Audit 357152

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Criteria Per Part 3 of the Compliance Supplement, an auditor is required to test special tests to ensure: (1) “Review the supporting records and ascertain if the applicable data elements were included in the sampled reports. Trace the reported data to records that accumulate and summarize data and (2) perform tests of the underlying data to verify that the data were accumulated and summarized in accordance with the required or stated criteria and methodology, including the accuracy and completeness of the reports”. Furthermore, a “Key Line Item[s]” is that the current year membership listed on the application is tested. Condition During testing of the Impact Aid application, we noted that the District did not use financial information from the correct year and they omitted an entity that should have been listed in the “Work-On Only” section of the submitted application. Questioned Costs N/A Context During testing of the submitted Impact Aid application, we noted that the District used the financial information from their FY22 application. Also, we noted that the District omitted an entity from the “Work-On Only” section of the application. Effect The District is not in compliance with Uniform Guidance’s reporting requirements. Cause Management oversight. Recommendation We recommend the District implement policies and procedures to ensure required reports submitted are done so accurately. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Internal Control – Material Weakness Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Criteria A system of internal controls requires all transactions to be properly approved, in addition expenditures should be supported by vendor invoices. Condition During transaction testing, we noted the following items: Title I Three transactions where the approver approved over their allowed threshold. ESF Two transactions that were supported by vendor statements instead of invoices. Questioned Costs N/A Context Title I In a population of over 250, a sample of 40 transactions were tested of which 28 of these were non-payroll transactions. In these 28 transactions, we noted 3 in which the approver had approved an amount in excess of their allowed threshold. ESF In a population of over 250, a sample of 40 transactions were tested of which 36 of these were non-payroll transactions. In these 36 transactions, we noted 2 of which were supported by vendor statements. Effect Increased risk of charging an unallowed transaction to the program. Cause Management oversight. Recommendation We recommend the District follow their purchasing policy. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Special Tests and Provisions Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: Education Stabilization Fund AL Number: 84.425 Criteria Uniform Guidance requires “all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL)”. Furthermore, “nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)). Condition District did not have the required wage rate verbiage in their signed construction contract. Furthermore, there was no review of the certified payrolls to ensure wages paid were paid according to the wage rate requirements. Questioned Costs Undeterminable Context The District had contracted out one construction project during the period under audit. Effect Wages paid by contractors may not have been in accordance with criteria identified above. Cause Management oversight. Recommendation We recommend the District implement policies and procedures to ensure when federal funds are paying for construction in excess of $2,000, that the wage rate requirements are being followed. Repeat Finding This is a repeat finding of 2023-006. Views of Responsible Officials See corrective action plan.

Internal Control – Material Weakness Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Criteria A system of internal controls requires all transactions to be properly approved, in addition expenditures should be supported by vendor invoices. Condition During transaction testing, we noted the following items: Title I Three transactions where the approver approved over their allowed threshold. ESF Two transactions that were supported by vendor statements instead of invoices. Questioned Costs N/A Context Title I In a population of over 250, a sample of 40 transactions were tested of which 28 of these were non-payroll transactions. In these 28 transactions, we noted 3 in which the approver had approved an amount in excess of their allowed threshold. ESF In a population of over 250, a sample of 40 transactions were tested of which 36 of these were non-payroll transactions. In these 36 transactions, we noted 2 of which were supported by vendor statements. Effect Increased risk of charging an unallowed transaction to the program. Cause Management oversight. Recommendation We recommend the District follow their purchasing policy. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Special Tests and Provisions Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: Education Stabilization Fund AL Number: 84.425 Criteria Uniform Guidance requires “all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL)”. Furthermore, “nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)). Condition District did not have the required wage rate verbiage in their signed construction contract. Furthermore, there was no review of the certified payrolls to ensure wages paid were paid according to the wage rate requirements. Questioned Costs Undeterminable Context The District had contracted out one construction project during the period under audit. Effect Wages paid by contractors may not have been in accordance with criteria identified above. Cause Management oversight. Recommendation We recommend the District implement policies and procedures to ensure when federal funds are paying for construction in excess of $2,000, that the wage rate requirements are being followed. Repeat Finding This is a repeat finding of 2023-006. Views of Responsible Officials See corrective action plan.

