2024-006 Unauthorized Use of Child Nutrition Funds
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: Repeat; see prior year finding #2023-005 and #2023-006.
Federal Program: Child Nutrition Cluster (ALNs 10.553, 10.555, 10.582)
Federal Agency: U.S. Department of Agriculture
Pass-through Entity and
Identifying Numbers:
Texas Department of Agriculture (NT4XL1YGLGC5), Texas Education Agency (71402401, 71302401)
Compliance
Requirement(s):
A - Activities Allowed or Unallowed, B - Allowable Costs / Costs Principles
Criteria: Under 2CFR200.403 and 2CFR200.405, federal program costs must be allocable to the program,
allowable under applicable federal cost principles, and properly supported by accounting records.
Additionally, the Texas Department of Agriculture (TDA) and federal program guidelines require that
Child Nutrition funds be accounted for separately and used solely for the operation of the school
food service program. All uses of funds must be properly documented and justified to ensure
restricted federal funds are not used for unallowable general government purposes.
Condition: The district’s general ledger and cash transfer records indicated that funds were transferred between
the Child Nutrition Service (CNS) fund and the general fund during the year. Due to inadequate
tracking and reconciliation controls, the district was unable to provide clear documentation
demonstrating that restricted CNS funds were used solely for allowable Child Nutrition Cluster
program expenditures and were not applied to general fund purposes. As a result, the auditors were
unable to fully verify that all CNS program expenditures were allowable under federal requirements.
Cause: The district did not have adequate internal controls to track, reconcile, and document transfers of
restricted CNS funds. Turnover in key finance positions and implementation of new finance software
contributed to the weak oversight over cash transfers between funds.
Effect or Potential Effect: There is a risk that restricted federal Child Nutrition funds were used for unallowable general fund
expenditures, potentially resulting in noncompliance with federal cost principles. Although the
auditors did not identify specific questioned costs, the district’s lack of clear tracking and
documentation limits the ability to demonstrate compliance and increases the risk of future
unallowable expenditures.
Questioned Costs: None identified, as auditors were unable to quantify specific unallowable costs due to the lack of
sufficient documentation.
Context During review of the District's response to the corrective action plan, we noted the Child Nutrition
Fund was reimbursed $701,402 for the amount due from the General Fund as of August 31, 2023.
However, due to lack of proper reconciliation controls during fiscal year 2024, we were unable to
determine the general fund was reimbursed for additional improper transfers that could have
occurred during the year.
Recommendation: We recommend the district strengthen internal controls by establishing clear written procedures for
tracking, approving, and reconciling any transfers between the CNS fund and the general fund. The
district should ensure all restricted Child Nutrition funds are used solely for allowable program
purposes, consistent with federal and state requirements. Staff responsible for financial oversight
should receive training on federal cost principles and documentation standards to ensure continued
compliance.
Views of Responsible
Officials:
District officials agree with the finding. The District will review transfers made after September 1,
2022 to determine if made in compliance with legal restrictions.
2024-006 Unauthorized Use of Child Nutrition Funds
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: Repeat; see prior year finding #2023-005 and #2023-006.
Federal Program: Child Nutrition Cluster (ALNs 10.553, 10.555, 10.582)
Federal Agency: U.S. Department of Agriculture
Pass-through Entity and
Identifying Numbers:
Texas Department of Agriculture (NT4XL1YGLGC5), Texas Education Agency (71402401, 71302401)
Compliance
Requirement(s):
A - Activities Allowed or Unallowed, B - Allowable Costs / Costs Principles
Criteria: Under 2CFR200.403 and 2CFR200.405, federal program costs must be allocable to the program,
allowable under applicable federal cost principles, and properly supported by accounting records.
Additionally, the Texas Department of Agriculture (TDA) and federal program guidelines require that
Child Nutrition funds be accounted for separately and used solely for the operation of the school
food service program. All uses of funds must be properly documented and justified to ensure
restricted federal funds are not used for unallowable general government purposes.
Condition: The district’s general ledger and cash transfer records indicated that funds were transferred between
the Child Nutrition Service (CNS) fund and the general fund during the year. Due to inadequate
tracking and reconciliation controls, the district was unable to provide clear documentation
demonstrating that restricted CNS funds were used solely for allowable Child Nutrition Cluster
program expenditures and were not applied to general fund purposes. As a result, the auditors were
unable to fully verify that all CNS program expenditures were allowable under federal requirements.
Cause: The district did not have adequate internal controls to track, reconcile, and document transfers of
restricted CNS funds. Turnover in key finance positions and implementation of new finance software
contributed to the weak oversight over cash transfers between funds.
Effect or Potential Effect: There is a risk that restricted federal Child Nutrition funds were used for unallowable general fund
expenditures, potentially resulting in noncompliance with federal cost principles. Although the
auditors did not identify specific questioned costs, the district’s lack of clear tracking and
documentation limits the ability to demonstrate compliance and increases the risk of future
unallowable expenditures.
Questioned Costs: None identified, as auditors were unable to quantify specific unallowable costs due to the lack of
sufficient documentation.
Context During review of the District's response to the corrective action plan, we noted the Child Nutrition
Fund was reimbursed $701,402 for the amount due from the General Fund as of August 31, 2023.
However, due to lack of proper reconciliation controls during fiscal year 2024, we were unable to
determine the general fund was reimbursed for additional improper transfers that could have
occurred during the year.
Recommendation: We recommend the district strengthen internal controls by establishing clear written procedures for
tracking, approving, and reconciling any transfers between the CNS fund and the general fund. The
district should ensure all restricted Child Nutrition funds are used solely for allowable program
purposes, consistent with federal and state requirements. Staff responsible for financial oversight
should receive training on federal cost principles and documentation standards to ensure continued
compliance.
Views of Responsible
Officials:
District officials agree with the finding. The District will review transfers made after September 1,
2022 to determine if made in compliance with legal restrictions.
