Audit 347778

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Under 2 CFR Part 200, entities receiving federal funds must follow the stricter of regulations between state and federal guidelines for purchasing and tracking equipment. Specifically, 2 CFR 313 requires recipients to maintain detailed property records for equipment acquired with federal awards. These records must include descriptions, identification numbers, funding sources, acquisition dates, costs, federal contribution percentages, locations, usage, conditions, and disposal information. Recipients must also update these records whenever the status of the property changes. Specifically, the Mississippi Public School Asset Management Manual requires school districts to maintain current inventories of property items valued at $1,000 or more. Additionally, other items, such as cameras, camera equipment, televisions, computers and computer equipment equal to or greater than $250, must be included in the inventory. Other equipment such as tools, furniture and other assets regardless of their purchase price or fair market value must be included. This also requires thorough tracking and management of school assets. Condition: We observed that the District’s internal controls are inadequate to ensure that the District complies with its current internal control policies and procedures for fixed assets. Specifically, as a result of our fixed asset inventory procedures we observed the following:  Approximately $298,894.26 in equipment purchased was not included in the District’s fixed asset system for compliance purposes as required.  Three assets selected for observation in our sample of fixed assets could not be located by the District. Additionally, our examination of the most recent District inventory taken in the spring of 2024 revealed that all three assets were missing at that time and personnel responsible for conducting the inventory did not properly report the assets as lost or stolen as required by District policy in a timely manner. Context/ Perspective: This finding is a result of our statistically valid random sample of forty fixed assets inventory observation for the Special Education Cluster (IDEA) performed for single audit purposes as well as other procedures were performed by us reconciling the District’s asset listing of ESSER II assets to the District’s financial records. Cause: The District’s internal control system is inadequate to ensure that the District’s fixed asset system fulfills the requirements of the current District internal control policy, “Fixed Asset Accountability”. Effect: Failure to follow federal and state fixed asset requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend the District develops and maintains an equipment listing that reflects all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment and that it completes a physical inventory of equipment annually and the results is reconciled to the equipment listing. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Under 2 CFR Part 200, entities receiving federal funds must follow the stricter of regulations between state and federal guidelines for purchasing and tracking equipment. Specifically, 2 CFR 313 requires recipients to maintain detailed property records for equipment acquired with federal awards. These records must include descriptions, identification numbers, funding sources, acquisition dates, costs, federal contribution percentages, locations, usage, conditions, and disposal information. Recipients must also update these records whenever the status of the property changes. Specifically, the Mississippi Public School Asset Management Manual requires school districts to maintain current inventories of property items valued at $1,000 or more. Additionally, other items, such as cameras, camera equipment, televisions, computers and computer equipment equal to or greater than $250, must be included in the inventory. Other equipment such as tools, furniture and other assets regardless of their purchase price or fair market value must be included. This also requires thorough tracking and management of school assets. Condition: We observed that the District’s internal controls are inadequate to ensure that the District complies with its current internal control policies and procedures for fixed assets. Specifically, as a result of our fixed asset inventory procedures we observed the following:  Approximately $298,894.26 in equipment purchased was not included in the District’s fixed asset system for compliance purposes as required.  Three assets selected for observation in our sample of fixed assets could not be located by the District. Additionally, our examination of the most recent District inventory taken in the spring of 2024 revealed that all three assets were missing at that time and personnel responsible for conducting the inventory did not properly report the assets as lost or stolen as required by District policy in a timely manner. Context/ Perspective: This finding is a result of our statistically valid random sample of forty fixed assets inventory observation for the Special Education Cluster (IDEA) performed for single audit purposes as well as other procedures were performed by us reconciling the District’s asset listing of ESSER II assets to the District’s financial records. Cause: The District’s internal control system is inadequate to ensure that the District’s fixed asset system fulfills the requirements of the current District internal control policy, “Fixed Asset Accountability”. Effect: Failure to follow federal and state fixed asset requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend the District develops and maintains an equipment listing that reflects all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment and that it completes a physical inventory of equipment annually and the results is reconciled to the equipment listing. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Under 2 CFR Part 200, entities receiving federal funds must follow the stricter of regulations between state and federal guidelines for purchasing and tracking equipment. Specifically, 2 CFR 313 requires recipients to maintain detailed property records for equipment acquired with federal awards. These records must include descriptions, identification numbers, funding sources, acquisition dates, costs, federal contribution percentages, locations, usage, conditions, and disposal information. Recipients must also update these records whenever the status of the property changes. Specifically, the Mississippi Public School Asset Management Manual requires school districts to maintain current inventories of property items valued at $1,000 or more. Additionally, other items, such as cameras, camera equipment, televisions, computers and computer equipment equal to or greater than $250, must be included in the inventory. Other equipment such as tools, furniture and other assets regardless of their purchase price or fair market value must be included. This also requires thorough tracking and management of school assets. Condition: We observed that the District’s internal controls are inadequate to ensure that the District complies with its current internal control policies and procedures for fixed assets. Specifically, as a result of our fixed asset inventory procedures we observed the following:  Approximately $298,894.26 in equipment purchased was not included in the District’s fixed asset system for compliance purposes as required.  