Internal Control – Material Weakness Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Criteria A system of internal controls requires all transactions to be properly approved, in addition expenditures should be supported by vendor invoices. Condition During transaction testing, we noted the following items: Title I Three transactions where the approver approved over their allowed threshold. ESF Two transactions that were supported by vendor statements instead of invoices. Questioned Costs N/A Context Title I In a population of over 250, a sample of 40 transactions were tested of which 28 of these were non-payroll transactions. In these 28 transactions, we noted 3 in which the approver had approved an amount in excess of their allowed threshold. ESF In a population of over 250, a sample of 40 transactions were tested of which 36 of these were non-payroll transactions. In these 36 transactions, we noted 2 of which were supported by vendor statements. Effect Increased risk of charging an unallowed transaction to the program. Cause Management oversight. Recommendation We recommend the District follow their purchasing policy. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Special Tests and Provisions Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: Education Stabilization Fund AL Number: 84.425 Criteria Uniform Guidance requires “all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL)”. Furthermore, “nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)). Condition District did not have the required wage rate verbiage in their signed construction contract. Furthermore, there was no review of the certified payrolls to ensure wages paid were paid according to the wage rate requirements. Questioned Costs Undeterminable Context The District had contracted out one construction project during the period under audit. Effect Wages paid by contractors may not have been in accordance with criteria identified above. Cause Management oversight. Recommendation We recommend the District implement policies and procedures to ensure when federal funds are paying for construction in excess of $2,000, that the wage rate requirements are being followed. Repeat Finding This is a repeat finding of 2023-006. Views of Responsible Officials See corrective action plan.

Internal Control – Material Weakness Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Criteria A system of internal controls requires all transactions to be properly approved, in addition expenditures should be supported by vendor invoices. Condition During transaction testing, we noted the following items: Title I Three transactions where the approver approved over their allowed threshold. ESF Two transactions that were supported by vendor statements instead of invoices. Questioned Costs N/A Context Title I In a population of over 250, a sample of 40 transactions were tested of which 28 of these were non-payroll transactions. In these 28 transactions, we noted 3 in which the approver had approved an amount in excess of their allowed threshold. ESF In a population of over 250, a sample of 40 transactions were tested of which 36 of these were non-payroll transactions. In these 36 transactions, we noted 2 of which were supported by vendor statements. Effect Increased risk of charging an unallowed transaction to the program. Cause Management oversight. Recommendation We recommend the District follow their purchasing policy. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Agriculture Title: Child Nutrition Cluster Pass-Through Entity: North Dakota State Department of Public Instruction AL Number: 10.553/10.555/10.559 Criteria In accordance with 7 CFR Section 210.8, the District shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly claim for reimbursement. Condition The District reported inaccurate meal counts for reimbursement reporting. Questioned Costs Undeterminable. Context Of nine months of reimbursements submitted for reimbursed, we tested two months. We noted variances in the reporting of breakfast and lunch meals served. Breakfast meals were understated by 596 meals and lunch meals were understated by 883 meals. Effect Inaccurate reimbursements for meals provided resulting in inaccurate revenues received. Cause Management oversight. Recommendation We recommend the District put policies and procedures in place to ensure all reimbursement reports are reviewed and approved by an individual outside of the preparation process prior to being submitted. Repeat Finding This is a repeat finding of 2023-005. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Agriculture Title: Child Nutrition Cluster Pass-Through Entity: North Dakota State Department of Public Instruction AL Number: 10.553/10.555/10.559 Criteria In accordance with 7 CFR Section 210.8, the District shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly claim for reimbursement. Condition The District reported inaccurate meal counts for reimbursement reporting. Questioned Costs Undeterminable. Context Of nine months of reimbursements submitted for reimbursed, we tested two months. We noted variances in the reporting of breakfast and lunch meals served. Breakfast meals were understated by 596 meals and lunch meals were understated by 883 meals. Effect Inaccurate reimbursements for meals provided resulting in inaccurate revenues received. Cause Management oversight. Recommendation We recommend the District put policies and procedures in place to ensure all reimbursement reports are reviewed and approved by an individual outside of the preparation process prior to being submitted. Repeat Finding This is a repeat finding of 2023-005. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Agriculture Title: Child Nutrition Cluster Pass-Through Entity: North Dakota State Department of Public Instruction AL Number: 10.553/10.555/10.559 Criteria In accordance with 7 CFR Section 210.8, the District shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly claim for reimbursement. Condition The District reported inaccurate meal counts for reimbursement reporting. Questioned Costs Undeterminable. Context Of nine months of reimbursements submitted for reimbursed, we tested two months. We noted variances in the reporting of breakfast and lunch meals served. Breakfast meals were understated by 596 meals and lunch meals were understated by 883 meals. Effect Inaccurate reimbursements for meals provided resulting in inaccurate revenues received. Cause Management oversight. Recommendation We recommend the District put policies and procedures in place to ensure all reimbursement reports are reviewed and approved by an individual outside of the preparation process prior to being submitted. Repeat Finding This is a repeat finding of 2023-005. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Agriculture Title: Child Nutrition Cluster Pass-Through Entity: North Dakota State Department of Public Instruction AL Number: 10.553/10.555/10.559 Criteria In accordance with 7 CFR Section 210.8, the District shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly claim for reimbursement. Condition The District reported inaccurate meal counts for reimbursement reporting. Questioned Costs Undeterminable. Context Of nine months of reimbursements submitted for reimbursed, we tested two months. We noted variances in the reporting of breakfast and lunch meals served. Breakfast meals were understated by 596 meals and lunch meals were understated by 883 meals. Effect Inaccurate reimbursements for meals provided resulting in inaccurate revenues received. Cause Management oversight. Recommendation We recommend the District put policies and procedures in place to ensure all reimbursement reports are reviewed and approved by an individual outside of the preparation process prior to being submitted. Repeat Finding This is a repeat finding of 2023-005. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Agriculture Title: Child Nutrition Cluster Pass-Through Entity: North Dakota State Department of Public Instruction AL Number: 10.553/10.555/10.559 Criteria In accordance with 7 CFR Section 210.8, the District shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly claim for reimbursement. Condition The District reported inaccurate meal counts for reimbursement reporting. Questioned Costs Undeterminable. Context Of nine months of reimbursements submitted for reimbursed, we tested two months. We noted variances in the reporting of breakfast and lunch meals served. Breakfast meals were understated by 596 meals and lunch meals were understated by 883 meals. Effect Inaccurate reimbursements for meals provided resulting in inaccurate revenues received. Cause Management oversight. Recommendation We recommend the District put policies and procedures in place to ensure all reimbursement reports are reviewed and approved by an individual outside of the preparation process prior to being submitted. Repeat Finding This is a repeat finding of 2023-005. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Criteria Per Part 3 of the Compliance Supplement, an auditor is required to test special tests to ensure: (1) “Review the supporting records and ascertain if the applicable data elements were included in the sampled reports. Trace the reported data to records that accumulate and summarize data and (2) perform tests of the underlying data to verify that the data were accumulated and summarized in accordance with the required or stated criteria and methodology, including the accuracy and completeness of the reports”. Furthermore, a “Key Line Item[s]” is that the current year membership listed on the application is tested. Condition During testing of the Impact Aid application, we noted that the District did not use financial information from the correct year and they omitted an entity that should have been listed in the “Work-On Only” section of the submitted application. Questioned Costs N/A Context During testing of the submitted Impact Aid application, we noted that the District used the financial information from their FY22 application. Also, we noted that the District omitted an entity from the “Work-On Only” section of the application. Effect The District is not in compliance with Uniform Guidance’s reporting requirements. Cause Management oversight. Recommendation We recommend the District implement policies and procedures to ensure required reports submitted are done so accurately. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Internal Control – Material Weakness Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Criteria A system of internal controls requires all transactions to be properly approved, in addition expenditures should be supported by vendor invoices. Condition During transaction testing, we noted the following items: Title I Three transactions where the approver approved over their allowed threshold. ESF Two transactions that were supported by vendor statements instead of invoices. Questioned Costs N/A Context Title I In a population of over 250, a sample of 40 transactions were tested of which 28 of these were non-payroll transactions. In these 28 transactions, we noted 3 in which the approver had approved an amount in excess of their allowed threshold. ESF In a population of over 250, a sample of 40 transactions were tested of which 36 of these were non-payroll transactions. In these 36 transactions, we noted 2 of which were supported by vendor statements. Effect Increased risk of charging an unallowed transaction to the program. Cause Management oversight. Recommendation We recommend the District follow their purchasing policy. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Special Tests and Provisions Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: Education Stabilization Fund AL Number: 84.425 Criteria Uniform Guidance requires “all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL)”. Furthermore, “nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)). Condition District did not have the required wage rate verbiage in their signed construction contract. Furthermore, there was no review of the certified payrolls to ensure wages paid were paid according to the wage rate requirements. Questioned Costs Undeterminable Context The District had contracted out one construction project during the period under audit. Effect Wages paid by contractors may not have been in accordance with criteria identified above. Cause Management oversight. Recommendation We recommend the District implement policies and procedures to ensure when federal funds are paying for construction in excess of $2,000, that the wage rate requirements are being followed. Repeat Finding This is a repeat finding of 2023-006. Views of Responsible Officials See corrective action plan.

Internal Control – Material Weakness Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Criteria A system of internal controls requires all transactions to be properly approved, in addition expenditures should be supported by vendor invoices. Condition During transaction testing, we noted the following items: Title I Three transactions where the approver approved over their allowed threshold. ESF Two transactions that were supported by vendor statements instead of invoices. Questioned Costs N/A Context Title I In a population of over 250, a sample of 40 transactions were tested of which 28 of these were non-payroll transactions. In these 28 transactions, we noted 3 in which the approver had approved an amount in excess of their allowed threshold. ESF In a population of over 250, a sample of 40 transactions were tested of which 36 of these were non-payroll transactions. In these 36 transactions, we noted 2 of which were supported by vendor statements. Effect Increased risk of charging an unallowed transaction to the program. Cause Management oversight. Recommendation We recommend the District follow their purchasing policy. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Special Tests and Provisions Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: Education Stabilization Fund AL Number: 84.425 Criteria Uniform Guidance requires “all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL)”. Furthermore, “nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)). Condition District did not have the required wage rate verbiage in their signed construction contract. Furthermore, there was no review of the certified payrolls to ensure wages paid were paid according to the wage rate requirements. Questioned Costs Undeterminable Context The District had contracted out one construction project during the period under audit. Effect Wages paid by contractors may not have been in accordance with criteria identified above. Cause Management oversight. Recommendation We recommend the District implement policies and procedures to ensure when federal funds are paying for construction in excess of $2,000, that the wage rate requirements are being followed. Repeat Finding This is a repeat finding of 2023-006. Views of Responsible Officials See corrective action plan.