2024-006 Unauthorized Use of Child Nutrition Funds
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: Repeat; see prior year finding #2023-005 and #2023-006.
Federal Program: Child Nutrition Cluster (ALNs 10.553, 10.555, 10.582)
Federal Agency: U.S. Department of Agriculture
Pass-through Entity and
Identifying Numbers:
Texas Department of Agriculture (NT4XL1YGLGC5), Texas Education Agency (71402401, 71302401)
Compliance
Requirement(s):
A - Activities Allowed or Unallowed, B - Allowable Costs / Costs Principles
Criteria: Under 2CFR200.403 and 2CFR200.405, federal program costs must be allocable to the program,
allowable under applicable federal cost principles, and properly supported by accounting records.
Additionally, the Texas Department of Agriculture (TDA) and federal program guidelines require that
Child Nutrition funds be accounted for separately and used solely for the operation of the school
food service program. All uses of funds must be properly documented and justified to ensure
restricted federal funds are not used for unallowable general government purposes.
Condition: The district’s general ledger and cash transfer records indicated that funds were transferred between
the Child Nutrition Service (CNS) fund and the general fund during the year. Due to inadequate
tracking and reconciliation controls, the district was unable to provide clear documentation
demonstrating that restricted CNS funds were used solely for allowable Child Nutrition Cluster
program expenditures and were not applied to general fund purposes. As a result, the auditors were
unable to fully verify that all CNS program expenditures were allowable under federal requirements.
Cause: The district did not have adequate internal controls to track, reconcile, and document transfers of
restricted CNS funds. Turnover in key finance positions and implementation of new finance software
contributed to the weak oversight over cash transfers between funds.
Effect or Potential Effect: There is a risk that restricted federal Child Nutrition funds were used for unallowable general fund
expenditures, potentially resulting in noncompliance with federal cost principles. Although the
auditors did not identify specific questioned costs, the district’s lack of clear tracking and
documentation limits the ability to demonstrate compliance and increases the risk of future
unallowable expenditures.
Questioned Costs: None identified, as auditors were unable to quantify specific unallowable costs due to the lack of
sufficient documentation.
Context During review of the District's response to the corrective action plan, we noted the Child Nutrition
Fund was reimbursed $701,402 for the amount due from the General Fund as of August 31, 2023.
However, due to lack of proper reconciliation controls during fiscal year 2024, we were unable to
determine the general fund was reimbursed for additional improper transfers that could have
occurred during the year.
Recommendation: We recommend the district strengthen internal controls by establishing clear written procedures for
tracking, approving, and reconciling any transfers between the CNS fund and the general fund. The
district should ensure all restricted Child Nutrition funds are used solely for allowable program
purposes, consistent with federal and state requirements. Staff responsible for financial oversight
should receive training on federal cost principles and documentation standards to ensure continued
compliance.
Views of Responsible
Officials:
District officials agree with the finding. The District will review transfers made after September 1,
2022 to determine if made in compliance with legal restrictions.
2024-006 Unauthorized Use of Child Nutrition Funds
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: Repeat; see prior year finding #2023-005 and #2023-006.
Federal Program: Child Nutrition Cluster (ALNs 10.553, 10.555, 10.582)
Federal Agency: U.S. Department of Agriculture
Pass-through Entity and
Identifying Numbers:
Texas Department of Agriculture (NT4XL1YGLGC5), Texas Education Agency (71402401, 71302401)
Compliance
Requirement(s):
A - Activities Allowed or Unallowed, B - Allowable Costs / Costs Principles
Criteria: Under 2CFR200.403 and 2CFR200.405, federal program costs must be allocable to the program,
allowable under applicable federal cost principles, and properly supported by accounting records.
Additionally, the Texas Department of Agriculture (TDA) and federal program guidelines require that
Child Nutrition funds be accounted for separately and used solely for the operation of the school
food service program. All uses of funds must be properly documented and justified to ensure
restricted federal funds are not used for unallowable general government purposes.
Condition: The district’s general ledger and cash transfer records indicated that funds were transferred between
the Child Nutrition Service (CNS) fund and the general fund during the year. Due to inadequate
tracking and reconciliation controls, the district was unable to provide clear documentation
demonstrating that restricted CNS funds were used solely for allowable Child Nutrition Cluster
program expenditures and were not applied to general fund purposes. As a result, the auditors were
unable to fully verify that all CNS program expenditures were allowable under federal requirements.
Cause: The district did not have adequate internal controls to track, reconcile, and document transfers of
restricted CNS funds. Turnover in key finance positions and implementation of new finance software
contributed to the weak oversight over cash transfers between funds.
Effect or Potential Effect: There is a risk that restricted federal Child Nutrition funds were used for unallowable general fund
expenditures, potentially resulting in noncompliance with federal cost principles. Although the
auditors did not identify specific questioned costs, the district’s lack of clear tracking and
documentation limits the ability to demonstrate compliance and increases the risk of future
unallowable expenditures.
Questioned Costs: None identified, as auditors were unable to quantify specific unallowable costs due to the lack of
sufficient documentation.
Context During review of the District's response to the corrective action plan, we noted the Child Nutrition
Fund was reimbursed $701,402 for the amount due from the General Fund as of August 31, 2023.
However, due to lack of proper reconciliation controls during fiscal year 2024, we were unable to
determine the general fund was reimbursed for additional improper transfers that could have
occurred during the year.
Recommendation: We recommend the district strengthen internal controls by establishing clear written procedures for
tracking, approving, and reconciling any transfers between the CNS fund and the general fund. The
district should ensure all restricted Child Nutrition funds are used solely for allowable program
purposes, consistent with federal and state requirements. Staff responsible for financial oversight
should receive training on federal cost principles and documentation standards to ensure continued
compliance.
Views of Responsible
Officials:
District officials agree with the finding. The District will review transfers made after September 1,
2022 to determine if made in compliance with legal restrictions.
2024-006 Unauthorized Use of Child Nutrition Funds
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: Repeat; see prior year finding #2023-005 and #2023-006.