Three assets selected for observation in our sample of fixed assets could not be located by the District. Additionally, our examination of the most recent District inventory taken in the spring of 2024 revealed that all three assets were missing at that time and personnel responsible for conducting the inventory did not properly report the assets as lost or stolen as required by District policy in a timely manner. Context/ Perspective: This finding is a result of our statistically valid random sample of forty fixed assets inventory observation for the Special Education Cluster (IDEA) performed for single audit purposes as well as other procedures were performed by us reconciling the District’s asset listing of ESSER II assets to the District’s financial records. Cause: The District’s internal control system is inadequate to ensure that the District’s fixed asset system fulfills the requirements of the current District internal control policy, “Fixed Asset Accountability”. Effect: Failure to follow federal and state fixed asset requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend the District develops and maintains an equipment listing that reflects all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment and that it completes a physical inventory of equipment annually and the results is reconciled to the equipment listing. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Under 2 CFR Part 200, entities receiving federal funds must follow the stricter of regulations between state and federal guidelines for purchasing and tracking equipment. Specifically, 2 CFR 313 requires recipients to maintain detailed property records for equipment acquired with federal awards. These records must include descriptions, identification numbers, funding sources, acquisition dates, costs, federal contribution percentages, locations, usage, conditions, and disposal information. Recipients must also update these records whenever the status of the property changes. Specifically, the Mississippi Public School Asset Management Manual requires school districts to maintain current inventories of property items valued at $1,000 or more. Additionally, other items, such as cameras, camera equipment, televisions, computers and computer equipment equal to or greater than $250, must be included in the inventory. Other equipment such as tools, furniture and other assets regardless of their purchase price or fair market value must be included. This also requires thorough tracking and management of school assets. Condition: We observed that the District’s internal controls are inadequate to ensure that the District complies with its current internal control policies and procedures for fixed assets. Specifically, as a result of our fixed asset inventory procedures we observed the following:  Approximately $298,894.26 in equipment purchased was not included in the District’s fixed asset system for compliance purposes as required.  Three assets selected for observation in our sample of fixed assets could not be located by the District. Additionally, our examination of the most recent District inventory taken in the spring of 2024 revealed that all three assets were missing at that time and personnel responsible for conducting the inventory did not properly report the assets as lost or stolen as required by District policy in a timely manner. Context/ Perspective: This finding is a result of our statistically valid random sample of forty fixed assets inventory observation for the Special Education Cluster (IDEA) performed for single audit purposes as well as other procedures were performed by us reconciling the District’s asset listing of ESSER II assets to the District’s financial records. Cause: The District’s internal control system is inadequate to ensure that the District’s fixed asset system fulfills the requirements of the current District internal control policy, “Fixed Asset Accountability”. Effect: Failure to follow federal and state fixed asset requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend the District develops and maintains an equipment listing that reflects all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment and that it completes a physical inventory of equipment annually and the results is reconciled to the equipment listing. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Under 2 CFR Part 200, entities receiving federal funds must follow the stricter of regulations between state and federal guidelines for purchasing and tracking equipment. Specifically, 2 CFR 313 requires recipients to maintain detailed property records for equipment acquired with federal awards. These records must include descriptions, identification numbers, funding sources, acquisition dates, costs, federal contribution percentages, locations, usage, conditions, and disposal information. Recipients must also update these records whenever the status of the property changes. Specifically, the Mississippi Public School Asset Management Manual requires school districts to maintain current inventories of property items valued at $1,000 or more. Additionally, other items, such as cameras, camera equipment, televisions, computers and computer equipment equal to or greater than $250, must be included in the inventory. Other equipment such as tools, furniture and other assets regardless of their purchase price or fair market value must be included. This also requires thorough tracking and management of school assets. Condition: We observed that the District’s internal controls are inadequate to ensure that the District complies with its current internal control policies and procedures for fixed assets. Specifically, as a result of our fixed asset inventory procedures we observed the following:  Approximately $298,894.26 in equipment purchased was not included in the District’s fixed asset system for compliance purposes as required.  Three assets selected for observation in our sample of fixed assets could not be located by the District. Additionally, our examination of the most recent District inventory taken in the spring of 2024 revealed that all three assets were missing at that time and personnel responsible for conducting the inventory did not properly report the assets as lost or stolen as required by District policy in a timely manner. Context/ Perspective: This finding is a result of our statistically valid random sample of forty fixed assets inventory observation for the Special Education Cluster (IDEA) performed for single audit purposes as well as other procedures were performed by us reconciling the District’s asset listing of ESSER II assets to the District’s financial records. Cause: The District’s internal control system is inadequate to ensure that the District’s fixed asset system fulfills the requirements of the current District internal control policy, “Fixed Asset Accountability”. Effect: Failure to follow federal and state fixed asset requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend the District develops and maintains an equipment listing that reflects all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment and that it completes a physical inventory of equipment annually and the results is reconciled to the equipment listing. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Repeat Finding: No Criteria: 2 CFR 200.303 requires that a non-federal entity establish, document and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 7 CFR 210.14(g) also requires school food authorities to follow fair and consistent methodologies to identify and allocate allowable indirect costs to the nonprofit school food service account, in accordance with 2 CFR part 200 as implemented by 2 CFR part 400. Condition: Our procedures indicate that the District’s internal control system is inadequate for ensuring that indirect costs charged to various federal grant programs are adequately documented and accurately calculated. Specifically:  Child Nutrition Cluster: The District could not provide documentation of its calculation to support the $25,000 per quarter requested as reimbursement for indirect costs.  