Internal Control – Material Weakness Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Criteria A system of internal controls requires all transactions to be properly approved, in addition expenditures should be supported by vendor invoices. Condition During transaction testing, we noted the following items: Title I Three transactions where the approver approved over their allowed threshold. ESF Two transactions that were supported by vendor statements instead of invoices. Questioned Costs N/A Context Title I In a population of over 250, a sample of 40 transactions were tested of which 28 of these were non-payroll transactions. In these 28 transactions, we noted 3 in which the approver had approved an amount in excess of their allowed threshold. ESF In a population of over 250, a sample of 40 transactions were tested of which 36 of these were non-payroll transactions. In these 36 transactions, we noted 2 of which were supported by vendor statements. Effect Increased risk of charging an unallowed transaction to the program. Cause Management oversight. Recommendation We recommend the District follow their purchasing policy. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Special Tests and Provisions Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: Education Stabilization Fund AL Number: 84.425 Criteria Uniform Guidance requires “all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL)”. Furthermore, “nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)). Condition District did not have the required wage rate verbiage in their signed construction contract. Furthermore, there was no review of the certified payrolls to ensure wages paid were paid according to the wage rate requirements. Questioned Costs Undeterminable Context The District had contracted out one construction project during the period under audit. Effect Wages paid by contractors may not have been in accordance with criteria identified above. Cause Management oversight. Recommendation We recommend the District implement policies and procedures to ensure when federal funds are paying for construction in excess of $2,000, that the wage rate requirements are being followed. Repeat Finding This is a repeat finding of 2023-006. Views of Responsible Officials See corrective action plan.

Internal Control – Material Weakness Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Criteria A system of internal controls requires all transactions to be properly approved, in addition expenditures should be supported by vendor invoices. Condition During transaction testing, we noted the following items: Title I Three transactions where the approver approved over their allowed threshold. ESF Two transactions that were supported by vendor statements instead of invoices. Questioned Costs N/A Context Title I In a population of over 250, a sample of 40 transactions were tested of which 28 of these were non-payroll transactions. In these 28 transactions, we noted 3 in which the approver had approved an amount in excess of their allowed threshold. ESF In a population of over 250, a sample of 40 transactions were tested of which 36 of these were non-payroll transactions. In these 36 transactions, we noted 2 of which were supported by vendor statements. Effect Increased risk of charging an unallowed transaction to the program. Cause Management oversight. Recommendation We recommend the District follow their purchasing policy. Repeat Finding This is not a repeat finding. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Agriculture Title: Child Nutrition Cluster Pass-Through Entity: North Dakota State Department of Public Instruction AL Number: 10.553/10.555/10.559 Criteria In accordance with 7 CFR Section 210.8, the District shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly claim for reimbursement. Condition The District reported inaccurate meal counts for reimbursement reporting. Questioned Costs Undeterminable. Context Of nine months of reimbursements submitted for reimbursed, we tested two months. We noted variances in the reporting of breakfast and lunch meals served. Breakfast meals were understated by 596 meals and lunch meals were understated by 883 meals. Effect Inaccurate reimbursements for meals provided resulting in inaccurate revenues received. Cause Management oversight. Recommendation We recommend the District put policies and procedures in place to ensure all reimbursement reports are reviewed and approved by an individual outside of the preparation process prior to being submitted. Repeat Finding This is a repeat finding of 2023-005. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Agriculture Title: Child Nutrition Cluster Pass-Through Entity: North Dakota State Department of Public Instruction AL Number: 10.553/10.555/10.559 Criteria In accordance with 7 CFR Section 210.8, the District shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly claim for reimbursement. Condition The District reported inaccurate meal counts for reimbursement reporting. Questioned Costs Undeterminable. Context Of nine months of reimbursements submitted for reimbursed, we tested two months. We noted variances in the reporting of breakfast and lunch meals served. Breakfast meals were understated by 596 meals and lunch meals were understated by 883 meals. Effect Inaccurate reimbursements for meals provided resulting in inaccurate revenues received. Cause Management oversight. Recommendation We recommend the District put policies and procedures in place to ensure all reimbursement reports are reviewed and approved by an individual outside of the preparation process prior to being submitted. Repeat Finding This is a repeat finding of 2023-005. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Agriculture Title: Child Nutrition Cluster Pass-Through Entity: North Dakota State Department of Public Instruction AL Number: 10.553/10.555/10.559 Criteria In accordance with 7 CFR Section 210.8, the District shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly claim for reimbursement. Condition The District reported inaccurate meal counts for reimbursement reporting. Questioned Costs Undeterminable. Context Of nine months of reimbursements submitted for reimbursed, we tested two months. We noted variances in the reporting of breakfast and lunch meals served. Breakfast meals were understated by 596 meals and lunch meals were understated by 883 meals. Effect Inaccurate reimbursements for meals provided resulting in inaccurate revenues received. Cause Management oversight. Recommendation We recommend the District put policies and procedures in place to ensure all reimbursement reports are reviewed and approved by an individual outside of the preparation process prior to being submitted. Repeat Finding This is a repeat finding of 2023-005. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Agriculture Title: Child Nutrition Cluster Pass-Through Entity: North Dakota State Department of Public Instruction AL Number: 10.553/10.555/10.559 Criteria In accordance with 7 CFR Section 210.8, the District shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly claim for reimbursement. Condition The District reported inaccurate meal counts for reimbursement reporting. Questioned Costs Undeterminable. Context Of nine months of reimbursements submitted for reimbursed, we tested two months. We noted variances in the reporting of breakfast and lunch meals served. Breakfast meals were understated by 596 meals and lunch meals were understated by 883 meals. Effect Inaccurate reimbursements for meals provided resulting in inaccurate revenues received. Cause Management oversight. Recommendation We recommend the District put policies and procedures in place to ensure all reimbursement reports are reviewed and approved by an individual outside of the preparation process prior to being submitted. Repeat Finding This is a repeat finding of 2023-005. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Title: Title I Grants to Local Educational Agencies AL Number: 84.010 Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Funding Agency: U.S. Department of Education Pass-Through Entity: North Dakota State Department of Public Instruction Pass-Through Entity: North Dakota State Department of Health and Human Services Title: ESF AL Number: 84.425 Funding Agency: U.S. Department of Agriculture Pass-Through Entity: North Dakota State Department of Public Instruction Title: Child Nutrition Cluster AL Number: 10.553/10.555/10.559 Criteria To provide reasonable assurance that the reporting requirement to timely file the annual audited financial statements with the Federal Audit Clearinghouse within nine months of the District’s year end is met. Condition The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Questioned Costs Not Applicable Context The District’s June 30, 2024 audited financial statements were not filed with the Federal Audit Clearinghouse within nine months of the District’s year end. Effect Non-compliance with Uniform Guidance reporting requirements. Cause The District did not contract for audit until after the filing deadline. Recommendation Controls should be implemented to contract for audit prior to audit deadline to ensure the District’s financial statements are audited and filed with the Federal Audit Clearinghouse within nine months of each year end. Repeat Finding This is a repeat finding of 2023-004. Views of Responsible Officials See corrective action plan.

Reporting Federal Program Information Funding Agency: U.S. Department of Agriculture Title: Child Nutrition Cluster Pass-Through Entity: North Dakota State Department of Public Instruction AL Number: 10.553/10.555/10.559 Criteria In accordance with 7 CFR Section 210.8, the District shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly claim for reimbursement. Condition The District reported inaccurate meal counts for reimbursement reporting. Questioned Costs Undeterminable. Context Of nine months of reimbursements submitted for reimbursed, we tested two months. We noted variances in the reporting of breakfast and lunch meals served. Breakfast meals were understated by 596 meals and lunch meals were understated by 883 meals. Effect Inaccurate reimbursements for meals provided resulting in inaccurate revenues received. Cause Management oversight. Recommendation We recommend the District put policies and procedures in place to ensure all reimbursement reports are reviewed and approved by an individual outside of the preparation process prior to being submitted. Repeat Finding This is a repeat finding of 2023-005. Views of Responsible Officials See corrective action plan.