Federal Program: Child Nutrition Cluster (ALNs 10.553, 10.555, 10.582)
Federal Agency: U.S. Department of Agriculture
Pass-through Entity and
Identifying Numbers:
Texas Department of Agriculture (NT4XL1YGLGC5), Texas Education Agency (71402401, 71302401)
Compliance
Requirement(s):
A - Activities Allowed or Unallowed, B - Allowable Costs / Costs Principles
Criteria: Under 2CFR200.403 and 2CFR200.405, federal program costs must be allocable to the program,
allowable under applicable federal cost principles, and properly supported by accounting records.
Additionally, the Texas Department of Agriculture (TDA) and federal program guidelines require that
Child Nutrition funds be accounted for separately and used solely for the operation of the school
food service program. All uses of funds must be properly documented and justified to ensure
restricted federal funds are not used for unallowable general government purposes.
Condition: The district’s general ledger and cash transfer records indicated that funds were transferred between
the Child Nutrition Service (CNS) fund and the general fund during the year. Due to inadequate
tracking and reconciliation controls, the district was unable to provide clear documentation
demonstrating that restricted CNS funds were used solely for allowable Child Nutrition Cluster
program expenditures and were not applied to general fund purposes. As a result, the auditors were
unable to fully verify that all CNS program expenditures were allowable under federal requirements.
Cause: The district did not have adequate internal controls to track, reconcile, and document transfers of
restricted CNS funds. Turnover in key finance positions and implementation of new finance software
contributed to the weak oversight over cash transfers between funds.
Effect or Potential Effect: There is a risk that restricted federal Child Nutrition funds were used for unallowable general fund
expenditures, potentially resulting in noncompliance with federal cost principles. Although the
auditors did not identify specific questioned costs, the district’s lack of clear tracking and
documentation limits the ability to demonstrate compliance and increases the risk of future
unallowable expenditures.
Questioned Costs: None identified, as auditors were unable to quantify specific unallowable costs due to the lack of
sufficient documentation.
Context During review of the District's response to the corrective action plan, we noted the Child Nutrition
Fund was reimbursed $701,402 for the amount due from the General Fund as of August 31, 2023.
However, due to lack of proper reconciliation controls during fiscal year 2024, we were unable to
determine the general fund was reimbursed for additional improper transfers that could have
occurred during the year.
Recommendation: We recommend the district strengthen internal controls by establishing clear written procedures for
tracking, approving, and reconciling any transfers between the CNS fund and the general fund. The
district should ensure all restricted Child Nutrition funds are used solely for allowable program
purposes, consistent with federal and state requirements. Staff responsible for financial oversight
should receive training on federal cost principles and documentation standards to ensure continued
compliance.
Views of Responsible
Officials:
District officials agree with the finding. The District will review transfers made after September 1,
2022 to determine if made in compliance with legal restrictions.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: New
Federal Program: Special Education Cluster (ALNs 84.027, 84.173)
Federal Agency: U.S. Department of Education
Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406,
225350020849025000, 225360020849025360), Region 10 Education Service Center
(236600497110001)
Compliance Requirement: B - Allowable Costs / Costs Principles
Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective,
charges for their salaries must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable, and properly allocated. One allowable method is
through completion of semi-annual certifications signed by the employee or a supervisory official
with firsthand knowledge. These certifications provide assurance that salary costs charged to the
federal program reflects the total activity for which the employee is compensated by the District, not
exceeding 100% of compensated activities.
Condition: The district did not maintain required semi-annual certifications for employees who worked solely on
the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee
worked 100% on the program for the period covered, were missing for all employees.
Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed,
and retained in accordance with federal requirements. Staff turnover and limited awareness of the
documentation rules contributed to the oversight.
Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary
costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported
personnel costs were charged to the program, even if employees were appropriately assigned.
Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures
that employees worked solely on the program. The personnel records of the employees sampled
contained approval of the employee to be hired into the appropriate job duties to be funded by
special education cluster grant funds.
Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees
selected in our sample for testing.
Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual
certifications are prepared, signed, and retained for all employees working solely on federal
programs. The district should provide training to finance and program staff to ensure continued
compliance with federal documentation requirements.
Views of Responsible
Officials:
District officials agree with the finding. The District has implemented new procedures in fiscal year
2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: New
Federal Program: Special Education Cluster (ALNs 84.027, 84.173)
Federal Agency: U.S. Department of Education
Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406,
225350020849025000, 225360020849025360), Region 10 Education Service Center
(236600497110001)
Compliance Requirement: B - Allowable Costs / Costs Principles
Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective,
charges for their salaries must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable, and properly allocated. One allowable method is
through completion of semi-annual certifications signed by the employee or a supervisory official
with firsthand knowledge. These certifications provide assurance that salary costs charged to the
federal program reflects the total activity for which the employee is compensated by the District, not
exceeding 100% of compensated activities.
Condition: The district did not maintain required semi-annual certifications for employees who worked solely on
the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee
worked 100% on the program for the period covered, were missing for all employees.
Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed,
and retained in accordance with federal requirements. Staff turnover and limited awareness of the
documentation rules contributed to the oversight.
Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary
costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported
personnel costs were charged to the program, even if employees were appropriately assigned.
Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures
that employees worked solely on the program. The personnel records of the employees sampled
contained approval of the employee to be hired into the appropriate job duties to be funded by
special education cluster grant funds.
Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees
selected in our sample for testing.
Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual
certifications are prepared, signed, and retained for all employees working solely on federal
programs. The district should provide training to finance and program staff to ensure continued
compliance with federal documentation requirements.
Views of Responsible
Officials:
District officials agree with the finding. The District has implemented new procedures in fiscal year
2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: New
Federal Program: Special Education Cluster (ALNs 84.027, 84.173)
Federal Agency: U.S. Department of Education
Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406,
225350020849025000, 225360020849025360), Region 10 Education Service Center
(236600497110001)
Compliance Requirement: B - Allowable Costs / Costs Principles
Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective,
charges for their salaries must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable, and properly allocated. One allowable method is
through completion of semi-annual certifications signed by the employee or a supervisory official
with firsthand knowledge. These certifications provide assurance that salary costs charged to the
federal program reflects the total activity for which the employee is compensated by the District, not
exceeding 100% of compensated activities.