Elementary and Secondary School Emergency Relief (ESSER II): The District used an indirect cost rate from a prior year to calculate indirect costs charged to the ESSER II program which resulted in an overcharge of $68,829. Our procedures indicate that the District’s internal control system is insufficient to ensure that the indirect cost charged to the program is accurately calculated and based on calculations that meet the requirements outlined in Sections 2 CFR 200.303, 2 CFR 200.414 and Appendix VII to Part 200. Context/ Perspective: This finding arises from our audit procedures on internal control, where attempted to obtain documentation of the District's calculation and subsequent approval of reimbursement for indirect costs as well as other procedures performed by us recalculating indirect costs charged to certain federal grant programs. Cause: The District lacks the necessary internal controls to ensure that requests for reimbursement of indirect costs are accurately calculated, properly documented and approved by the appropriate director. Effect: The lack of adequate internal controls over the calculation of indirect cost reimbursement may increase the risk of misappropriation or loss of public funds. It could also result in inappropriate charges to the federal award, potentially leading to disallowed costs being applied to the program. Questioned Costs: $68,829 (Elementary and Secondary School Emergency Relief II) Recommendation: The District should implement stronger internal controls to ensure that indirect cost reimbursements are accurately calculated, properly documented, and approved by the appropriate federal grant program director. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Repeat Finding: No Criteria: 2 CFR 200.303 requires that a non-federal entity establish, document and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 7 CFR 210.14(g) also requires school food authorities to follow fair and consistent methodologies to identify and allocate allowable indirect costs to the nonprofit school food service account, in accordance with 2 CFR part 200 as implemented by 2 CFR part 400. Condition: Our procedures indicate that the District’s internal control system is inadequate for ensuring that indirect costs charged to various federal grant programs are adequately documented and accurately calculated. Specifically:  Child Nutrition Cluster: The District could not provide documentation of its calculation to support the $25,000 per quarter requested as reimbursement for indirect costs.  Elementary and Secondary School Emergency Relief (ESSER II): The District used an indirect cost rate from a prior year to calculate indirect costs charged to the ESSER II program which resulted in an overcharge of $68,829. Our procedures indicate that the District’s internal control system is insufficient to ensure that the indirect cost charged to the program is accurately calculated and based on calculations that meet the requirements outlined in Sections 2 CFR 200.303, 2 CFR 200.414 and Appendix VII to Part 200. Context/ Perspective: This finding arises from our audit procedures on internal control, where attempted to obtain documentation of the District's calculation and subsequent approval of reimbursement for indirect costs as well as other procedures performed by us recalculating indirect costs charged to certain federal grant programs. Cause: The District lacks the necessary internal controls to ensure that requests for reimbursement of indirect costs are accurately calculated, properly documented and approved by the appropriate director. Effect: The lack of adequate internal controls over the calculation of indirect cost reimbursement may increase the risk of misappropriation or loss of public funds. It could also result in inappropriate charges to the federal award, potentially leading to disallowed costs being applied to the program. Questioned Costs: $68,829 (Elementary and Secondary School Emergency Relief II) Recommendation: The District should implement stronger internal controls to ensure that indirect cost reimbursements are accurately calculated, properly documented, and approved by the appropriate federal grant program director. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Repeat Finding: No Criteria: 2 CFR 200.303 requires that a non-federal entity establish, document and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 7 CFR 210.14(g) also requires school food authorities to follow fair and consistent methodologies to identify and allocate allowable indirect costs to the nonprofit school food service account, in accordance with 2 CFR part 200 as implemented by 2 CFR part 400. Condition: Our procedures indicate that the District’s internal control system is inadequate for ensuring that indirect costs charged to various federal grant programs are adequately documented and accurately calculated. Specifically:  Child Nutrition Cluster: The District could not provide documentation of its calculation to support the $25,000 per quarter requested as reimbursement for indirect costs.  Elementary and Secondary School Emergency Relief (ESSER II): The District used an indirect cost rate from a prior year to calculate indirect costs charged to the ESSER II program which resulted in an overcharge of $68,829. Our procedures indicate that the District’s internal control system is insufficient to ensure that the indirect cost charged to the program is accurately calculated and based on calculations that meet the requirements outlined in Sections 2 CFR 200.303, 2 CFR 200.414 and Appendix VII to Part 200. Context/ Perspective: This finding arises from our audit procedures on internal control, where attempted to obtain documentation of the District's calculation and subsequent approval of reimbursement for indirect costs as well as other procedures performed by us recalculating indirect costs charged to certain federal grant programs. Cause: The District lacks the necessary internal controls to ensure that requests for reimbursement of indirect costs are accurately calculated, properly documented and approved by the appropriate director. Effect: The lack of adequate internal controls over the calculation of indirect cost reimbursement may increase the risk of misappropriation or loss of public funds. It could also result in inappropriate charges to the federal award, potentially leading to disallowed costs being applied to the program. Questioned Costs: $68,829 (Elementary and Secondary School Emergency Relief II) Recommendation: The District should implement stronger internal controls to ensure that indirect cost reimbursements are accurately calculated, properly documented, and approved by the appropriate federal grant program director. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Repeat Finding: No Criteria: Section 7 CFR 210.8 requires the school food authority (SFA) to establish internal controls to ensure the accuracy of meal counts before submitting the monthly Claim for Reimbursement. These controls include:  On-site Review: Each SFA with multiple schools must conduct at least one on-site review each school year, prior to February 1, of the meal counting and claiming system for each school. The review attempts to identify discrepancies in meal counts and compares daily meal data to identify any issues. If problems are found, corrective action must be implemented, and a follow-up review must occur within 45 days to confirm resolution. The review ensures that the meal count system is accurate and compliant with state and federal regulations.  