Audit 349366

Federal Program Information: Funding Agency: U.S. Department of Education Title: Impact Aid Federal Assistance Listing: 84.041 Passthrough: State of New Mexico Public Education Department Award Year: 2024 Criteria: 20 U.S.C. Code 7703 – Payments for Eligible Federally Connected Children (a)Computation of payment (1)In general For the purpose of computing the amount that a local educational agency is eligible to receive under subsection (b) or (d) for any fiscal year, the Secretary shall determine the number of children who were in average daily attendance in the schools of such agency, and for whom such agency provided free public education, during the preceding school year and who, while in attendance at such schools— (A) (i) resided on Federal property with a parent employed on Federal property situated in whole or in part within the boundaries of the school district of such agency; or (ii) resided on Federal property with a parent who is an official of, and accredited by, a foreign government and is a foreign military officer; (B) resided on Federal property and had a parent on active duty in the uniformed services (as defined in section 101 of title 37); (C) resided on Indian lands; Impact Aid Regulations § 222.35 How does a local educational agency count the membership of its federally connected children? An applicant counts the membership of its federally connected children using one of the following methods: (a) Parent-pupil survey. An applicant may conduct a parent-pupil survey to count the membership of its federally connected children, which must be counted as of the survey date. (b) Source check. A source check is a type of survey tool that groups children being claimed on the Impact Aid application by Federal property. This form is used in lieu of the parent-pupil survey form to substantiate a pupil’s place of residence or parent’s place of employment on the survey date. (1) The source check must include sufficient information to determine the eligibility of the Federal property and the individual children claimed on the form. (2) A source check may also include: (iv) Certification by the Bureau of Indian Affairs (BIA) or authorized tribal official regarding the eligibility of Indian lands. Condition: The District did not have signed parent-pupil surveys for the survey date for the grant funds under audit. The District also did not have a source check form with a listing of the students with a tribal official’s certification. The District did have a source check form with nineteen students listed for the school year during the survey date, but there was no certification by a tribal leader. The District did not make an improvement in this area in the year under audit. The District did change its method for certifying those students for Impact Aid for the 2024-2025 application year to correct this issue. Questioned Costs: $434,103 The District had claimed 71 total students as children living on Federal land, six of which were children with disabilities. As none of these students claimed have valid parent-pupil surveys or a valid source check, all students claimed on the application become questioned costs. The District has received $434,103 from Impact Aid to date based upon this application under audit. Cause: The District had misunderstood the method of counting students for Impact Aid funding and the documentation required to support this funding. The District had been counting students who had certificates of Indian blood no matter where they resided. Effect: The District has been improperly claiming students who did not qualify for funding under the guidelines of Impact Aid. Additionally, the District had not been obtaining the proper certification for those students who would qualify for funding under Impact Aid. As such, funding which the District has been receiving under Impact Aid may be invalid, and the District may be required to return those funds. Auditor’s Recommendation: We recommend that the district put policies and procedures in place to properly identify students who qualify under Impact Aid funding. After identification, we recommend that the District use the source check method to certify those students as this requires obtaining one to three signatures, depending on the number of chapter’s who have students attending Jemez Mountain Schools, rather than attempting to obtain the signature of each parent who’s children qualify because of where they live. We also recommend that the District work to obtain as much certification as possible on the students who were part of this application and any other applications which do not have parent-pupil surveys or source check certifications. Responsible Official’s View:  Specific corrective action plan for finding: The district Superintendent, Federal Programs Manager and Lybrook principal have received training from Impact Aid in identifying eligible students. The recommended process will be used when submitting the next funding application.  Timeline for completion of corrective action plan: June 2025  Employee position(s) responsible for meeting the timeline: Superintendent, Federal Programs Manager, Principals

Federal Program Information: Funding Agency: U.S. Department of Education Title: Impact Aid Federal Assistance Listing: 84.041 Passthrough: State of New Mexico Public Education Department Award Year: 2024 Criteria: 20 U.S.C. Code 7703 – Payments for Eligible Federally Connected Children (a)Computation of payment (1)In general For the purpose of computing the amount that a local educational agency is eligible to receive under subsection (b) or (d) for any fiscal year, the Secretary shall determine the number of children who were in average daily attendance in the schools of such agency, and for whom such agency provided free public education, during the preceding school year and who, while in attendance at such schools— (A) (i) resided on Federal property with a parent employed on Federal property situated in whole or in part within the boundaries of the school district of such agency; or (ii) resided on Federal property with a parent who is an official of, and accredited by, a foreign government and is a foreign military officer; (B) resided on Federal property and had a parent on active duty in the uniformed services (as defined in section 101 of title 37); (C) resided on Indian lands; Impact Aid Regulations § 222.35 How does a local educational agency count the membership of its federally connected children? An applicant counts the membership of its federally connected children using one of the following methods: (a) Parent-pupil survey. An applicant may conduct a parent-pupil survey to count the membership of its federally connected children, which must be counted as of the survey date. (b) Source check. A source check is a type of survey tool that groups children being claimed on the Impact Aid application by Federal property. This form is used in lieu of the parent-pupil survey form to substantiate a pupil’s place of residence or parent’s place of employment on the survey date. (1) The source check must include sufficient information to determine the eligibility of the Federal property and the individual children claimed on the form. (2) A source check may also include: (iv) Certification by the Bureau of Indian Affairs (BIA) or authorized tribal official regarding the eligibility of Indian lands. Condition: The District did not have signed parent-pupil surveys for the survey date for the grant funds under audit. The District also did not have a source check form with a listing of the students with a tribal official’s certification. The District did have a source check form with nineteen students listed for the school year during the survey date, but there was no certification by a tribal leader. The District did not make an improvement in this area in the year under audit. The District did change its method for certifying those students for Impact Aid for the 2024-2025 application year to correct this issue. Questioned Costs: $434,103 The District had claimed 71 total students as children living on Federal land, six of which were children with disabilities. As none of these students claimed have valid parent-pupil surveys or a valid source check, all students claimed on the application become questioned costs. The District has received $434,103 from Impact Aid to date based upon this application under audit. Cause: The District had misunderstood the method of counting students for Impact Aid funding and the documentation required to support this funding. The District had been counting students who had certificates of Indian blood no matter where they resided. Effect: The District has been improperly claiming students who did not qualify for funding under the guidelines of Impact Aid. Additionally, the District had not been obtaining the proper certification for those students who would qualify for funding under Impact Aid. As such, funding which the District has been receiving under Impact Aid may be invalid, and the District may be required to return those funds. Auditor’s Recommendation: We recommend that the district put policies and procedures in place to properly identify students who qualify under Impact Aid funding. After identification, we recommend that the District use the source check method to certify those students as this requires obtaining one to three signatures, depending on the number of chapter’s who have students attending Jemez Mountain Schools, rather than attempting to obtain the signature of each parent who’s children qualify because of where they live. We also recommend that the District work to obtain as much certification as possible on the students who were part of this application and any other applications which do not have parent-pupil surveys or source check certifications. Responsible Official’s View:  Specific corrective action plan for finding: The district Superintendent, Federal Programs Manager and Lybrook principal have received training from Impact Aid in identifying eligible students. The recommended process will be used when submitting the next funding application.  Timeline for completion of corrective action plan: June 2025  Employee position(s) responsible for meeting the timeline: Superintendent, Federal Programs Manager, Principals