Condition: The district did not maintain required semi-annual certifications for employees who worked solely on
the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee
worked 100% on the program for the period covered, were missing for all employees.
Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed,
and retained in accordance with federal requirements. Staff turnover and limited awareness of the
documentation rules contributed to the oversight.
Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary
costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported
personnel costs were charged to the program, even if employees were appropriately assigned.
Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures
that employees worked solely on the program. The personnel records of the employees sampled
contained approval of the employee to be hired into the appropriate job duties to be funded by
special education cluster grant funds.
Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees
selected in our sample for testing.
Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual
certifications are prepared, signed, and retained for all employees working solely on federal
programs. The district should provide training to finance and program staff to ensure continued
compliance with federal documentation requirements.
Views of Responsible
Officials:
District officials agree with the finding. The District has implemented new procedures in fiscal year
2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: New
Federal Program: Special Education Cluster (ALNs 84.027, 84.173)
Federal Agency: U.S. Department of Education
Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406,
225350020849025000, 225360020849025360), Region 10 Education Service Center
(236600497110001)
Compliance Requirement: B - Allowable Costs / Costs Principles
Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective,
charges for their salaries must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable, and properly allocated. One allowable method is
through completion of semi-annual certifications signed by the employee or a supervisory official
with firsthand knowledge. These certifications provide assurance that salary costs charged to the
federal program reflects the total activity for which the employee is compensated by the District, not
exceeding 100% of compensated activities.
Condition: The district did not maintain required semi-annual certifications for employees who worked solely on
the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee
worked 100% on the program for the period covered, were missing for all employees.
Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed,
and retained in accordance with federal requirements. Staff turnover and limited awareness of the
documentation rules contributed to the oversight.
Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary
costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported
personnel costs were charged to the program, even if employees were appropriately assigned.
Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures
that employees worked solely on the program. The personnel records of the employees sampled
contained approval of the employee to be hired into the appropriate job duties to be funded by
special education cluster grant funds.
Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees
selected in our sample for testing.
Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual
certifications are prepared, signed, and retained for all employees working solely on federal
programs. The district should provide training to finance and program staff to ensure continued
compliance with federal documentation requirements.
Views of Responsible
Officials:
District officials agree with the finding. The District has implemented new procedures in fiscal year
2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: New
Federal Program: Special Education Cluster (ALNs 84.027, 84.173)
Federal Agency: U.S. Department of Education
Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406,
225350020849025000, 225360020849025360), Region 10 Education Service Center
(236600497110001)
Compliance Requirement: B - Allowable Costs / Costs Principles
Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective,
charges for their salaries must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable, and properly allocated. One allowable method is
through completion of semi-annual certifications signed by the employee or a supervisory official
with firsthand knowledge. These certifications provide assurance that salary costs charged to the
federal program reflects the total activity for which the employee is compensated by the District, not
exceeding 100% of compensated activities.
Condition: The district did not maintain required semi-annual certifications for employees who worked solely on
the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee
worked 100% on the program for the period covered, were missing for all employees.
Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed,
and retained in accordance with federal requirements. Staff turnover and limited awareness of the
documentation rules contributed to the oversight.
Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary
costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported
personnel costs were charged to the program, even if employees were appropriately assigned.
Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures
that employees worked solely on the program. The personnel records of the employees sampled
contained approval of the employee to be hired into the appropriate job duties to be funded by
special education cluster grant funds.
Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees
selected in our sample for testing.
Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual
certifications are prepared, signed, and retained for all employees working solely on federal
programs. The district should provide training to finance and program staff to ensure continued
compliance with federal documentation requirements.
Views of Responsible
Officials:
District officials agree with the finding. The District has implemented new procedures in fiscal year
2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: New
Federal Program: Special Education Cluster (ALNs 84.027, 84.173)
Federal Agency: U.S. Department of Education
Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406,
225350020849025000, 225360020849025360), Region 10 Education Service Center
(236600497110001)
Compliance Requirement: B - Allowable Costs / Costs Principles
Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective,
charges for their salaries must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable, and properly allocated. One allowable method is
through completion of semi-annual certifications signed by the employee or a supervisory official
with firsthand knowledge. These certifications provide assurance that salary costs charged to the
federal program reflects the total activity for which the employee is compensated by the District, not
exceeding 100% of compensated activities.
Condition: The district did not maintain required semi-annual certifications for employees who worked solely on
the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee
worked 100% on the program for the period covered, were missing for all employees.
Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed,
and retained in accordance with federal requirements. Staff turnover and limited awareness of the
documentation rules contributed to the oversight.
Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary
costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported
personnel costs were charged to the program, even if employees were appropriately assigned.
Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures
that employees worked solely on the program. The personnel records of the employees sampled
contained approval of the employee to be hired into the appropriate job duties to be funded by
special education cluster grant funds.
Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees
selected in our sample for testing.
Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual
certifications are prepared, signed, and retained for all employees working solely on federal
programs. The district should provide training to finance and program staff to ensure continued
compliance with federal documentation requirements.
Views of Responsible
Officials:
District officials agree with the finding. The District has implemented new procedures in fiscal year
2025 to ensure semi-annual certifications are completed appropriately.
2024-006 Unauthorized Use of Child Nutrition Funds
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: Repeat; see prior year finding #2023-005 and #2023-006.
Federal Program: Child Nutrition Cluster (ALNs 10.553, 10.555, 10.582)
Federal Agency: U.S. Department of Agriculture
Pass-through Entity and
Identifying Numbers:
Texas Department of Agriculture (NT4XL1YGLGC5), Texas Education Agency (71402401, 71302401)
Compliance
Requirement(s):
A - Activities Allowed or Unallowed, B - Allowable Costs / Costs Principles
Criteria: Under 2CFR200.403 and 2CFR200.405, federal program costs must be allocable to the program,
allowable under applicable federal cost principles, and properly supported by accounting records.