Claims Review Process: Before submitting the Claim for Reimbursement, the SFA must review the lunch count data for each school to verify the accuracy of the claims. The goal is to ensure that only the correct number of reimbursable free, reduced price, and paid meals served to eligible children are included in the claim. Condition: Our procedures indicated that the District’s internal control system is inadequate for ensuring for compliance with federal requirements for preparing claims for reimbursements in the food service program. In performing our procedures, the District did not provide supporting documentation for the month of August which the director stated was prepared using manual calculations because the point-of-sale system was not operational for that month. Our procedures also identified several input errors for several months in entering meals served for individual schools that qualify under the Community Eligibility Program (CEP) for several other months. Context/ Perspective: This finding is a result of our audit procedures over internal control and compliance for one hundred percent of claims for reimbursement in the food service program. Cause: The District lacks the necessary internal controls to ensure that claims for reimbursement for meals served are accurately calculated, properly documented and approved by the food service director. Effect: The lack of adequate internal controls over claims for reimbursement for food service may increase the risk of misappropriation or loss of public funds. It could also result in inappropriate charges to the federal award, potentially leading to disallowed costs being applied to the program. Questioned Costs: None Recommendation: The District should implement additional internal controls to ensure that claims for reimbursements for the food service program are accurately calculated, properly documented, and approved by the food service director. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Repeat Finding: No Criteria: Section 7 CFR 210.8 requires the school food authority (SFA) to establish internal controls to ensure the accuracy of meal counts before submitting the monthly Claim for Reimbursement. These controls include:  On-site Review: Each SFA with multiple schools must conduct at least one on-site review each school year, prior to February 1, of the meal counting and claiming system for each school. The review attempts to identify discrepancies in meal counts and compares daily meal data to identify any issues. If problems are found, corrective action must be implemented, and a follow-up review must occur within 45 days to confirm resolution. The review ensures that the meal count system is accurate and compliant with state and federal regulations.  Claims Review Process: Before submitting the Claim for Reimbursement, the SFA must review the lunch count data for each school to verify the accuracy of the claims. The goal is to ensure that only the correct number of reimbursable free, reduced price, and paid meals served to eligible children are included in the claim. Condition: Our procedures indicated that the District’s internal control system is inadequate for ensuring for compliance with federal requirements for preparing claims for reimbursements in the food service program. In performing our procedures, the District did not provide supporting documentation for the month of August which the director stated was prepared using manual calculations because the point-of-sale system was not operational for that month. Our procedures also identified several input errors for several months in entering meals served for individual schools that qualify under the Community Eligibility Program (CEP) for several other months. Context/ Perspective: This finding is a result of our audit procedures over internal control and compliance for one hundred percent of claims for reimbursement in the food service program. Cause: The District lacks the necessary internal controls to ensure that claims for reimbursement for meals served are accurately calculated, properly documented and approved by the food service director. Effect: The lack of adequate internal controls over claims for reimbursement for food service may increase the risk of misappropriation or loss of public funds. It could also result in inappropriate charges to the federal award, potentially leading to disallowed costs being applied to the program. Questioned Costs: None Recommendation: The District should implement additional internal controls to ensure that claims for reimbursements for the food service program are accurately calculated, properly documented, and approved by the food service director. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D– Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U– Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.302 and 2 CFR 200.303 outline key requirements for non-federal entities managing federal awards. Section 200.302 mandates that a financial management system be in place to prepare reports as required by both general and program-specific terms and conditions. It also requires tracing funds to a level of expenditure that demonstrates compliance with federal statutes, regulations, and the terms of the federal award, including comparing expenditures with the budget for each federal award. Section 200.303 requires non-federal entities to establish and maintain effective internal controls over federal awards, ensuring reasonable assurance that the entity is managing the award in compliance with federal laws, regulations, and the award's terms and conditions. Condition: The District’s internal controls over budgeting for federal grants are insufficient to ensure compliance with federal regulations and to stay within the budgetary limits established by the federal awards, as specified in the Mississippi Comprehensive Automated Performance-based System (MCAPS), administered through the Mississippi Department of Education. Specifically, the District has not adequately adhered to budgeting restraints outlined for its federal grants. Our audit procedures identified the following instances where actual expenditures appear to exceed the budgeted amounts:  Six-line items in the ARP ESSER grant, totaling $115,645.51.  Five-line items in the ESSER II grant, totaling $31,135.42  Three-line items in the Special Education IDEA Part B grant, totaling $9,474.44.  One-line item in the Title I, Part A grant, totaling $8,640.88. Context/ Perspective: This finding is a result of our budget to actual comparisons for federal grant purposes of major programs and the conditions cited appear to be a systematic issue. Cause: The District did not properly monitor budget limits established in MCAPS to ensure that budgeting requirements were fulfilled. Effect: Failure to remain within established budget limits in MCAPS could affect future eligibility for federal award programs or result in a loss or misappropriation of public assets. Questioned Costs: $146,780.93 (ESSER II and ARP ESSER) Recommendation: The District should establish additional internal controls to ensure that it remains within budget limits for each grant maintained in MCAPS. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Under 2 CFR Part 200, entities receiving federal funds must follow the stricter of regulations between state and federal guidelines for purchasing and tracking equipment. Specifically, 2 CFR 313 requires recipients to maintain detailed property records for equipment acquired with federal awards. These records must include descriptions, identification numbers, funding sources, acquisition dates, costs, federal contribution percentages, locations, usage, conditions, and disposal information. Recipients must also update these records whenever the status of the property changes. Specifically, the Mississippi Public School Asset Management Manual requires school districts to maintain current inventories of property items valued at $1,000 or more. Additionally, other items, such as cameras, camera equipment, televisions, computers and computer equipment equal to or greater than $250, must be included in the inventory. Other equipment such as tools, furniture and other assets regardless of their purchase price or fair market value must be included. This also requires thorough tracking and management of school assets. Condition: We observed that the District’s internal controls are inadequate to ensure that the District complies with its current internal control policies and procedures for fixed assets. Specifically, as a result of our fixed asset inventory procedures we observed the following:  Approximately $298,894.26 in equipment purchased was not included in the District’s fixed asset system for compliance purposes as required.  