authorization represents approval for the specific services indicated in the child's plan. The plan is considered authorized when the designated individual electronically locks the plan within CINC. Service plans should be maintained for children enrolled in programs and copies retained in accordance with the State of Maine's document retention policy. Condition Found : In consideration of prior year findings, CDS developed a prior year corrective action plan which addressed the importance of documenting the authorization of children's service plans by working to establish an acceptable time frame protocol for the time between the date a plan is written and the date the plan is locked. During our testing in the current year we noted several instances were noted in which a plan was unlocked or not locked within the acceptable timeframe. Additionally, it was noted that there were several instances of plans locked by unauthorized individuals. We noted the service plans were not properly maintained for 14 out of 40 children under the Part B program. We understand the individual plans are transferred to other school districts when children either age out or transfer districts, however copies of documentation is not retained by CDS for audit purposes. Context: A nonstatistical sample of 40 children was tested under the Part B program and a nonstatistical sample of 40 children was tested under the Part C program. Cause and Effect: Inconsistent controls and lack of available authorized staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created upon determination of the child's eligibility for services and others whereby modifications were made to the plan requiring the file to be re-approved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-002 and 2021-002 Recommendation: We continue to recommend CDS clearly communicate the acceptable time frame policy between the date a plan is written and the date the plan is locked. Furthermore, although program managers at the Regional Site levels are reviewing the unfinalized plan report from CINC on a regular basis, at the State level, we recommend that the quality assurance director continue to perform inspection of the unfinalized plan report from CINC on a regular basis to review the status of all unlocked plans beyond the established time and contact the Regional Sites as needed. In addition, we recommend that it is clearly communicated that individuals possess the appropriate qualifications to lock plans and that user access rights for locking plans be restricted to only those with the proper qualifications. Alternatively, if management determines that locking children’s plans may no longer be the most effective and efficient means of documenting approval, we recommend that another approach be determined and implemented. If so, we recommend that management consult with the database provider to consider feasibility of other options, such as implementing a field for electronic signature of the authorized individual, or auto-flow updates for plans pending approval. We also recommend management create a policy to maintain copies of documentation for students when they transition to another school district. We understand these documents follow the students to the new district, however this leaves CDS without proper support to undergo audits and other program reviews. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program :Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria : All service plans should be authorized by a designated individual with the appropriate experience or certification and accordingly be documented within the child's file. This authorization represents approval for the specific services indicated in the child's plan. The plan is considered authorized when the designated individual electronically locks the plan within CINC. Service plans should be maintained for children enrolled in programs and copies retained in accordance with the State of Maine's document retention policy. Condition Found : In consideration of prior year findings, CDS developed a prior year corrective action plan which addressed the importance of documenting the authorization of children's service plans by working to establish an acceptable time frame protocol for the time between the date a plan is written and the date the plan is locked. During our testing in the current year we noted several instances were noted in which a plan was unlocked or not locked within the acceptable timeframe. Additionally, it was noted that there were several instances of plans locked by unauthorized individuals. We noted the service plans were not properly maintained for 14 out of 40 children under the Part B program. We understand the individual plans are transferred to other school districts when children either age out or transfer districts, however copies of documentation is not retained by CDS for audit purposes. Context: A nonstatistical sample of 40 children was tested under the Part B program and a nonstatistical sample of 40 children was tested under the Part C program. Cause and Effect: Inconsistent controls and lack of available authorized staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created upon determination of the child's eligibility for services and others whereby modifications were made to the plan requiring the file to be re-approved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-002 and 2021-002 Recommendation: We continue to recommend CDS clearly communicate the acceptable time frame policy between the date a plan is written and the date the plan is locked. Furthermore, although program managers at the Regional Site levels are reviewing the unfinalized plan report from CINC on a regular basis, at the State level, we recommend that the quality assurance director continue to perform inspection of the unfinalized plan report from CINC on a regular basis to review the status of all unlocked plans beyond the established time and contact the Regional Sites as needed. In addition, we recommend that it is clearly communicated that individuals possess the appropriate qualifications to lock plans and that user access rights for locking plans be restricted to only those with the proper qualifications. Alternatively, if management determines that locking children’s plans may no longer be the most effective and efficient means of documenting approval, we recommend that another approach be determined and implemented. If so, we recommend that management consult with the database provider to consider feasibility of other options, such as implementing a field for electronic signature of the authorized individual, or auto-flow updates for plans pending approval. We also recommend management create a policy to maintain copies of documentation for students when they transition to another school district. We understand these documents follow the students to the new district, however this leaves CDS without proper support to undergo audits and other program reviews. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program :Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria : All service plans should be authorized by a designated individual with the appropriate experience or certification and accordingly be documented within the child's file. This authorization represents approval for the specific services indicated in the child's plan. The plan is considered authorized when the designated individual electronically locks the plan within CINC. Service plans should be maintained for children enrolled in programs and copies retained in accordance with the State of Maine's document retention policy. Condition Found : In consideration of prior year findings, CDS developed a prior year corrective action plan which addressed the importance of documenting the authorization of children's service plans by working to establish an acceptable time frame protocol for the time between the date a plan is written and the date the plan is locked. During our testing in the current year we noted several instances were noted in which a plan was unlocked or not locked within the acceptable timeframe. Additionally, it was noted that there were several instances of plans locked by unauthorized individuals. We noted the service plans were not properly maintained for 14 out of 40 children under the Part B program. We understand the individual plans are transferred to other school districts when children either age out or transfer districts, however copies of documentation is not retained by CDS for audit purposes. Context: A nonstatistical sample of 40 children was tested under the Part B program and a nonstatistical sample of 40 children was tested under the Part C program. Cause and Effect: Inconsistent controls and lack of available authorized staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created upon determination of the child's eligibility for services and others whereby modifications were made to the plan requiring the file to be re-approved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-002 and 2021-002 Recommendation: We continue to recommend CDS clearly communicate the acceptable time frame policy between the date a plan is written and the date the plan is locked. Furthermore, although program managers at the Regional Site levels are reviewing the unfinalized plan report from CINC on a regular basis, at the State level, we recommend that the quality assurance director continue to perform inspection of the unfinalized plan report from CINC on a regular basis to review the status of all unlocked plans beyond the established time and contact the Regional Sites as needed. In addition, we recommend that it is clearly communicated that individuals possess the appropriate qualifications to lock plans and that user access rights for locking plans be restricted to only those with the proper qualifications. Alternatively, if management determines that locking children’s plans may no longer be the most effective and efficient means of documenting approval, we recommend that another approach be determined and implemented. If so, we recommend that management consult with the database provider to consider feasibility of other options, such as implementing a field for electronic signature of the authorized individual, or auto-flow updates for plans pending approval. We also recommend management create a policy to maintain copies of documentation for students when they transition to another school district. We understand these documents follow the students to the new district, however this leaves CDS without proper support to undergo audits and other program reviews. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program :Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria : All service plans should be authorized by a designated individual with the appropriate experience or certification and accordingly be documented within the child's file. This authorization represents approval for the specific services indicated in the child's plan. The plan is considered authorized when the designated individual electronically locks the plan within CINC. Service plans should be maintained for children enrolled in programs and copies retained in accordance with the State of Maine's document retention policy. Condition Found : In consideration of prior year findings, CDS developed a prior year corrective action plan which addressed the importance of documenting the authorization of children's service plans by working to establish an acceptable time frame protocol for the time between the date a plan is written and the date the plan is locked. During our testing in the current year we noted several instances were noted in which a plan was unlocked or not locked within the acceptable timeframe. Additionally, it was noted that there were several instances of plans locked by unauthorized individuals. We noted the service plans were not properly maintained for 14 out of 40 children under the Part B program. We understand the individual plans are transferred to other school districts when children either age out or transfer districts, however copies of documentation is not retained by CDS for audit purposes. Context: A nonstatistical sample of 40 children was tested under the Part B program and a nonstatistical sample of 40 children was tested under the Part C program. Cause and Effect: Inconsistent controls and lack of available authorized staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created upon determination of the child's eligibility for services and others whereby modifications were made to the plan requiring the file to be re-approved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-002 and 2021-002 Recommendation: We continue to recommend CDS clearly communicate the acceptable time frame policy between the date a plan is written and the date the plan is locked. Furthermore, although program managers at the Regional Site levels are reviewing the unfinalized plan report from CINC on a regular basis, at the State level, we recommend that the quality assurance director continue to perform inspection of the unfinalized plan report from CINC on a regular basis to review the status of all unlocked plans beyond the established time and contact the Regional Sites as needed. In addition, we recommend that it is clearly communicated that individuals possess the appropriate qualifications to lock plans and that user access rights for locking plans be restricted to only those with the proper qualifications. Alternatively, if management determines that locking children’s plans may no longer be the most effective and efficient means of documenting approval, we recommend that another approach be determined and implemented. If so, we recommend that management consult with the database provider to consider feasibility of other options, such as implementing a field for electronic signature of the authorized individual, or auto-flow updates for plans pending approval. We also recommend management create a policy to maintain copies of documentation for students when they transition to another school district. We understand these documents follow the students to the new district, however this leaves CDS without proper support to undergo audits and other program reviews. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The consistency of the process of obtaining and inputting children’s financial information and the setting of the children’s services into CINC is a significant factor of the internal control structure for the CDS system to ensure that the appropriate payor is paying for the approved services and the appropriate service rate for the setting. Condition Found: In response to the fiscal year 2021 findings, CDS piloted a procedure at one of the regional sites, using a temporary employee to coordinate the "Authorization to Provide Services and Seek Payment" form and to use this form to verify the accuracy of payor information within children's plans. The goal of this pilot procedure was to increase the accuracy of payor information within CINC, as well as to implement a more consistent procedure for obtaining and updating of "Authorization to Provide Services and Seek Payment" forms. However, the temporary employee left during fiscal year 2022 and the pilot was discontinued. During our current year testing we noted 1 out of 40 students for Part B and 1 out of 40 students for Part C did not have the "Authorization to Provide Services and Seek Payment" forms maintained in their files, however, the child was set up as CINC as either MaineCare or Private Insurance. We further noted CDS did not maintain signed authorizations from parents or guardians granting permission for the students to participate in the evaluation and/or program. We noted these authorizations were not properly maintained for 4 out of 40 students under the Part B program and 13 out of 40 under the Part C program. The prior year finding also noted the setting for the children's services of specially designed instruction (SDI) was treated inconsistently across the Regional Sites. The prior year finding indicated the ratio of children to services providers was inconsistent within CINC and the children's plan. The prior year finding noted two instances of SDI 2:1 services that were listed in CINC as individual for the setting. Context: In testing the status prior year findings, we noted the related corrective action plan had not yet been fully implemented. Questioned Costs: None noted Cause and Effect: Inconsistent controls and lack of available qualified staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created at inception and others whereby modifications were made to the plan requiring the file to be reapproved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-003 and 2021-003 Recommendation: We recommend communicating a clear policy for when the form should be obtained and establishing a directive for Regional Site staff when it is not returned at the designated time. We also recommend communicating a clear policy surroudning the importance of obtaining and retaining the proper authorizations from parents and guardians to participate in the evaluation and/or program. Moreover, we recommend an employee at each Regional Site should be designated to run a report to show all plans that are missing the “Authorization to Provide Services and Seek Payment” forms and/or authorization forms to participate in services so that those forms can be addressed by the appropriate employee. Finally, we recommend that once financial and setting information has been entered into the responsible payor input and child’s plan in CINC, it be reviewed by another designated individual to ensure its accuracy. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The consistency of the process of obtaining and inputting children’s financial information and the setting of the children’s services into CINC is a significant factor of the internal control structure for the CDS system to ensure that the appropriate payor is paying for the approved services and the appropriate service rate for the setting. Condition Found: In response to the fiscal year 2021 findings, CDS piloted a procedure at one of the regional sites, using a temporary employee to coordinate the "Authorization to Provide Services and Seek Payment" form and to use this form to verify the accuracy of payor information within children's plans. The goal of this pilot procedure was to increase the accuracy of payor information within CINC, as well as to implement a more consistent procedure for obtaining and updating of "Authorization to Provide Services and Seek Payment" forms. However, the temporary employee left during fiscal year 2022 and the pilot was discontinued. During our current year testing we noted 1 out of 40 students for Part B and 1 out of 40 students for Part C did not have the "Authorization to Provide Services and Seek Payment" forms maintained in their files, however, the child was set up as CINC as either MaineCare or Private Insurance. We further noted CDS did not maintain signed authorizations from parents or guardians granting permission for the students to participate in the evaluation and/or program. We noted these authorizations were not properly maintained for 4 out of 40 students under the Part B program and 13 out of 40 under the Part C program. The prior year finding also noted the setting for the children's services of specially designed instruction (SDI) was treated inconsistently across the Regional Sites. The prior year finding indicated the ratio of children to services providers was inconsistent within CINC and the children's plan. The prior year finding noted two instances of SDI 2:1 services that were listed in CINC as individual for the setting. Context: In testing the status prior year findings, we noted the related corrective action plan had not yet been fully implemented. Questioned Costs: None noted Cause and Effect: Inconsistent controls and lack of available qualified staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created at inception and others whereby modifications were made to the plan requiring the file to be reapproved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-003 and 2021-003 Recommendation: We recommend communicating a clear policy for when the form should be obtained and establishing a directive for Regional Site staff when it is not returned at the designated time. We also recommend communicating a clear policy surroudning the importance of obtaining and retaining the proper authorizations from parents and guardians to participate in the evaluation and/or program. Moreover, we recommend an employee at each Regional Site should be designated to run a report to show all plans that are missing the “Authorization to Provide Services and Seek Payment” forms and/or authorization forms to participate in services so that those forms can be addressed by the appropriate employee. Finally, we recommend that once financial and setting information has been entered into the responsible payor input and child’s plan in CINC, it be reviewed by another designated individual to ensure its accuracy. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The consistency of the process of obtaining and inputting children’s financial information and the setting of the children’s services into CINC is a significant factor of the internal control structure for the CDS system to ensure that the appropriate payor is paying for the approved services and the appropriate service rate for the setting. Condition Found: In response to the fiscal year 2021 findings, CDS piloted a procedure at one of the regional sites, using a temporary employee to coordinate the "Authorization to Provide Services and Seek Payment" form and to use this form to verify the accuracy of payor information within children's plans. The goal of this pilot procedure was to increase the accuracy of payor information within CINC, as well as to implement a more consistent procedure for obtaining and updating of "Authorization to Provide Services and Seek Payment" forms. However, the temporary employee left during fiscal year 2022 and the pilot was discontinued. During our current year testing we noted 1 out of 40 students for Part B and 1 out of 40 students for Part C did not have the "Authorization to Provide Services and Seek Payment" forms maintained in their files, however, the child was set up as CINC as either MaineCare or Private Insurance. We further noted CDS did not maintain signed authorizations from parents or guardians granting permission for the students to participate in the evaluation and/or program. We noted these authorizations were not properly maintained for 4 out of 40 students under the Part B program and 13 out of 40 under the Part C program. The prior year finding also noted the setting for the children's services of specially designed instruction (SDI) was treated inconsistently across the Regional Sites. The prior year finding indicated the ratio of children to services providers was inconsistent within CINC and the children's plan. The prior year finding noted two instances of SDI 2:1 services that were listed in CINC as individual for the setting. Context: In testing the status prior year findings, we noted the related corrective action plan had not yet been fully implemented. Questioned Costs: None noted Cause and Effect: Inconsistent controls and lack of available qualified staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created at inception and others whereby modifications were made to the plan requiring the file to be reapproved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-003 and 2021-003 Recommendation: We recommend communicating a clear policy for when the form should be obtained and establishing a directive for Regional Site staff when it is not returned at the designated time. We also recommend communicating a clear policy surroudning the importance of obtaining and retaining the proper authorizations from parents and guardians to participate in the evaluation and/or program. Moreover, we recommend an employee at each Regional Site should be designated to run a report to show all plans that are missing the “Authorization to Provide Services and Seek Payment” forms and/or authorization forms to participate in services so that those forms can be addressed by the appropriate employee. Finally, we recommend that once financial and setting information has been entered into the responsible payor input and child’s plan in CINC, it be reviewed by another designated individual to ensure its accuracy. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The consistency of the process of obtaining and inputting children’s financial information and the setting of the children’s services into CINC is a significant factor of the internal control structure for the CDS system to ensure that the appropriate payor is paying for the approved services and the appropriate service rate for the setting. Condition Found: In response to the fiscal year 2021 findings, CDS piloted a procedure at one of the regional sites, using a temporary employee to coordinate the "Authorization to Provide Services and Seek Payment" form and to use this form to verify the accuracy of payor information within children's plans. The goal of this pilot procedure was to increase the accuracy of payor information within CINC, as well as to implement a more consistent procedure for obtaining and updating of "Authorization to Provide Services and Seek Payment" forms. However, the temporary employee left during fiscal year 2022 and the pilot was discontinued. During our current year testing we noted 1 out of 40 students for Part B and 1 out of 40 students for Part C did not have the "Authorization to Provide Services and Seek Payment" forms maintained in their files, however, the child was set up as CINC as either MaineCare or Private Insurance. We further noted CDS did not maintain signed authorizations from parents or guardians granting permission for the students to participate in the evaluation and/or program. We noted these authorizations were not properly maintained for 4 out of 40 students under the Part B program and 13 out of 40 under the Part C program. The prior year finding also noted the setting for the children's services of specially designed instruction (SDI) was treated inconsistently across the Regional Sites. The prior year finding indicated the ratio of children to services providers was inconsistent within CINC and the children's plan. The prior year finding noted two instances of SDI 2:1 services that were listed in CINC as individual for the setting. Context: In testing the status prior year findings, we noted the related corrective action plan had not yet been fully implemented. Questioned Costs: None noted Cause and Effect: Inconsistent controls and lack of available qualified staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created at inception and others whereby modifications were made to the plan requiring the file to be reapproved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-003 and 2021-003 Recommendation: We recommend communicating a clear policy for when the form should be obtained and establishing a directive for Regional Site staff when it is not returned at the designated time. We also recommend communicating a clear policy surroudning the importance of obtaining and retaining the proper authorizations from parents and guardians to participate in the evaluation and/or program. Moreover, we recommend an employee at each Regional Site should be designated to run a report to show all plans that are missing the “Authorization to Provide Services and Seek Payment” forms and/or authorization forms to participate in services so that those forms can be addressed by the appropriate employee. Finally, we recommend that once financial and setting information has been entered into the responsible payor input and child’s plan in CINC, it be reviewed by another designated individual to ensure its accuracy. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The consistency of the process of obtaining and inputting children’s financial information and the setting of the children’s services into CINC is a significant factor of the internal control structure for the CDS system to ensure that the appropriate payor is paying for the approved services and the appropriate service rate for the setting. Condition Found: In response to the fiscal year 2021 findings, CDS piloted a procedure at one of the regional sites, using a temporary employee to coordinate the "Authorization to Provide Services and Seek Payment" form and to use this form to verify the accuracy of payor information within children's plans. The goal of this pilot procedure was to increase the accuracy of payor information within CINC, as well as to implement a more consistent procedure for obtaining and updating of "Authorization to Provide Services and Seek Payment" forms. However, the temporary employee left during fiscal year 2022 and the pilot was discontinued. During our current year testing we noted 1 out of 40 students for Part B and 1 out of 40 students for Part C did not have the "Authorization to Provide Services and Seek Payment" forms maintained in their files, however, the child was set up as CINC as either MaineCare or Private Insurance. We further noted CDS did not maintain signed authorizations from parents or guardians granting permission for the students to participate in the evaluation and/or program. We noted these authorizations were not properly maintained for 4 out of 40 students under the Part B program and 13 out of 40 under the Part C program. The prior year finding also noted the setting for the children's services of specially designed instruction (SDI) was treated inconsistently across the Regional Sites. The prior year finding indicated the ratio of children to services providers was inconsistent within CINC and the children's plan. The prior year finding noted two instances of SDI 2:1 services that were listed in CINC as individual for the setting. Context: In testing the status prior year findings, we noted the related corrective action plan had not yet been fully implemented. Questioned Costs: None noted Cause and Effect: Inconsistent controls and lack of available qualified staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created at inception and others whereby modifications were made to the plan requiring the file to be reapproved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-003 and 2021-003 Recommendation: We recommend communicating a clear policy for when the form should be obtained and establishing a directive for Regional Site staff when it is not returned at the designated time. We also recommend communicating a clear policy surroudning the importance of obtaining and retaining the proper authorizations from parents and guardians to participate in the evaluation and/or program. Moreover, we recommend an employee at each Regional Site should be designated to run a report to show all plans that are missing the “Authorization to Provide Services and Seek Payment” forms and/or authorization forms to participate in services so that those forms can be addressed by the appropriate employee. Finally, we recommend that once financial and setting information has been entered into the responsible payor input and child’s plan in CINC, it be reviewed by another designated individual to ensure its accuracy. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted the Organization did not review the SAM for contractors, vendors and employees meeting the covered transaction threshold. Context: Based on our testing, we noted that while none of the sample of vendors and employees tested grant were included in the SAM listing, the Organization did not perform a review of vendors, contractors or employees charged to this specific grant. Questioned Costs: None noted Cause and Effect: The Organization was unaware of the requirement to verify employees and vendors against the SAM, therefore, the SAM was not checked prior to payments being made. This results in an increased risk that payments under grant agreements may in appropriately made to excluded parties. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. We also recommend the Organization implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted the Organization did not review the SAM for contractors, vendors and employees meeting the covered transaction threshold. Context: Based on our testing, we noted that while none of the sample of vendors and employees tested grant were included in the SAM listing, the Organization did not perform a review of vendors, contractors or employees charged to this specific grant. Questioned Costs: None noted Cause and Effect: The Organization was unaware of the requirement to verify employees and vendors against the SAM, therefore, the SAM was not checked prior to payments being made. This results in an increased risk that payments under grant agreements may in appropriately made to excluded parties. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. We also recommend the Organization implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted the Organization did not review the SAM for contractors, vendors and employees meeting the covered transaction threshold. Context: Based on our testing, we noted that while none of the sample of vendors and employees tested grant were included in the SAM listing, the Organization did not perform a review of vendors, contractors or employees charged to this specific grant. Questioned Costs: None noted Cause and Effect: The Organization was unaware of the requirement to verify employees and vendors against the SAM, therefore, the SAM was not checked prior to payments being made. This results in an increased risk that payments under grant agreements may in appropriately made to excluded parties. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. We also recommend the Organization implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted the Organization did not review the SAM for contractors, vendors and employees meeting the covered transaction threshold. Context: Based on our testing, we noted that while none of the sample of vendors and employees tested grant were included in the SAM listing, the Organization did not perform a review of vendors, contractors or employees charged to this specific grant. Questioned Costs: None noted Cause and Effect: The Organization was unaware of the requirement to verify employees and vendors against the SAM, therefore, the SAM was not checked prior to payments being made. This results in an increased risk that payments under grant agreements may in appropriately made to excluded parties. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. We also recommend the Organization implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted the Organization did not review the SAM for contractors, vendors and employees meeting the covered transaction threshold. Context: Based on our testing, we noted that while none of the sample of vendors and employees tested grant were included in the SAM listing, the Organization did not perform a review of vendors, contractors or employees charged to this specific grant. Questioned Costs: None noted Cause and Effect: The Organization was unaware of the requirement to verify employees and vendors against the SAM, therefore, the SAM was not checked prior to payments being made. This results in an increased risk that payments under grant agreements may in appropriately made to excluded parties. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. We also recommend the Organization implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted the Organization did not review the SAM for contractors, vendors and employees meeting the covered transaction threshold. Context: Based on our testing, we noted that while none of the sample of vendors and employees tested grant were included in the SAM listing, the Organization did not perform a review of vendors, contractors or employees charged to this specific grant. Questioned Costs: None noted Cause and Effect: The Organization was unaware of the requirement to verify employees and vendors against the SAM, therefore, the SAM was not checked prior to payments being made. This results in an increased risk that payments under grant agreements may in appropriately made to excluded parties. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. We also recommend the Organization implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The cost principles in 2 CFR, Part 200, Subpart E (Cost Principles) are required for the administration of federal awards of Nonprofit organizations. Condition Found: During our audit we noted the Organization had served children under the grant program that did not meet the activities allowable under the grant as follows: - For one child tested, we were unable to verify if the services provided were documented in the CINC service logs were allowable activities under the grant. Context: Of the nonstatistical sample of 40 children tested under the Part B program, one child served did not have adequate documentation retained supporting an allowable activity in line with the grant requirements. Questioned Costs: None noted. Cause and Effect: The Organization was unaware of the Allowable Costs and Cost Principles requirements as to the requirements of the Part B program. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to review all child files and service logs charged to the Part B program to verify the services performed within the notes were properly documented and the activities are allowable under grant requirements. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The cost principles in 2 CFR, Part 200, Subpart E (Cost Principles) are required for the administration of federal awards of Nonprofit organizations. Condition Found: During our audit we noted the Organization had served children under the grant program that did not meet the activities allowable under the grant as follows: - For one child tested, we were unable to verify if the services provided were documented in the CINC service logs were allowable activities under the grant. Context: Of the nonstatistical sample of 40 children tested under the Part B program, one child served did not have adequate documentation retained supporting an allowable activity in line with the grant requirements. Questioned Costs: None noted. Cause and Effect: The Organization was unaware of the Allowable Costs and Cost Principles requirements as to the requirements of the Part B program. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to review all child files and service logs charged to the Part B program to verify the services performed within the notes were properly documented and the activities are allowable under grant requirements. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The cost principles in 2 CFR, Part 200, Subpart E (Cost Principles) are required for the administration of federal awards of Nonprofit organizations. Condition Found: During our audit we noted the Organization had served children under the grant program that did not meet the activities allowable under the grant as follows: - For one child tested, we were unable to verify if the services provided were documented in the CINC service logs were allowable activities under the grant. Context: Of the nonstatistical sample of 40 children tested under the Part B program, one child served did not have adequate documentation retained supporting an allowable activity in line with the grant requirements. Questioned Costs: None noted. Cause and Effect: The Organization was unaware of the Allowable Costs and Cost Principles requirements as to the requirements of the Part B program. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to review all child files and service logs charged to the Part B program to verify the services performed within the notes were properly documented and the activities are allowable under grant requirements. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The cost principles in 2 CFR, Part 200, Subpart E (Cost Principles) are required for the administration of federal awards of Nonprofit organizations. Condition Found: During our audit we noted the Organization had served children under the grant program that did not meet the activities allowable under the grant as follows: - For one child tested, we were unable to verify if the services provided were documented in the CINC service logs were allowable activities under the grant. Context: Of the nonstatistical sample of 40 children tested under the Part B program, one child served did not have adequate documentation retained supporting an allowable activity in line with the grant requirements. Questioned Costs: None noted. Cause and Effect: The Organization was unaware of the Allowable Costs and Cost Principles requirements as to the requirements of the Part B program. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to review all child files and service logs charged to the Part B program to verify the services performed within the notes were properly documented and the activities are allowable under grant requirements. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Finding Number: 2023-013 Information on the Federal Program Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: The cost principles in 2 CFR, Part 200, Subpart E (Cost Principles) are required for the administration of federal awards. Condition Found: During our audit of allowable costs, we noted the Organization had service costs charged to the grant for which they were unable to provide verifiable support for the costs or activities. Specifically: - The sample included six expenditures charged to the grant by journal entry for which the Organization was unable to provide supporting documentation. - The sample tested included five disbursements for which the Organization was unable to provide invoices to support the transactions. Context: A nonstatistical sample of forty expenditures under the ARP ESSER Grant were selected for testing, of which eleven transactions could not be supported to determine if they were consistent with the Cost Principles. Questioned Costs: $237,328 Cause and Effect: The Organization was unaware of the Allowable Costs and Cost Principles requirements as to the expenditures charged to the grant. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement and monitor a process to retain documentation for all transactions and journal entries charged to the grants to support allowable costs under the Federal Cost Principles. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program :Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria : All service plans should be authorized by a designated individual with the appropriate experience or certification and accordingly be documented within the child's file. This authorization represents approval for the specific services indicated in the child's plan. The plan is considered authorized when the designated individual electronically locks the plan within CINC. Service plans should be maintained for children enrolled in programs and copies retained in accordance with the State of Maine's document retention policy. Condition Found : In consideration of prior year findings, CDS developed a prior year corrective action plan which addressed the importance of documenting the authorization of children's service plans by working to establish an acceptable time frame protocol for the time between the date a plan is written and the date the plan is locked. During our testing in the current year we noted several instances were noted in which a plan was unlocked or not locked within the acceptable timeframe. Additionally, it was noted that there were several instances of plans locked by unauthorized individuals. We noted the service plans were not properly maintained for 14 out of 40 children under the Part B program. We understand the individual plans are transferred to other school districts when children either age out or transfer districts, however copies of documentation is not retained by CDS for audit purposes. Context: A nonstatistical sample of 40 children was tested under the Part B program and a nonstatistical sample of 40 children was tested under the Part C program. Cause and Effect: Inconsistent controls and lack of available authorized staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created upon determination of the child's eligibility for services and others whereby modifications were made to the plan requiring the file to be re-approved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-002 and 2021-002 Recommendation: We continue to recommend CDS clearly communicate the acceptable time frame policy between the date a plan is written and the date the plan is locked. Furthermore, although program managers at the Regional Site levels are reviewing the unfinalized plan report from CINC on a regular basis, at the State level, we recommend that the quality assurance director continue to perform inspection of the unfinalized plan report from CINC on a regular basis to review the status of all unlocked plans beyond the established time and contact the Regional Sites as needed. In addition, we recommend that it is clearly communicated that individuals possess the appropriate qualifications to lock plans and that user access rights for locking plans be restricted to only those with the proper qualifications. Alternatively, if management determines that locking children’s plans may no longer be the most effective and efficient means of documenting approval, we recommend that another approach be determined and implemented. If so, we recommend that management consult with the database provider to consider feasibility of other options, such as implementing a field for electronic signature of the authorized individual, or auto-flow updates for plans pending approval. We also recommend management create a policy to maintain copies of documentation for students when they transition to another school district. We understand these documents follow the students to the new district, however this leaves CDS without proper support to undergo audits and other program reviews. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program :Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria : All service plans should be authorized by a designated individual with the appropriate experience or certification and accordingly be documented within the child's file. This authorization represents approval for the specific services indicated in the child's plan. The plan is considered authorized when the designated individual electronically locks the plan within CINC. Service plans should be maintained for children enrolled in programs and copies retained in accordance with the State of Maine's document retention policy. Condition Found : In consideration of prior year findings, CDS developed a prior year corrective action plan which addressed the importance of documenting the authorization of children's service plans by working to establish an acceptable time frame protocol for the time between the date a plan is written and the date the plan is locked. During our testing in the current year we noted several instances were noted in which a plan was unlocked or not locked within the acceptable timeframe. Additionally, it was noted that there were several instances of plans locked by unauthorized individuals. We noted the service plans were not properly maintained for 14 out of 40 children under the Part B program. We understand the individual plans are transferred to other school districts when children either age out or transfer districts, however copies of documentation is not retained by CDS for audit purposes. Context: A nonstatistical sample of 40 children was tested under the Part B program and a nonstatistical sample of 40 children was tested under the Part C program. Cause and Effect: Inconsistent controls and lack of available authorized staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created upon determination of the child's eligibility for services and others whereby modifications were made to the plan requiring the file to be re-approved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-002 and 2021-002 Recommendation: We continue to recommend CDS clearly communicate the acceptable time frame policy between the date a plan is written and the date the plan is locked. Furthermore, although program managers at the Regional Site levels are reviewing the unfinalized plan report from CINC on a regular basis, at the State level, we recommend that the quality assurance director continue to perform inspection of the unfinalized plan report from CINC on a regular basis to review the status of all unlocked plans beyond the established time and contact the Regional Sites as needed. In addition, we recommend that it is clearly communicated that individuals possess the appropriate qualifications to lock plans and that user access rights for locking plans be restricted to only those with the proper qualifications. Alternatively, if management determines that locking children’s plans may no longer be the most effective and efficient means of documenting approval, we recommend that another approach be determined and implemented. If so, we recommend that management consult with the database provider to consider feasibility of other options, such as implementing a field for electronic signature of the authorized individual, or auto-flow updates for plans pending approval. We also recommend management create a policy to maintain copies of documentation for students when they transition to another school district. We understand these documents follow the students to the new district, however this leaves CDS without proper support to undergo audits and other program reviews. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program :Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria : All service plans should be authorized by a designated individual with the appropriate experience or certification and accordingly be documented within the child's file. This authorization represents approval for the specific services indicated in the child's plan. The plan is considered authorized when the designated individual electronically locks the plan within CINC. Service plans should be maintained for children enrolled in programs and copies retained in accordance with the State of Maine's document retention policy. Condition Found : In consideration of prior year findings, CDS developed a prior year corrective action plan which addressed the importance of documenting the authorization of children's service plans by working to establish an acceptable time frame protocol for the time between the date a plan is written and the date the plan is locked. During our testing in the current year we noted several instances were noted in which a plan was unlocked or not locked within the acceptable timeframe. Additionally, it was noted that there were several instances of plans locked by unauthorized individuals. We noted the service plans were not properly maintained for 14 out of 40 children under the Part B program. We understand the individual plans are transferred to other school districts when children either age out or transfer districts, however copies of documentation is not retained by CDS for audit purposes. Context: A nonstatistical sample of 40 children was tested under the Part B program and a nonstatistical sample of 40 children was tested under the Part C program. Cause and Effect: Inconsistent controls and lack of available authorized staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created upon determination of the child's eligibility for services and others whereby modifications were made to the plan requiring the file to be re-approved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-002 and 2021-002 Recommendation: We continue to recommend CDS clearly communicate the acceptable time frame policy between the date a plan is written and the date the plan is locked. Furthermore, although program managers at the Regional Site levels are reviewing the unfinalized plan report from CINC on a regular basis, at the State level, we recommend that the quality assurance director continue to perform inspection of the unfinalized plan report from CINC on a regular basis to review the status of all unlocked plans beyond the established time and contact the Regional Sites as needed. In addition, we recommend that it is clearly communicated that individuals possess the appropriate qualifications to lock plans and that user access rights for locking plans be restricted to only those with the proper qualifications. Alternatively, if management determines that locking children’s plans may no longer be the most effective and efficient means of documenting approval, we recommend that another approach be determined and implemented. If so, we recommend that management consult with the database provider to consider feasibility of other options, such as implementing a field for electronic signature of the authorized individual, or auto-flow updates for plans pending approval. We also recommend management create a policy to maintain copies of documentation for students when they transition to another school district. We understand these documents follow the students to the new district, however this leaves CDS without proper support to undergo audits and other program reviews. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program :Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria : All service plans should be authorized by a designated individual with the appropriate experience or certification and accordingly be documented within the child's file. This authorization represents approval for the specific services indicated in the child's plan. The plan is considered authorized when the designated individual electronically locks the plan within CINC. Service plans should be maintained for children enrolled in programs and copies retained in accordance with the State of Maine's document retention policy. Condition Found : In consideration of prior year findings, CDS developed a prior year corrective action plan which addressed the importance of documenting the authorization of children's service plans by working to establish an acceptable time frame protocol for the time between the date a plan is written and the date the plan is locked. During our testing in the current year we noted several instances were noted in which a plan was unlocked or not locked within the acceptable timeframe. Additionally, it was noted that there were several instances of plans locked by unauthorized individuals. We noted the service plans were not properly maintained for 14 out of 40 children under the Part B program. We understand the individual plans are transferred to other school districts when children either age out or transfer districts, however copies of documentation is not retained by CDS for audit purposes. Context: A nonstatistical sample of 40 children was tested under the Part B program and a nonstatistical sample of 40 children was tested under the Part C program. Cause and Effect: Inconsistent controls and lack of available authorized staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created upon determination of the child's eligibility for services and others whereby modifications were made to the plan requiring the file to be re-approved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-002 and 2021-002 Recommendation: We continue to recommend CDS clearly communicate the acceptable time frame policy between the date a plan is written and the date the plan is locked. Furthermore, although program managers at the Regional Site levels are reviewing the unfinalized plan report from CINC on a regular basis, at the State level, we recommend that the quality assurance director continue to perform inspection of the unfinalized plan report from CINC on a regular basis to review the status of all unlocked plans beyond the established time and contact the Regional Sites as needed. In addition, we recommend that it is clearly communicated that individuals possess the appropriate qualifications to lock plans and that user access rights for locking plans be restricted to only those with the proper qualifications. Alternatively, if management determines that locking children’s plans may no longer be the most effective and efficient means of documenting approval, we recommend that another approach be determined and implemented. If so, we recommend that management consult with the database provider to consider feasibility of other options, such as implementing a field for electronic signature of the authorized individual, or auto-flow updates for plans pending approval. We also recommend management create a policy to maintain copies of documentation for students when they transition to another school district. We understand these documents follow the students to the new district, however this leaves CDS without proper support to undergo audits and other program reviews. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program :Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria : All service plans should be authorized by a designated individual with the appropriate experience or certification and accordingly be documented within the child's file. This authorization represents approval for the specific services indicated in the child's plan. The plan is considered authorized when the designated individual electronically locks the plan within CINC. Service plans should be maintained for children enrolled in programs and copies retained in accordance with the State of Maine's document retention policy. Condition Found : In consideration of prior year findings, CDS developed a prior year corrective action plan which addressed the importance of documenting the authorization of children's service plans by working to establish an acceptable time frame protocol for the time between the date a plan is written and the date the plan is locked. During our testing in the current year we noted several instances were noted in which a plan was unlocked or not locked within the acceptable timeframe. Additionally, it was noted that there were several instances of plans locked by unauthorized individuals. We noted the service plans were not properly maintained for 14 out of 40 children under the Part B program. We understand the individual plans are transferred to other school districts when children either age out or transfer districts, however copies of documentation is not retained by CDS for audit purposes. Context: A nonstatistical sample of 40 children was tested under the Part B program and a nonstatistical sample of 40 children was tested under the Part C program. Cause and Effect: Inconsistent controls and lack of available authorized staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created upon determination of the child's eligibility for services and others whereby modifications were made to the plan requiring the file to be re-approved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-002 and 2021-002 Recommendation: We continue to recommend CDS clearly communicate the acceptable time frame policy between the date a plan is written and the date the plan is locked. Furthermore, although program managers at the Regional Site levels are reviewing the unfinalized plan report from CINC on a regular basis, at the State level, we recommend that the quality assurance director continue to perform inspection of the unfinalized plan report from CINC on a regular basis to review the status of all unlocked plans beyond the established time and contact the Regional Sites as needed. In addition, we recommend that it is clearly communicated that individuals possess the appropriate qualifications to lock plans and that user access rights for locking plans be restricted to only those with the proper qualifications. Alternatively, if management determines that locking children’s plans may no longer be the most effective and efficient means of documenting approval, we recommend that another approach be determined and implemented. If so, we recommend that management consult with the database provider to consider feasibility of other options, such as implementing a field for electronic signature of the authorized individual, or auto-flow updates for plans pending approval. We also recommend management create a policy to maintain copies of documentation for students when they transition to another school district. We understand these documents follow the students to the new district, however this leaves CDS without proper support to undergo audits and other program reviews. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The consistency of the process of obtaining and inputting children’s financial information and the setting of the children’s services into CINC is a significant factor of the internal control structure for the CDS system to ensure that the appropriate payor is paying for the approved services and the appropriate service rate for the setting. Condition Found: In response to the fiscal year 2021 findings, CDS piloted a procedure at one of the regional sites, using a temporary employee to coordinate the "Authorization to Provide Services and Seek Payment" form and to use this form to verify the accuracy of payor information within children's plans. The goal of this pilot procedure was to increase the accuracy of payor information within CINC, as well as to implement a more consistent procedure for obtaining and updating of "Authorization to Provide Services and Seek Payment" forms. However, the temporary employee left during fiscal year 2022 and the pilot was discontinued. During our current year testing we noted 1 out of 40 students for Part B and 1 out of 40 students for Part C did not have the "Authorization to Provide Services and Seek Payment" forms maintained in their files, however, the child was set up as CINC as either MaineCare or Private Insurance. We further noted CDS did not maintain signed authorizations from parents or guardians granting permission for the students to participate in the evaluation and/or program. We noted these authorizations were not properly maintained for 4 out of 40 students under the Part B program and 13 out of 40 under the Part C program. The prior year finding also noted the setting for the children's services of specially designed instruction (SDI) was treated inconsistently across the Regional Sites. The prior year finding indicated the ratio of children to services providers was inconsistent within CINC and the children's plan. The prior year finding noted two instances of SDI 2:1 services that were listed in CINC as individual for the setting. Context: In testing the status prior year findings, we noted the related corrective action plan had not yet been fully implemented. Questioned Costs: None noted Cause and Effect: Inconsistent controls and lack of available qualified staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created at inception and others whereby modifications were made to the plan requiring the file to be reapproved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-003 and 2021-003 Recommendation: We recommend communicating a clear policy for when the form should be obtained and establishing a directive for Regional Site staff when it is not returned at the designated time. We also recommend communicating a clear policy surroudning the importance of obtaining and retaining the proper authorizations from parents and guardians to participate in the evaluation and/or program. Moreover, we recommend an employee at each Regional Site should be designated to run a report to show all plans that are missing the “Authorization to Provide Services and Seek Payment” forms and/or authorization forms to participate in services so that those forms can be addressed by the appropriate employee. Finally, we recommend that once financial and setting information has been entered into the responsible payor input and child’s plan in CINC, it be reviewed by another designated individual to ensure its accuracy. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The consistency of the process of obtaining and inputting children’s financial information and the setting of the children’s services into CINC is a significant factor of the internal control structure for the CDS system to ensure that the appropriate payor is paying for the approved services and the appropriate service rate for the setting. Condition Found: In response to the fiscal year 2021 findings, CDS piloted a procedure at one of the regional sites, using a temporary employee to coordinate the "Authorization to Provide Services and Seek Payment" form and to use this form to verify the accuracy of payor information within children's plans. The goal of this pilot procedure was to increase the accuracy of payor information within CINC, as well as to implement a more consistent procedure for obtaining and updating of "Authorization to Provide Services and Seek Payment" forms. However, the temporary employee left during fiscal year 2022 and the pilot was discontinued. During our current year testing we noted 1 out of 40 students for Part B and 1 out of 40 students for Part C did not have the "Authorization to Provide Services and Seek Payment" forms maintained in their files, however, the child was set up as CINC as either MaineCare or Private Insurance. We further noted CDS did not maintain signed authorizations from parents or guardians granting permission for the students to participate in the evaluation and/or program. We noted these authorizations were not properly maintained for 4 out of 40 students under the Part B program and 13 out of 40 under the Part C program. The prior year finding also noted the setting for the children's services of specially designed instruction (SDI) was treated inconsistently across the Regional Sites. The prior year finding indicated the ratio of children to services providers was inconsistent within CINC and the children's plan. The prior year finding noted two instances of SDI 2:1 services that were listed in CINC as individual for the setting. Context: In testing the status prior year findings, we noted the related corrective action plan had not yet been fully implemented. Questioned Costs: None noted Cause and Effect: Inconsistent controls and lack of available qualified staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created at inception and others whereby modifications were made to the plan requiring the file to be reapproved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-003 and 2021-003 Recommendation: We recommend communicating a clear policy for when the form should be obtained and establishing a directive for Regional Site staff when it is not returned at the designated time. We also recommend communicating a clear policy surroudning the importance of obtaining and retaining the proper authorizations from parents and guardians to participate in the evaluation and/or program. Moreover, we recommend an employee at each Regional Site should be designated to run a report to show all plans that are missing the “Authorization to Provide Services and Seek Payment” forms and/or authorization forms to participate in services so that those forms can be addressed by the appropriate employee. Finally, we recommend that once financial and setting information has been entered into the responsible payor input and child’s plan in CINC, it be reviewed by another designated individual to ensure its accuracy. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The consistency of the process of obtaining and inputting children’s financial information and the setting of the children’s services into CINC is a significant factor of the internal control structure for the CDS system to ensure that the appropriate payor is paying for the approved services and the appropriate service rate for the setting. Condition Found: In response to the fiscal year 2021 findings, CDS piloted a procedure at one of the regional sites, using a temporary employee to coordinate the "Authorization to Provide Services and Seek Payment" form and to use this form to verify the accuracy of payor information within children's plans. The goal of this pilot procedure was to increase the accuracy of payor information within CINC, as well as to implement a more consistent procedure for obtaining and updating of "Authorization to Provide Services and Seek Payment" forms. However, the temporary employee left during fiscal year 2022 and the pilot was discontinued. During our current year testing we noted 1 out of 40 students for Part B and 1 out of 40 students for Part C did not have the "Authorization to Provide Services and Seek Payment" forms maintained in their files, however, the child was set up as CINC as either MaineCare or Private Insurance. We further noted CDS did not maintain signed authorizations from parents or guardians granting permission for the students to participate in the evaluation and/or program. We noted these authorizations were not properly maintained for 4 out of 40 students under the Part B program and 13 out of 40 under the Part C program. The prior year finding also noted the setting for the children's services of specially designed instruction (SDI) was treated inconsistently across the Regional Sites. The prior year finding indicated the ratio of children to services providers was inconsistent within CINC and the children's plan. The prior year finding noted two instances of SDI 2:1 services that were listed in CINC as individual for the setting. Context: In testing the status prior year findings, we noted the related corrective action plan had not yet been fully implemented. Questioned Costs: None noted Cause and Effect: Inconsistent controls and lack of available qualified staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created at inception and others whereby modifications were made to the plan requiring the file to be reapproved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-003 and 2021-003 Recommendation: We recommend communicating a clear policy for when the form should be obtained and establishing a directive for Regional Site staff when it is not returned at the designated time. We also recommend communicating a clear policy surroudning the importance of obtaining and retaining the proper authorizations from parents and guardians to participate in the evaluation and/or program. Moreover, we recommend an employee at each Regional Site should be designated to run a report to show all plans that are missing the “Authorization to Provide Services and Seek Payment” forms and/or authorization forms to participate in services so that those forms can be addressed by the appropriate employee. Finally, we recommend that once financial and setting information has been entered into the responsible payor input and child’s plan in CINC, it be reviewed by another designated individual to ensure its accuracy. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The consistency of the process of obtaining and inputting children’s financial information and the setting of the children’s services into CINC is a significant factor of the internal control structure for the CDS system to ensure that the appropriate payor is paying for the approved services and the appropriate service rate for the setting. Condition Found: In response to the fiscal year 2021 findings, CDS piloted a procedure at one of the regional sites, using a temporary employee to coordinate the "Authorization to Provide Services and Seek Payment" form and to use this form to verify the accuracy of payor information within children's plans. The goal of this pilot procedure was to increase the accuracy of payor information within CINC, as well as to implement a more consistent procedure for obtaining and updating of "Authorization to Provide Services and Seek Payment" forms. However, the temporary employee left during fiscal year 2022 and the pilot was discontinued. During our current year testing we noted 1 out of 40 students for Part B and 1 out of 40 students for Part C did not have the "Authorization to Provide Services and Seek Payment" forms maintained in their files, however, the child was set up as CINC as either MaineCare or Private Insurance. We further noted CDS did not maintain signed authorizations from parents or guardians granting permission for the students to participate in the evaluation and/or program. We noted these authorizations were not properly maintained for 4 out of 40 students under the Part B program and 13 out of 40 under the Part C program. The prior year finding also noted the setting for the children's services of specially designed instruction (SDI) was treated inconsistently across the Regional Sites. The prior year finding indicated the ratio of children to services providers was inconsistent within CINC and the children's plan. The prior year finding noted two instances of SDI 2:1 services that were listed in CINC as individual for the setting. Context: In testing the status prior year findings, we noted the related corrective action plan had not yet been fully implemented. Questioned Costs: None noted Cause and Effect: Inconsistent controls and lack of available qualified staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created at inception and others whereby modifications were made to the plan requiring the file to be reapproved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-003 and 2021-003 Recommendation: We recommend communicating a clear policy for when the form should be obtained and establishing a directive for Regional Site staff when it is not returned at the designated time. We also recommend communicating a clear policy surroudning the importance of obtaining and retaining the proper authorizations from parents and guardians to participate in the evaluation and/or program. Moreover, we recommend an employee at each Regional Site should be designated to run a report to show all plans that are missing the “Authorization to Provide Services and Seek Payment” forms and/or authorization forms to participate in services so that those forms can be addressed by the appropriate employee. Finally, we recommend that once financial and setting information has been entered into the responsible payor input and child’s plan in CINC, it be reviewed by another designated individual to ensure its accuracy. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The consistency of the process of obtaining and inputting children’s financial information and the setting of the children’s services into CINC is a significant factor of the internal control structure for the CDS system to ensure that the appropriate payor is paying for the approved services and the appropriate service rate for the setting. Condition Found: In response to the fiscal year 2021 findings, CDS piloted a procedure at one of the regional sites, using a temporary employee to coordinate the "Authorization to Provide Services and Seek Payment" form and to use this form to verify the accuracy of payor information within children's plans. The goal of this pilot procedure was to increase the accuracy of payor information within CINC, as well as to implement a more consistent procedure for obtaining and updating of "Authorization to Provide Services and Seek Payment" forms. However, the temporary employee left during fiscal year 2022 and the pilot was discontinued. During our current year testing we noted 1 out of 40 students for Part B and 1 out of 40 students for Part C did not have the "Authorization to Provide Services and Seek Payment" forms maintained in their files, however, the child was set up as CINC as either MaineCare or Private Insurance. We further noted CDS did not maintain signed authorizations from parents or guardians granting permission for the students to participate in the evaluation and/or program. We noted these authorizations were not properly maintained for 4 out of 40 students under the Part B program and 13 out of 40 under the Part C program. The prior year finding also noted the setting for the children's services of specially designed instruction (SDI) was treated inconsistently across the Regional Sites. The prior year finding indicated the ratio of children to services providers was inconsistent within CINC and the children's plan. The prior year finding noted two instances of SDI 2:1 services that were listed in CINC as individual for the setting. Context: In testing the status prior year findings, we noted the related corrective action plan had not yet been fully implemented. Questioned Costs: None noted Cause and Effect: Inconsistent controls and lack of available qualified staff to properly monitor all plans resulted in unlocked plans and unauthorized individuals locking plans, some of which were created at inception and others whereby modifications were made to the plan requiring the file to be reapproved (locked). A critical internal control procedure over financial reporting and compliance is having an appropriate individual with the proper knowledge, experience, and authority to commit funds on behalf of CDS. When the authorization is not documented, there is no assurance that the child's plans have been reviewed for allowable activities and allowable costs in accordance with CDS policies and the Maine Department of Education Regulations, Chapter 101, Maine Unified Special Education Regulation Birth to Age Twenty. The result is that CDS is at risk for potential noncompliance or misstatement of the financial statements. Identification of a Repeat Finding, if Applicable A repeat finding; See finding 2022-003 and 2021-003 Recommendation: We recommend communicating a clear policy for when the form should be obtained and establishing a directive for Regional Site staff when it is not returned at the designated time. We also recommend communicating a clear policy surroudning the importance of obtaining and retaining the proper authorizations from parents and guardians to participate in the evaluation and/or program. Moreover, we recommend an employee at each Regional Site should be designated to run a report to show all plans that are missing the “Authorization to Provide Services and Seek Payment” forms and/or authorization forms to participate in services so that those forms can be addressed by the appropriate employee. Finally, we recommend that once financial and setting information has been entered into the responsible payor input and child’s plan in CINC, it be reviewed by another designated individual to ensure its accuracy. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted the Organization did not review the SAM for contractors, vendors and employees meeting the covered transaction threshold. Context: Based on our testing, we noted that while none of the sample of vendors and employees tested grant were included in the SAM listing, the Organization did not perform a review of vendors, contractors or employees charged to this specific grant. Questioned Costs: None noted Cause and Effect: The Organization was unaware of the requirement to verify employees and vendors against the SAM, therefore, the SAM was not checked prior to payments being made. This results in an increased risk that payments under grant agreements may in appropriately made to excluded parties. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. We also recommend the Organization implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted the Organization did not review the SAM for contractors, vendors and employees meeting the covered transaction threshold. Context: Based on our testing, we noted that while none of the sample of vendors and employees tested grant were included in the SAM listing, the Organization did not perform a review of vendors, contractors or employees charged to this specific grant. Questioned Costs: None noted Cause and Effect: The Organization was unaware of the requirement to verify employees and vendors against the SAM, therefore, the SAM was not checked prior to payments being made. This results in an increased risk that payments under grant agreements may in appropriately made to excluded parties. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. We also recommend the Organization implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted the Organization did not review the SAM for contractors, vendors and employees meeting the covered transaction threshold. Context: Based on our testing, we noted that while none of the sample of vendors and employees tested grant were included in the SAM listing, the Organization did not perform a review of vendors, contractors or employees charged to this specific grant. Questioned Costs: None noted Cause and Effect: The Organization was unaware of the requirement to verify employees and vendors against the SAM, therefore, the SAM was not checked prior to payments being made. This results in an increased risk that payments under grant agreements may in appropriately made to excluded parties. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. We also recommend the Organization implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted the Organization did not review the SAM for contractors, vendors and employees meeting the covered transaction threshold. Context: Based on our testing, we noted that while none of the sample of vendors and employees tested grant were included in the SAM listing, the Organization did not perform a review of vendors, contractors or employees charged to this specific grant. Questioned Costs: None noted Cause and Effect: The Organization was unaware of the requirement to verify employees and vendors against the SAM, therefore, the SAM was not checked prior to payments being made. This results in an increased risk that payments under grant agreements may in appropriately made to excluded parties. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. We also recommend the Organization implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted the Organization did not review the SAM for contractors, vendors and employees meeting the covered transaction threshold. Context: Based on our testing, we noted that while none of the sample of vendors and employees tested grant were included in the SAM listing, the Organization did not perform a review of vendors, contractors or employees charged to this specific grant. Questioned Costs: None noted Cause and Effect: The Organization was unaware of the requirement to verify employees and vendors against the SAM, therefore, the SAM was not checked prior to payments being made. This results in an increased risk that payments under grant agreements may in appropriately made to excluded parties. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. We also recommend the Organization implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education – Grants for Infants and Families AL: 84.181 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor or employee is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted the Organization did not review the SAM for contractors, vendors and employees meeting the covered transaction threshold. Context: Based on our testing, we noted that while none of the sample of vendors and employees tested grant were included in the SAM listing, the Organization did not perform a review of vendors, contractors or employees charged to this specific grant. Questioned Costs: None noted Cause and Effect: The Organization was unaware of the requirement to verify employees and vendors against the SAM, therefore, the SAM was not checked prior to payments being made. This results in an increased risk that payments under grant agreements may in appropriately made to excluded parties. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to compare all vendors meeting the $25,000 threshold funded by any federal program to the SAM at least annually and when a new vendor is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. We also recommend the Organization implement a process to verify any employees that are charged to a grant subsequent to their initial hire, whether through allocations or journal entries, are reviewed against the SAM. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The cost principles in 2 CFR, Part 200, Subpart E (Cost Principles) are required for the administration of federal awards of Nonprofit organizations. Condition Found: During our audit we noted the Organization had served children under the grant program that did not meet the activities allowable under the grant as follows: - For one child tested, we were unable to verify if the services provided were documented in the CINC service logs were allowable activities under the grant. Context: Of the nonstatistical sample of 40 children tested under the Part B program, one child served did not have adequate documentation retained supporting an allowable activity in line with the grant requirements. Questioned Costs: None noted. Cause and Effect: The Organization was unaware of the Allowable Costs and Cost Principles requirements as to the requirements of the Part B program. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to review all child files and service logs charged to the Part B program to verify the services performed within the notes were properly documented and the activities are allowable under grant requirements. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The cost principles in 2 CFR, Part 200, Subpart E (Cost Principles) are required for the administration of federal awards of Nonprofit organizations. Condition Found: During our audit we noted the Organization had served children under the grant program that did not meet the activities allowable under the grant as follows: - For one child tested, we were unable to verify if the services provided were documented in the CINC service logs were allowable activities under the grant. Context: Of the nonstatistical sample of 40 children tested under the Part B program, one child served did not have adequate documentation retained supporting an allowable activity in line with the grant requirements. Questioned Costs: None noted. Cause and Effect: The Organization was unaware of the Allowable Costs and Cost Principles requirements as to the requirements of the Part B program. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to review all child files and service logs charged to the Part B program to verify the services performed within the notes were properly documented and the activities are allowable under grant requirements. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The cost principles in 2 CFR, Part 200, Subpart E (Cost Principles) are required for the administration of federal awards of Nonprofit organizations. Condition Found: During our audit we noted the Organization had served children under the grant program that did not meet the activities allowable under the grant as follows: - For one child tested, we were unable to verify if the services provided were documented in the CINC service logs were allowable activities under the grant. Context: Of the nonstatistical sample of 40 children tested under the Part B program, one child served did not have adequate documentation retained supporting an allowable activity in line with the grant requirements. Questioned Costs: None noted. Cause and Effect: The Organization was unaware of the Allowable Costs and Cost Principles requirements as to the requirements of the Part B program. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to review all child files and service logs charged to the Part B program to verify the services performed within the notes were properly documented and the activities are allowable under grant requirements. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Information on the Federal Program Federal Agency: United States Department of Education Program Names: Special Education Cluster (IDEA) AL: 84.027, 84.173 Federal Award Year: 2023 Criteria: The cost principles in 2 CFR, Part 200, Subpart E (Cost Principles) are required for the administration of federal awards of Nonprofit organizations. Condition Found: During our audit we noted the Organization had served children under the grant program that did not meet the activities allowable under the grant as follows: - For one child tested, we were unable to verify if the services provided were documented in the CINC service logs were allowable activities under the grant. Context: Of the nonstatistical sample of 40 children tested under the Part B program, one child served did not have adequate documentation retained supporting an allowable activity in line with the grant requirements. Questioned Costs: None noted. Cause and Effect: The Organization was unaware of the Allowable Costs and Cost Principles requirements as to the requirements of the Part B program. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement a process to review all child files and service logs charged to the Part B program to verify the services performed within the notes were properly documented and the activities are allowable under grant requirements. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Finding Number: 2023-013 Information on the Federal Program Federal Agency: United States Department of Education Program Names: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) AL: 84.425U Federal Award Year: 2023 Criteria: The cost principles in 2 CFR, Part 200, Subpart E (Cost Principles) are required for the administration of federal awards. Condition Found: During our audit of allowable costs, we noted the Organization had service costs charged to the grant for which they were unable to provide verifiable support for the costs or activities. Specifically: - The sample included six expenditures charged to the grant by journal entry for which the Organization was unable to provide supporting documentation. - The sample tested included five disbursements for which the Organization was unable to provide invoices to support the transactions. Context: A nonstatistical sample of forty expenditures under the ARP ESSER Grant were selected for testing, of which eleven transactions could not be supported to determine if they were consistent with the Cost Principles. Questioned Costs: $237,328 Cause and Effect: The Organization was unaware of the Allowable Costs and Cost Principles requirements as to the expenditures charged to the grant. Identification as a Repeat Finding, if applicable N/A Recommendation: We recommend the Organization implement and monitor a process to retain documentation for all transactions and journal entries charged to the grants to support allowable costs under the Federal Cost Principles. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.