Additionally, the Texas Department of Agriculture (TDA) and federal program guidelines require that
Child Nutrition funds be accounted for separately and used solely for the operation of the school
food service program. All uses of funds must be properly documented and justified to ensure
restricted federal funds are not used for unallowable general government purposes.
Condition: The district’s general ledger and cash transfer records indicated that funds were transferred between
the Child Nutrition Service (CNS) fund and the general fund during the year. Due to inadequate
tracking and reconciliation controls, the district was unable to provide clear documentation
demonstrating that restricted CNS funds were used solely for allowable Child Nutrition Cluster
program expenditures and were not applied to general fund purposes. As a result, the auditors were
unable to fully verify that all CNS program expenditures were allowable under federal requirements.
Cause: The district did not have adequate internal controls to track, reconcile, and document transfers of
restricted CNS funds. Turnover in key finance positions and implementation of new finance software
contributed to the weak oversight over cash transfers between funds.
Effect or Potential Effect: There is a risk that restricted federal Child Nutrition funds were used for unallowable general fund
expenditures, potentially resulting in noncompliance with federal cost principles. Although the
auditors did not identify specific questioned costs, the district’s lack of clear tracking and
documentation limits the ability to demonstrate compliance and increases the risk of future
unallowable expenditures.
Questioned Costs: None identified, as auditors were unable to quantify specific unallowable costs due to the lack of
sufficient documentation.
Context During review of the District's response to the corrective action plan, we noted the Child Nutrition
Fund was reimbursed $701,402 for the amount due from the General Fund as of August 31, 2023.
However, due to lack of proper reconciliation controls during fiscal year 2024, we were unable to
determine the general fund was reimbursed for additional improper transfers that could have
occurred during the year.
Recommendation: We recommend the district strengthen internal controls by establishing clear written procedures for
tracking, approving, and reconciling any transfers between the CNS fund and the general fund. The
district should ensure all restricted Child Nutrition funds are used solely for allowable program
purposes, consistent with federal and state requirements. Staff responsible for financial oversight
should receive training on federal cost principles and documentation standards to ensure continued
compliance.
Views of Responsible
Officials:
District officials agree with the finding. The District will review transfers made after September 1,
2022 to determine if made in compliance with legal restrictions.
2024-006 Unauthorized Use of Child Nutrition Funds
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: Repeat; see prior year finding #2023-005 and #2023-006.
Federal Program: Child Nutrition Cluster (ALNs 10.553, 10.555, 10.582)
Federal Agency: U.S. Department of Agriculture
Pass-through Entity and
Identifying Numbers:
Texas Department of Agriculture (NT4XL1YGLGC5), Texas Education Agency (71402401, 71302401)
Compliance
Requirement(s):
A - Activities Allowed or Unallowed, B - Allowable Costs / Costs Principles
Criteria: Under 2CFR200.403 and 2CFR200.405, federal program costs must be allocable to the program,
allowable under applicable federal cost principles, and properly supported by accounting records.
Additionally, the Texas Department of Agriculture (TDA) and federal program guidelines require that
Child Nutrition funds be accounted for separately and used solely for the operation of the school
food service program. All uses of funds must be properly documented and justified to ensure
restricted federal funds are not used for unallowable general government purposes.
Condition: The district’s general ledger and cash transfer records indicated that funds were transferred between
the Child Nutrition Service (CNS) fund and the general fund during the year. Due to inadequate
tracking and reconciliation controls, the district was unable to provide clear documentation
demonstrating that restricted CNS funds were used solely for allowable Child Nutrition Cluster
program expenditures and were not applied to general fund purposes. As a result, the auditors were
unable to fully verify that all CNS program expenditures were allowable under federal requirements.
Cause: The district did not have adequate internal controls to track, reconcile, and document transfers of
restricted CNS funds. Turnover in key finance positions and implementation of new finance software
contributed to the weak oversight over cash transfers between funds.
Effect or Potential Effect: There is a risk that restricted federal Child Nutrition funds were used for unallowable general fund
expenditures, potentially resulting in noncompliance with federal cost principles. Although the
auditors did not identify specific questioned costs, the district’s lack of clear tracking and
documentation limits the ability to demonstrate compliance and increases the risk of future
unallowable expenditures.
Questioned Costs: None identified, as auditors were unable to quantify specific unallowable costs due to the lack of
sufficient documentation.
Context During review of the District's response to the corrective action plan, we noted the Child Nutrition
Fund was reimbursed $701,402 for the amount due from the General Fund as of August 31, 2023.
However, due to lack of proper reconciliation controls during fiscal year 2024, we were unable to
determine the general fund was reimbursed for additional improper transfers that could have
occurred during the year.
Recommendation: We recommend the district strengthen internal controls by establishing clear written procedures for
tracking, approving, and reconciling any transfers between the CNS fund and the general fund. The
district should ensure all restricted Child Nutrition funds are used solely for allowable program
purposes, consistent with federal and state requirements. Staff responsible for financial oversight
should receive training on federal cost principles and documentation standards to ensure continued
compliance.
Views of Responsible
Officials:
District officials agree with the finding. The District will review transfers made after September 1,
2022 to determine if made in compliance with legal restrictions.
2024-006 Unauthorized Use of Child Nutrition Funds
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: Repeat; see prior year finding #2023-005 and #2023-006.
Federal Program: Child Nutrition Cluster (ALNs 10.553, 10.555, 10.582)
Federal Agency: U.S. Department of Agriculture
Pass-through Entity and
Identifying Numbers:
Texas Department of Agriculture (NT4XL1YGLGC5), Texas Education Agency (71402401, 71302401)
Compliance
Requirement(s):
A - Activities Allowed or Unallowed, B - Allowable Costs / Costs Principles
Criteria: Under 2CFR200.403 and 2CFR200.405, federal program costs must be allocable to the program,
allowable under applicable federal cost principles, and properly supported by accounting records.