Three assets selected for observation in our sample of fixed assets could not be located by the District. Additionally, our examination of the most recent District inventory taken in the spring of 2024 revealed that all three assets were missing at that time and personnel responsible for conducting the inventory did not properly report the assets as lost or stolen as required by District policy in a timely manner. Context/ Perspective: This finding is a result of our statistically valid random sample of forty fixed assets inventory observation for the Special Education Cluster (IDEA) performed for single audit purposes as well as other procedures were performed by us reconciling the District’s asset listing of ESSER II assets to the District’s financial records. Cause: The District’s internal control system is inadequate to ensure that the District’s fixed asset system fulfills the requirements of the current District internal control policy, “Fixed Asset Accountability”. Effect: Failure to follow federal and state fixed asset requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend the District develops and maintains an equipment listing that reflects all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment and that it completes a physical inventory of equipment annually and the results is reconciled to the equipment listing. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Under 2 CFR Part 200, entities receiving federal funds must follow the stricter of regulations between state and federal guidelines for purchasing and tracking equipment. Specifically, 2 CFR 313 requires recipients to maintain detailed property records for equipment acquired with federal awards. These records must include descriptions, identification numbers, funding sources, acquisition dates, costs, federal contribution percentages, locations, usage, conditions, and disposal information. Recipients must also update these records whenever the status of the property changes. Specifically, the Mississippi Public School Asset Management Manual requires school districts to maintain current inventories of property items valued at $1,000 or more. Additionally, other items, such as cameras, camera equipment, televisions, computers and computer equipment equal to or greater than $250, must be included in the inventory. Other equipment such as tools, furniture and other assets regardless of their purchase price or fair market value must be included. This also requires thorough tracking and management of school assets. Condition: We observed that the District’s internal controls are inadequate to ensure that the District complies with its current internal control policies and procedures for fixed assets. Specifically, as a result of our fixed asset inventory procedures we observed the following:  Approximately $298,894.26 in equipment purchased was not included in the District’s fixed asset system for compliance purposes as required.  Three assets selected for observation in our sample of fixed assets could not be located by the District. Additionally, our examination of the most recent District inventory taken in the spring of 2024 revealed that all three assets were missing at that time and personnel responsible for conducting the inventory did not properly report the assets as lost or stolen as required by District policy in a timely manner. Context/ Perspective: This finding is a result of our statistically valid random sample of forty fixed assets inventory observation for the Special Education Cluster (IDEA) performed for single audit purposes as well as other procedures were performed by us reconciling the District’s asset listing of ESSER II assets to the District’s financial records. Cause: The District’s internal control system is inadequate to ensure that the District’s fixed asset system fulfills the requirements of the current District internal control policy, “Fixed Asset Accountability”. Effect: Failure to follow federal and state fixed asset requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend the District develops and maintains an equipment listing that reflects all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment and that it completes a physical inventory of equipment annually and the results is reconciled to the equipment listing. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Under 2 CFR Part 200, entities receiving federal funds must follow the stricter of regulations between state and federal guidelines for purchasing and tracking equipment. Specifically, 2 CFR 313 requires recipients to maintain detailed property records for equipment acquired with federal awards. These records must include descriptions, identification numbers, funding sources, acquisition dates, costs, federal contribution percentages, locations, usage, conditions, and disposal information. Recipients must also update these records whenever the status of the property changes. Specifically, the Mississippi Public School Asset Management Manual requires school districts to maintain current inventories of property items valued at $1,000 or more. Additionally, other items, such as cameras, camera equipment, televisions, computers and computer equipment equal to or greater than $250, must be included in the inventory. Other equipment such as tools, furniture and other assets regardless of their purchase price or fair market value must be included. This also requires thorough tracking and management of school assets. Condition: We observed that the District’s internal controls are inadequate to ensure that the District complies with its current internal control policies and procedures for fixed assets. Specifically, as a result of our fixed asset inventory procedures we observed the following:  Approximately $298,894.26 in equipment purchased was not included in the District’s fixed asset system for compliance purposes as required.  Three assets selected for observation in our sample of fixed assets could not be located by the District. Additionally, our examination of the most recent District inventory taken in the spring of 2024 revealed that all three assets were missing at that time and personnel responsible for conducting the inventory did not properly report the assets as lost or stolen as required by District policy in a timely manner. Context/ Perspective: This finding is a result of our statistically valid random sample of forty fixed assets inventory observation for the Special Education Cluster (IDEA) performed for single audit purposes as well as other procedures were performed by us reconciling the District’s asset listing of ESSER II assets to the District’s financial records. Cause: The District’s internal control system is inadequate to ensure that the District’s fixed asset system fulfills the requirements of the current District internal control policy, “Fixed Asset Accountability”. Effect: Failure to follow federal and state fixed asset requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend the District develops and maintains an equipment listing that reflects all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment and that it completes a physical inventory of equipment annually and the results is reconciled to the equipment listing. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Under 2 CFR Part 200, entities receiving federal funds must follow the stricter of regulations between state and federal guidelines for purchasing and tracking equipment. Specifically, 2 CFR 313 requires recipients to maintain detailed property records for equipment acquired with federal awards. These records must include descriptions, identification numbers, funding sources, acquisition dates, costs, federal contribution percentages, locations, usage, conditions, and disposal information. Recipients must also update these records whenever the status of the property changes. Specifically, the Mississippi Public School Asset Management Manual requires school districts to maintain current inventories of property items valued at $1,000 or more. Additionally, other items, such as cameras, camera equipment, televisions, computers and computer equipment equal to or greater than $250, must be included in the inventory. Other equipment such as tools, furniture and other assets regardless of their purchase price or fair market value must be included. This also requires thorough tracking and management of school assets. Condition: We observed that the District’s internal controls are inadequate to ensure that the District complies with its current internal control policies and procedures for fixed assets. Specifically, as a result of our fixed asset inventory procedures we observed the following:  Approximately $298,894.26 in equipment purchased was not included in the District’s fixed asset system for compliance purposes as required.  Three assets selected for observation in our sample of fixed assets could not be located by the District. Additionally, our examination of the most recent District inventory taken in the spring of 2024 revealed that all three assets were missing at that time and personnel responsible for conducting the inventory did not properly report the assets as lost or stolen as required by District policy in a timely manner. Context/ Perspective: This finding is a result of our statistically valid random sample of forty fixed assets inventory observation for the Special Education Cluster (IDEA) performed for single audit purposes as well as other procedures were performed by us reconciling the District’s asset listing of ESSER II assets to the District’s financial records. Cause: The District’s internal control system is inadequate to ensure that the District’s fixed asset system fulfills the requirements of the current District internal control policy, “Fixed Asset Accountability”. Effect: Failure to follow federal and state fixed asset requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend the District develops and maintains an equipment listing that reflects all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment and that it completes a physical inventory of equipment annually and the results is reconciled to the equipment listing. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Material Weakness Material Noncompliance Program: Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Under 2 CFR Part 200, entities receiving federal funds must follow the stricter of regulations between state and federal guidelines for purchasing and tracking equipment. Specifically, 2 CFR 313 requires recipients to maintain detailed property records for equipment acquired with federal awards. These records must include descriptions, identification numbers, funding sources, acquisition dates, costs, federal contribution percentages, locations, usage, conditions, and disposal information. Recipients must also update these records whenever the status of the property changes. Specifically, the Mississippi Public School Asset Management Manual requires school districts to maintain current inventories of property items valued at $1,000 or more. Additionally, other items, such as cameras, camera equipment, televisions, computers and computer equipment equal to or greater than $250, must be included in the inventory. Other equipment such as tools, furniture and other assets regardless of their purchase price or fair market value must be included. This also requires thorough tracking and management of school assets. Condition: We observed that the District’s internal controls are inadequate to ensure that the District complies with its current internal control policies and procedures for fixed assets. Specifically, as a result of our fixed asset inventory procedures we observed the following:  Approximately $298,894.26 in equipment purchased was not included in the District’s fixed asset system for compliance purposes as required.  Three assets selected for observation in our sample of fixed assets could not be located by the District. Additionally, our examination of the most recent District inventory taken in the spring of 2024 revealed that all three assets were missing at that time and personnel responsible for conducting the inventory did not properly report the assets as lost or stolen as required by District policy in a timely manner. Context/ Perspective: This finding is a result of our statistically valid random sample of forty fixed assets inventory observation for the Special Education Cluster (IDEA) performed for single audit purposes as well as other procedures were performed by us reconciling the District’s asset listing of ESSER II assets to the District’s financial records. Cause: The District’s internal control system is inadequate to ensure that the District’s fixed asset system fulfills the requirements of the current District internal control policy, “Fixed Asset Accountability”. Effect: Failure to follow federal and state fixed asset requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend the District develops and maintains an equipment listing that reflects all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment and that it completes a physical inventory of equipment annually and the results is reconciled to the equipment listing. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Assistance Listing: 84.425U – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) Repeat Finding: Yes Criteria: 2 CFR 200.303 requires that a non-federal entity must establish and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.334 requires subrecipients to retain all Federal award records for three years from the date of submission of their final financial report. For awards that are renewed quarterly or annually, the recipient and subrecipient must retain records for three years from the date of submission of their quarterly or annual financial report, respectively. Records to be retained include but are not limited to financial records, supporting documentation, and statistical records. Federal agencies or pass-through entities may not impose any other record retention requirements except records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken if any litigation, claim, or audit is started before the expiration of the three-year period. Condition: As part of our statistically valid random sample of sixty non-payroll disbursements from the District’s grant expenditures from major programs, we observed the following instances where information required to ensure that these expenditures fulfilled requirements of 2 CFR Part 200 as follows was not obtained by the District or was otherwise unavailable for our examination:  Sixteen instances where there was no documentation to determine the District obtained the required information to ensure that the vendor was not suspended or debarred.  One instance where there was no invoice or credit memo to support the transaction.  Numerous instances where an invoice was not included in the paid invoice. These invoices were made available to us for our examination on our fourth request Context/ Perspective: This finding is based on our statistically valid random sample of sixty non-payroll cash disbursements charged to major programs of the District. Effect: Failure to follow the federal and state requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls as necessary to ensure that proper records are maintained to adequately document its expenditures charged to federal grant programs. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.010A - Title I Grants To Local Educational Agencies Assistance Listing: 84.027/84.027X/84.173/84.173X – Special Education Cluster (IDEA) Repeat Finding: Yes Criteria: Section 2 CFR 200 and other federal regulations require that payroll expenditures for a grant be documented with accurate records reflecting the work performed by each employee. This includes maintaining time sheets, pay stubs, and other payroll records to ensure charges are allowable, accurate, and properly allocated to the specific grant. These records must be kept for at least three years after the final financial report is submitted. Subgrantees must also ensure that employees paid with federal funds maintain time distribution records, known as time and effort reports. Specifically, Section 200.430 states: “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the changes are accurate, allowable, and properly allocated. Condition: The District’s its present internal control policies and procedures are not sufficient to ensure compliance with controls contained in the District’s Federal Programs Procedural Handbook as well as requirements contained in Section 2 CFR 200. As a result of our statistically valid random sample of forty payroll disbursements included in grant expenditures for the major federal programs, we observed the following:  One instance where the salary approved by the board was more than the salary paid to the employee.  One instance where an employee’s time sheets were not approved by their direct supervisor.  Six instances where we were unable to observe the required semi-annual certifications for employees working under a single cost objective.  Two instances where we were unable to observe pro-rated timesheets for employees that work on multiple cost objectives. Context/ Perspective: This finding is a result of our statistically valid random sample of forty payroll cash disbursements for single audit purposes. Cause: The cause is likely a failure to monitor and fulfill the District’s present internal controls. Effect: Failure to follow the federal requirements could affect future eligibility for federal award programs or could result in a loss or misappropriation of public assets. Questioned Costs: None Recommendation: We recommend that the District implement additional internal controls to ensure that the District maintains the required payroll documentation as well as the required semi-annual certifications necessary for employees who work on a single cost objective and are paid through federal grants and prorated timesheets that are necessary for employees who work on multiple cost objectives. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Repeat Finding: No Criteria: 2 CFR 200.303 requires that a non-federal entity establish, document and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 7 CFR 210.14(g) also requires school food authorities to follow fair and consistent methodologies to identify and allocate allowable indirect costs to the nonprofit school food service account, in accordance with 2 CFR part 200 as implemented by 2 CFR part 400. Condition: Our procedures indicate that the District’s internal control system is inadequate for ensuring that indirect costs charged to various federal grant programs are adequately documented and accurately calculated. Specifically:  Child Nutrition Cluster: The District could not provide documentation of its calculation to support the $25,000 per quarter requested as reimbursement for indirect costs.  Elementary and Secondary School Emergency Relief (ESSER II): The District used an indirect cost rate from a prior year to calculate indirect costs charged to the ESSER II program which resulted in an overcharge of $68,829. Our procedures indicate that the District’s internal control system is insufficient to ensure that the indirect cost charged to the program is accurately calculated and based on calculations that meet the requirements outlined in Sections 2 CFR 200.303, 2 CFR 200.414 and Appendix VII to Part 200. Context/ Perspective: This finding arises from our audit procedures on internal control, where attempted to obtain documentation of the District's calculation and subsequent approval of reimbursement for indirect costs as well as other procedures performed by us recalculating indirect costs charged to certain federal grant programs. Cause: The District lacks the necessary internal controls to ensure that requests for reimbursement of indirect costs are accurately calculated, properly documented and approved by the appropriate director. Effect: The lack of adequate internal controls over the calculation of indirect cost reimbursement may increase the risk of misappropriation or loss of public funds. It could also result in inappropriate charges to the federal award, potentially leading to disallowed costs being applied to the program. Questioned Costs: $68,829 (Elementary and Secondary School Emergency Relief II) Recommendation: The District should implement stronger internal controls to ensure that indirect cost reimbursements are accurately calculated, properly documented, and approved by the appropriate federal grant program director. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Repeat Finding: No Criteria: 2 CFR 200.303 requires that a non-federal entity establish, document and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 7 CFR 210.14(g) also requires school food authorities to follow fair and consistent methodologies to identify and allocate allowable indirect costs to the nonprofit school food service account, in accordance with 2 CFR part 200 as implemented by 2 CFR part 400. Condition: Our procedures indicate that the District’s internal control system is inadequate for ensuring that indirect costs charged to various federal grant programs are adequately documented and accurately calculated. Specifically:  Child Nutrition Cluster: The District could not provide documentation of its calculation to support the $25,000 per quarter requested as reimbursement for indirect costs.  Elementary and Secondary School Emergency Relief (ESSER II): The District used an indirect cost rate from a prior year to calculate indirect costs charged to the ESSER II program which resulted in an overcharge of $68,829. Our procedures indicate that the District’s internal control system is insufficient to ensure that the indirect cost charged to the program is accurately calculated and based on calculations that meet the requirements outlined in Sections 2 CFR 200.303, 2 CFR 200.414 and Appendix VII to Part 200. Context/ Perspective: This finding arises from our audit procedures on internal control, where attempted to obtain documentation of the District's calculation and subsequent approval of reimbursement for indirect costs as well as other procedures performed by us recalculating indirect costs charged to certain federal grant programs. Cause: The District lacks the necessary internal controls to ensure that requests for reimbursement of indirect costs are accurately calculated, properly documented and approved by the appropriate director. Effect: The lack of adequate internal controls over the calculation of indirect cost reimbursement may increase the risk of misappropriation or loss of public funds. It could also result in inappropriate charges to the federal award, potentially leading to disallowed costs being applied to the program. Questioned Costs: $68,829 (Elementary and Secondary School Emergency Relief II) Recommendation: The District should implement stronger internal controls to ensure that indirect cost reimbursements are accurately calculated, properly documented, and approved by the appropriate federal grant program director. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Assistance Listing: 84.425D – Elementary and Secondary School Emergency Relief Fund (ESSER II) Repeat Finding: No Criteria: 2 CFR 200.303 requires that a non-federal entity establish, document and maintain effective internal control over a federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 7 CFR 210.14(g) also requires school food authorities to follow fair and consistent methodologies to identify and allocate allowable indirect costs to the nonprofit school food service account, in accordance with 2 CFR part 200 as implemented by 2 CFR part 400. Condition: Our procedures indicate that the District’s internal control system is inadequate for ensuring that indirect costs charged to various federal grant programs are adequately documented and accurately calculated. Specifically:  Child Nutrition Cluster: The District could not provide documentation of its calculation to support the $25,000 per quarter requested as reimbursement for indirect costs.  Elementary and Secondary School Emergency Relief (ESSER II): The District used an indirect cost rate from a prior year to calculate indirect costs charged to the ESSER II program which resulted in an overcharge of $68,829. Our procedures indicate that the District’s internal control system is insufficient to ensure that the indirect cost charged to the program is accurately calculated and based on calculations that meet the requirements outlined in Sections 2 CFR 200.303, 2 CFR 200.414 and Appendix VII to Part 200. Context/ Perspective: This finding arises from our audit procedures on internal control, where attempted to obtain documentation of the District's calculation and subsequent approval of reimbursement for indirect costs as well as other procedures performed by us recalculating indirect costs charged to certain federal grant programs. Cause: The District lacks the necessary internal controls to ensure that requests for reimbursement of indirect costs are accurately calculated, properly documented and approved by the appropriate director. Effect: The lack of adequate internal controls over the calculation of indirect cost reimbursement may increase the risk of misappropriation or loss of public funds. It could also result in inappropriate charges to the federal award, potentially leading to disallowed costs being applied to the program. Questioned Costs: $68,829 (Elementary and Secondary School Emergency Relief II) Recommendation: The District should implement stronger internal controls to ensure that indirect cost reimbursements are accurately calculated, properly documented, and approved by the appropriate federal grant program director. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Repeat Finding: No Criteria: Section 7 CFR 210.8 requires the school food authority (SFA) to establish internal controls to ensure the accuracy of meal counts before submitting the monthly Claim for Reimbursement. These controls include:  On-site Review: Each SFA with multiple schools must conduct at least one on-site review each school year, prior to February 1, of the meal counting and claiming system for each school. The review attempts to identify discrepancies in meal counts and compares daily meal data to identify any issues. If problems are found, corrective action must be implemented, and a follow-up review must occur within 45 days to confirm resolution. The review ensures that the meal count system is accurate and compliant with state and federal regulations.  Claims Review Process: Before submitting the Claim for Reimbursement, the SFA must review the lunch count data for each school to verify the accuracy of the claims. The goal is to ensure that only the correct number of reimbursable free, reduced price, and paid meals served to eligible children are included in the claim. Condition: Our procedures indicated that the District’s internal control system is inadequate for ensuring for compliance with federal requirements for preparing claims for reimbursements in the food service program. In performing our procedures, the District did not provide supporting documentation for the month of August which the director stated was prepared using manual calculations because the point-of-sale system was not operational for that month. Our procedures also identified several input errors for several months in entering meals served for individual schools that qualify under the Community Eligibility Program (CEP) for several other months. Context/ Perspective: This finding is a result of our audit procedures over internal control and compliance for one hundred percent of claims for reimbursement in the food service program. Cause: The District lacks the necessary internal controls to ensure that claims for reimbursement for meals served are accurately calculated, properly documented and approved by the food service director. Effect: The lack of adequate internal controls over claims for reimbursement for food service may increase the risk of misappropriation or loss of public funds. It could also result in inappropriate charges to the federal award, potentially leading to disallowed costs being applied to the program. Questioned Costs: None Recommendation: The District should implement additional internal controls to ensure that claims for reimbursements for the food service program are accurately calculated, properly documented, and approved by the food service director. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.

Significant Deficiency Other Noncompliance Program: Assistance Listing: 10.553/10.555 – Child Nutrition Cluster Repeat Finding: No Criteria: Section 7 CFR 210.8 requires the school food authority (SFA) to establish internal controls to ensure the accuracy of meal counts before submitting the monthly Claim for Reimbursement. These controls include:  On-site Review: Each SFA with multiple schools must conduct at least one on-site review each school year, prior to February 1, of the meal counting and claiming system for each school. The review attempts to identify discrepancies in meal counts and compares daily meal data to identify any issues. If problems are found, corrective action must be implemented, and a follow-up review must occur within 45 days to confirm resolution. The review ensures that the meal count system is accurate and compliant with state and federal regulations.  Claims Review Process: Before submitting the Claim for Reimbursement, the SFA must review the lunch count data for each school to verify the accuracy of the claims. The goal is to ensure that only the correct number of reimbursable free, reduced price, and paid meals served to eligible children are included in the claim. Condition: Our procedures indicated that the District’s internal control system is inadequate for ensuring for compliance with federal requirements for preparing claims for reimbursements in the food service program. In performing our procedures, the District did not provide supporting documentation for the month of August which the director stated was prepared using manual calculations because the point-of-sale system was not operational for that month. Our procedures also identified several input errors for several months in entering meals served for individual schools that qualify under the Community Eligibility Program (CEP) for several other months. Context/ Perspective: This finding is a result of our audit procedures over internal control and compliance for one hundred percent of claims for reimbursement in the food service program. Cause: The District lacks the necessary internal controls to ensure that claims for reimbursement for meals served are accurately calculated, properly documented and approved by the food service director. Effect: The lack of adequate internal controls over claims for reimbursement for food service may increase the risk of misappropriation or loss of public funds. It could also result in inappropriate charges to the federal award, potentially leading to disallowed costs being applied to the program. Questioned Costs: None Recommendation: The District should implement additional internal controls to ensure that claims for reimbursements for the food service program are accurately calculated, properly documented, and approved by the food service director. Views of Responsible Officials: The Auditee’s Corrective Action Plan lists the District’s response to the findings.