Additionally, the Texas Department of Agriculture (TDA) and federal program guidelines require that
Child Nutrition funds be accounted for separately and used solely for the operation of the school
food service program. All uses of funds must be properly documented and justified to ensure
restricted federal funds are not used for unallowable general government purposes.
Condition: The district’s general ledger and cash transfer records indicated that funds were transferred between
the Child Nutrition Service (CNS) fund and the general fund during the year. Due to inadequate
tracking and reconciliation controls, the district was unable to provide clear documentation
demonstrating that restricted CNS funds were used solely for allowable Child Nutrition Cluster
program expenditures and were not applied to general fund purposes. As a result, the auditors were
unable to fully verify that all CNS program expenditures were allowable under federal requirements.
Cause: The district did not have adequate internal controls to track, reconcile, and document transfers of
restricted CNS funds. Turnover in key finance positions and implementation of new finance software
contributed to the weak oversight over cash transfers between funds.
Effect or Potential Effect: There is a risk that restricted federal Child Nutrition funds were used for unallowable general fund
expenditures, potentially resulting in noncompliance with federal cost principles. Although the
auditors did not identify specific questioned costs, the district’s lack of clear tracking and
documentation limits the ability to demonstrate compliance and increases the risk of future
unallowable expenditures.
Questioned Costs: None identified, as auditors were unable to quantify specific unallowable costs due to the lack of
sufficient documentation.
Context During review of the District's response to the corrective action plan, we noted the Child Nutrition
Fund was reimbursed $701,402 for the amount due from the General Fund as of August 31, 2023.
However, due to lack of proper reconciliation controls during fiscal year 2024, we were unable to
determine the general fund was reimbursed for additional improper transfers that could have
occurred during the year.
Recommendation: We recommend the district strengthen internal controls by establishing clear written procedures for
tracking, approving, and reconciling any transfers between the CNS fund and the general fund. The
district should ensure all restricted Child Nutrition funds are used solely for allowable program
purposes, consistent with federal and state requirements. Staff responsible for financial oversight
should receive training on federal cost principles and documentation standards to ensure continued
compliance.
Views of Responsible
Officials:
District officials agree with the finding. The District will review transfers made after September 1,
2022 to determine if made in compliance with legal restrictions.
2024-006 Unauthorized Use of Child Nutrition Funds
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: Repeat; see prior year finding #2023-005 and #2023-006.
Federal Program: Child Nutrition Cluster (ALNs 10.553, 10.555, 10.582)
Federal Agency: U.S. Department of Agriculture
Pass-through Entity and
Identifying Numbers:
Texas Department of Agriculture (NT4XL1YGLGC5), Texas Education Agency (71402401, 71302401)
Compliance
Requirement(s):
A - Activities Allowed or Unallowed, B - Allowable Costs / Costs Principles
Criteria: Under 2CFR200.403 and 2CFR200.405, federal program costs must be allocable to the program,
allowable under applicable federal cost principles, and properly supported by accounting records.
Additionally, the Texas Department of Agriculture (TDA) and federal program guidelines require that
Child Nutrition funds be accounted for separately and used solely for the operation of the school
food service program. All uses of funds must be properly documented and justified to ensure
restricted federal funds are not used for unallowable general government purposes.
Condition: The district’s general ledger and cash transfer records indicated that funds were transferred between
the Child Nutrition Service (CNS) fund and the general fund during the year. Due to inadequate
tracking and reconciliation controls, the district was unable to provide clear documentation
demonstrating that restricted CNS funds were used solely for allowable Child Nutrition Cluster
program expenditures and were not applied to general fund purposes. As a result, the auditors were
unable to fully verify that all CNS program expenditures were allowable under federal requirements.
Cause: The district did not have adequate internal controls to track, reconcile, and document transfers of
restricted CNS funds. Turnover in key finance positions and implementation of new finance software
contributed to the weak oversight over cash transfers between funds.
Effect or Potential Effect: There is a risk that restricted federal Child Nutrition funds were used for unallowable general fund
expenditures, potentially resulting in noncompliance with federal cost principles. Although the
auditors did not identify specific questioned costs, the district’s lack of clear tracking and
documentation limits the ability to demonstrate compliance and increases the risk of future
unallowable expenditures.
Questioned Costs: None identified, as auditors were unable to quantify specific unallowable costs due to the lack of
sufficient documentation.
Context During review of the District's response to the corrective action plan, we noted the Child Nutrition
Fund was reimbursed $701,402 for the amount due from the General Fund as of August 31, 2023.
However, due to lack of proper reconciliation controls during fiscal year 2024, we were unable to
determine the general fund was reimbursed for additional improper transfers that could have
occurred during the year.
Recommendation: We recommend the district strengthen internal controls by establishing clear written procedures for
tracking, approving, and reconciling any transfers between the CNS fund and the general fund. The
district should ensure all restricted Child Nutrition funds are used solely for allowable program
purposes, consistent with federal and state requirements. Staff responsible for financial oversight
should receive training on federal cost principles and documentation standards to ensure continued
compliance.
Views of Responsible
Officials:
District officials agree with the finding. The District will review transfers made after September 1,
2022 to determine if made in compliance with legal restrictions.
2024-006 Unauthorized Use of Child Nutrition Funds
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: Repeat; see prior year finding #2023-005 and #2023-006.
Federal Program: Child Nutrition Cluster (ALNs 10.553, 10.555, 10.582)
Federal Agency: U.S. Department of Agriculture
Pass-through Entity and
Identifying Numbers:
Texas Department of Agriculture (NT4XL1YGLGC5), Texas Education Agency (71402401, 71302401)
Compliance
Requirement(s):
A - Activities Allowed or Unallowed, B - Allowable Costs / Costs Principles
Criteria: Under 2CFR200.403 and 2CFR200.405, federal program costs must be allocable to the program,
allowable under applicable federal cost principles, and properly supported by accounting records.
Additionally, the Texas Department of Agriculture (TDA) and federal program guidelines require that
Child Nutrition funds be accounted for separately and used solely for the operation of the school
food service program. All uses of funds must be properly documented and justified to ensure
restricted federal funds are not used for unallowable general government purposes.
Condition: The district’s general ledger and cash transfer records indicated that funds were transferred between
the Child Nutrition Service (CNS) fund and the general fund during the year. Due to inadequate
tracking and reconciliation controls, the district was unable to provide clear documentation
demonstrating that restricted CNS funds were used solely for allowable Child Nutrition Cluster
program expenditures and were not applied to general fund purposes. As a result, the auditors were
unable to fully verify that all CNS program expenditures were allowable under federal requirements.
Cause: The district did not have adequate internal controls to track, reconcile, and document transfers of
restricted CNS funds. Turnover in key finance positions and implementation of new finance software
contributed to the weak oversight over cash transfers between funds.
Effect or Potential Effect: There is a risk that restricted federal Child Nutrition funds were used for unallowable general fund
expenditures, potentially resulting in noncompliance with federal cost principles. Although the
auditors did not identify specific questioned costs, the district’s lack of clear tracking and
documentation limits the ability to demonstrate compliance and increases the risk of future
unallowable expenditures.
Questioned Costs: None identified, as auditors were unable to quantify specific unallowable costs due to the lack of
sufficient documentation.
Context During review of the District's response to the corrective action plan, we noted the Child Nutrition
Fund was reimbursed $701,402 for the amount due from the General Fund as of August 31, 2023.
However, due to lack of proper reconciliation controls during fiscal year 2024, we were unable to
determine the general fund was reimbursed for additional improper transfers that could have
occurred during the year.
Recommendation: We recommend the district strengthen internal controls by establishing clear written procedures for
tracking, approving, and reconciling any transfers between the CNS fund and the general fund. The
district should ensure all restricted Child Nutrition funds are used solely for allowable program
purposes, consistent with federal and state requirements. Staff responsible for financial oversight
should receive training on federal cost principles and documentation standards to ensure continued
compliance.
Views of Responsible
Officials:
District officials agree with the finding. The District will review transfers made after September 1,
2022 to determine if made in compliance with legal restrictions.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: New
Federal Program: Special Education Cluster (ALNs 84.027, 84.173)
Federal Agency: U.S. Department of Education
Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406,
225350020849025000, 225360020849025360), Region 10 Education Service Center
(236600497110001)
Compliance Requirement: B - Allowable Costs / Costs Principles
Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective,
charges for their salaries must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable, and properly allocated. One allowable method is
through completion of semi-annual certifications signed by the employee or a supervisory official
with firsthand knowledge. These certifications provide assurance that salary costs charged to the
federal program reflects the total activity for which the employee is compensated by the District, not
exceeding 100% of compensated activities.
Condition: The district did not maintain required semi-annual certifications for employees who worked solely on
the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee
worked 100% on the program for the period covered, were missing for all employees.
Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed,
and retained in accordance with federal requirements. Staff turnover and limited awareness of the
documentation rules contributed to the oversight.
Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary
costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported
personnel costs were charged to the program, even if employees were appropriately assigned.
Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures
that employees worked solely on the program. The personnel records of the employees sampled
contained approval of the employee to be hired into the appropriate job duties to be funded by
special education cluster grant funds.
Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees
selected in our sample for testing.
Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual
certifications are prepared, signed, and retained for all employees working solely on federal
programs. The district should provide training to finance and program staff to ensure continued
compliance with federal documentation requirements.
Views of Responsible
Officials:
District officials agree with the finding. The District has implemented new procedures in fiscal year
2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: New
Federal Program: Special Education Cluster (ALNs 84.027, 84.173)
Federal Agency: U.S. Department of Education
Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406,
225350020849025000, 225360020849025360), Region 10 Education Service Center
(236600497110001)
Compliance Requirement: B - Allowable Costs / Costs Principles
Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective,
charges for their salaries must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable, and properly allocated. One allowable method is
through completion of semi-annual certifications signed by the employee or a supervisory official
with firsthand knowledge. These certifications provide assurance that salary costs charged to the
federal program reflects the total activity for which the employee is compensated by the District, not
exceeding 100% of compensated activities.
Condition: The district did not maintain required semi-annual certifications for employees who worked solely on
the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee
worked 100% on the program for the period covered, were missing for all employees.
Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed,
and retained in accordance with federal requirements. Staff turnover and limited awareness of the
documentation rules contributed to the oversight.
Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary
costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported
personnel costs were charged to the program, even if employees were appropriately assigned.
Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures
that employees worked solely on the program. The personnel records of the employees sampled
contained approval of the employee to be hired into the appropriate job duties to be funded by
special education cluster grant funds.
Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees
selected in our sample for testing.
Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual
certifications are prepared, signed, and retained for all employees working solely on federal
programs. The district should provide training to finance and program staff to ensure continued
compliance with federal documentation requirements.
Views of Responsible
Officials:
District officials agree with the finding. The District has implemented new procedures in fiscal year
2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: New
Federal Program: Special Education Cluster (ALNs 84.027, 84.173)
Federal Agency: U.S. Department of Education
Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406,
225350020849025000, 225360020849025360), Region 10 Education Service Center
(236600497110001)
Compliance Requirement: B - Allowable Costs / Costs Principles
Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective,
charges for their salaries must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable, and properly allocated. One allowable method is
through completion of semi-annual certifications signed by the employee or a supervisory official
with firsthand knowledge. These certifications provide assurance that salary costs charged to the
federal program reflects the total activity for which the employee is compensated by the District, not
exceeding 100% of compensated activities.
Condition: The district did not maintain required semi-annual certifications for employees who worked solely on
the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee
worked 100% on the program for the period covered, were missing for all employees.
Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed,
and retained in accordance with federal requirements. Staff turnover and limited awareness of the
documentation rules contributed to the oversight.
Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary
costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported
personnel costs were charged to the program, even if employees were appropriately assigned.
Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures
that employees worked solely on the program. The personnel records of the employees sampled
contained approval of the employee to be hired into the appropriate job duties to be funded by
special education cluster grant funds.
Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees
selected in our sample for testing.
Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual
certifications are prepared, signed, and retained for all employees working solely on federal
programs. The district should provide training to finance and program staff to ensure continued
compliance with federal documentation requirements.
Views of Responsible
Officials:
District officials agree with the finding. The District has implemented new procedures in fiscal year
2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: New
Federal Program: Special Education Cluster (ALNs 84.027, 84.173)
Federal Agency: U.S. Department of Education
Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406,
225350020849025000, 225360020849025360), Region 10 Education Service Center
(236600497110001)
Compliance Requirement: B - Allowable Costs / Costs Principles
Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective,
charges for their salaries must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable, and properly allocated. One allowable method is
through completion of semi-annual certifications signed by the employee or a supervisory official
with firsthand knowledge. These certifications provide assurance that salary costs charged to the
federal program reflects the total activity for which the employee is compensated by the District, not
exceeding 100% of compensated activities.
Condition: The district did not maintain required semi-annual certifications for employees who worked solely on
the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee
worked 100% on the program for the period covered, were missing for all employees.
Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed,
and retained in accordance with federal requirements. Staff turnover and limited awareness of the
documentation rules contributed to the oversight.
Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary
costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported
personnel costs were charged to the program, even if employees were appropriately assigned.
Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures
that employees worked solely on the program. The personnel records of the employees sampled
contained approval of the employee to be hired into the appropriate job duties to be funded by
special education cluster grant funds.
Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees
selected in our sample for testing.
Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual
certifications are prepared, signed, and retained for all employees working solely on federal
programs. The district should provide training to finance and program staff to ensure continued
compliance with federal documentation requirements.
Views of Responsible
Officials:
District officials agree with the finding. The District has implemented new procedures in fiscal year
2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: New
Federal Program: Special Education Cluster (ALNs 84.027, 84.173)
Federal Agency: U.S. Department of Education
Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406,
225350020849025000, 225360020849025360), Region 10 Education Service Center
(236600497110001)
Compliance Requirement: B - Allowable Costs / Costs Principles
Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective,
charges for their salaries must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable, and properly allocated. One allowable method is
through completion of semi-annual certifications signed by the employee or a supervisory official
with firsthand knowledge. These certifications provide assurance that salary costs charged to the
federal program reflects the total activity for which the employee is compensated by the District, not
exceeding 100% of compensated activities.
Condition: The district did not maintain required semi-annual certifications for employees who worked solely on
the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee
worked 100% on the program for the period covered, were missing for all employees.
Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed,
and retained in accordance with federal requirements. Staff turnover and limited awareness of the
documentation rules contributed to the oversight.
Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary
costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported
personnel costs were charged to the program, even if employees were appropriately assigned.
Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures
that employees worked solely on the program. The personnel records of the employees sampled
contained approval of the employee to be hired into the appropriate job duties to be funded by
special education cluster grant funds.
Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees
selected in our sample for testing.
Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual
certifications are prepared, signed, and retained for all employees working solely on federal
programs. The district should provide training to finance and program staff to ensure continued
compliance with federal documentation requirements.
Views of Responsible
Officials:
District officials agree with the finding. The District has implemented new procedures in fiscal year
2025 to ensure semi-annual certifications are completed appropriately.
2024-007 Lack of Semi-Annual Certifications for Special Education Personnel
Type of Finding: Material Weakness in Internal Control Over Compliance
New or Repeat Finding: New
Federal Program: Special Education Cluster (ALNs 84.027, 84.173)
Federal Agency: U.S. Department of Education
Pass-through Entity(ies): Texas Education Agency (246600010849086600, 246610010849086610, 66002406,
225350020849025000, 225360020849025360), Region 10 Education Service Center
(236600497110001)
Compliance Requirement: B - Allowable Costs / Costs Principles
Criteria: Under 2 CFR 200.430(g), when employees work solely on a single federal award or cost objective,
charges for their salaries must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable, and properly allocated. One allowable method is
through completion of semi-annual certifications signed by the employee or a supervisory official
with firsthand knowledge. These certifications provide assurance that salary costs charged to the
federal program reflects the total activity for which the employee is compensated by the District, not
exceeding 100% of compensated activities.
Condition: The district did not maintain required semi-annual certifications for employees who worked solely on
the Special Education Cluster (IDEA) programs. These certifications, which confirm that the employee
worked 100% on the program for the period covered, were missing for all employees.
Cause: The district did not have adequate procedures in place to ensure the forms were prepared, signed,
and retained in accordance with federal requirements. Staff turnover and limited awareness of the
documentation rules contributed to the oversight.
Effect or Potential Effect: Without semi-annual certifications, the district lacks required documentation to fully support salary
costs charged to the Special Education Cluster. This raises the risk that unallowable or unsupported
personnel costs were charged to the program, even if employees were appropriately assigned.
Questioned Costs: No questioned costs were identified, as auditors were able to verify through alternative procedures
that employees worked solely on the program. The personnel records of the employees sampled
contained approval of the employee to be hired into the appropriate job duties to be funded by
special education cluster grant funds.
Context: The district was unable to provide required semi-annual certifications for 14 out of 14 employees
selected in our sample for testing.
Recommendation: We recommend that the district develop and implement written procedures to ensure that semiannual
certifications are prepared, signed, and retained for all employees working solely on federal
programs. The district should provide training to finance and program staff to ensure continued
compliance with federal documentation requirements.
Views of Responsible
Officials:
District officials agree with the finding. The District has implemented new procedures in fiscal year
2025 to ensure semi-annual certifications are completed appropriately.