Statement of condition: Supporting documentation for expenditures paid from the Education Stabilization Fund did not contain evidence of appropriate review and approval performed. Additionally, supporting documentation was not maintained for all expenditures.
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.302-303 requires non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, all recipients and subrecipients of federal awards must maintain sufficient records to track expenditures to establish that funds have been used in accordance with Federal statutes,
regulations, and the terms and conditions of the Federal award. Sound internal control procedures should include a documented review and approval process for expenditures to ensure that funds are used appropriately and in accordance with program requirements.
Cause of condition: Procedures are in place which require all federal program expenditures to be reviewed and approved by appropriate personnel and supported by appropriate documentation. However, due to turnover of key personnel, these procedures were not appropriately followed.
Effect of condition: Without proper review and approval of expenditures and maintenance of supporting documentation, there is an increased risk of noncompliance with federal regulations.
Context: A total of 20 non-payroll expenditures were selected for testing of the Education Stabilization Fund. Of these, 16 expenditures lacked evidence of review or approval. These expenditures total $1,017,291. Additionally, management was unable to provide adequate supporting documentation for 1 of the 20 non-payroll expenditures selected for testing totaling $200.Recommendation: To ensure that non-payroll expenditures charged to federal award programs are accurate, all expenditures should be reviewed and approved by the appropriate School personnel. Documentation of this review and approval should be maintained. Furthermore, expenditures paid
with federal funds should be reviewed and approved by personnel with the appropriate training necessary to identify allowable expenditures. We also recommend that the Federal Program Director position is filled by an individual that has training and knowledge of the federal program they are administrating.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place for the review and approval of expenditures and maintenance of supporting documentation surrounding federal awards.
Statement of condition: Time certifications that support salaries and wages charged to the Education Stabilization program were not maintained.
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.430(g)(1)(i) requires that salaries and wages charged to federal awards must be supported by a system of internal controls that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Cause of condition: Policies and procedures are in place which require time certifications to be maintained for all employees paid from federal funds. However, due to turnover of key personnel, these policies and procedures were not followed in the current year.
Effect of condition: Without proper documentation, it cannot be verified that salaries and wages charged to the Education Stabilization program were based on actual time spent on allowable program-related activities. Context: Time certifications were not maintained for any employees paid from Education Stabilization Funds. This resulted in questioned costs of $2,548,644.
Recommendation: To ensure that salaries and wages charged to federal award programs are accurate, time certifications should be maintained for all employees paid from federal funds. All time certifications should be signed by the employee and reviewed and approved by the appropriate School personnel, as evidenced by the School personnel’s signature. We also recommend that the Federal Program Director position is filled by an individual that has training and knowledge of the federal program they are administering.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place for the review and approval of time certifications.
Statement of condition: Time certifications that support salaries and wages charged to Title I, Part A were not maintained for all employees. Of the time certifications that were maintained, not all showed evidence of review and approval performed.
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.430(g)(1)(i) requires that salaries and wages charged to federal awards must be supported by a system of internal controls that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Cause of condition: Policies and procedures are in place which require time certifications to be maintained for all employees paid from federal funds. However, due to turnover of key personnel, these policies and procedures were not followed in the current year.
Effect of condition: Without proper documentation, it cannot be verified that salaries and wages charged to Title I, Part A were based on actual time spent on allowable program-related activities.
Context: A sample of 40 employees paid with Title I, Part A funds were selected for testing. The audit testing found that time certifications were not maintained for 22 of the 40 employees. This resulted in questioned costs of $40,403. Additionally, the audit testing found that one employee’s time certification had no evidence of review and approval from appropriate School personnel.
Recommendation: To ensure that salaries and wages charged to federal award programs are accurate, time certifications should be maintained for all employees paid from federal funds. All time certifications should be signed by the employee and reviewed and approved by the appropriate School personnel, as evidenced by the School personnel’s signature. We also recommend that the Federal Program Director position is filled by an individual that has training and knowledge of the federal program they are administrating.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place for the maintenance, review, and approval of time certifications. See 2024-005 for management's detailed action plan surrounding the time certification findings.
Statement of condition: Property records for equipment acquired under the Education Stabilization Fund program were not maintained.
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.313(d)(1) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Per the School’s policies, property records should be maintained for all
equipment and theft-sensitive assets.
Cause of condition: Procedures are in place for property records to be maintained for all equipment acquired during the fiscal year. However, these procedures do not include maintaining all of the information required by 2 CFR 200.313(d)(1).
Effect of condition: During testing, it was noted that property records including all required information were not maintained for capital assets acquired under the Education Stabilization Fund program.
Context: Property including HVAC units and various other equipment and furniture and fixtures was acquired under the Education Stabilization Fund program. The audit testing found that for all property acquired during the fiscal year, records including a description of the property, the acquisition date, and the cost of the property are being maintained. However, the property records do not include various additional information as required by 2 CFR 200.313(d)(1).
Recommendation: Procedures should be put in place to ensure that property records including all required information are maintained for all capital assets purchased by the School in accordance with 2 CFR 200.313(d)(1). Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to maintain adequate property records.
Statement of condition: A physical inventory of property was not performed within the last two years. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.313(d)(2) requires that a physical inventory of property must be conducted, and the results must be reconciled with the property records at least once every two years.
Cause of condition: A physical inventory of property was planned for the current fiscal year, however, due to employee turnover, this inventory was never performed.
Effect of condition: The School was not in compliance with 2 CFR 200.313(d)(2) as a physical inventory of property had not been performed within the past two years.
Context: Property including HVAC units and various other equipment and furniture and fixtures was acquired under the Education Stabilization Fund program. A physical inventory of this property has not been performed with the past two years as required by 2 CFR 200.313(d)(2).
Recommendation: Procedures should be put in place to ensure that a physical inventory of property is being performed every two years in accordance with 2 CFR 200.313(d)(2). We also recommend that the Federal Program Director position is filled by an individual that has training and knowledge of the federal program they are administrating.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to perform a physical inventory of property at least once very two years. See 2024-007 for management's detailed action plan surrounding the property findings.
Statement of condition: The allocation of salaries and wages charged to the Title I, Part A program for employees tested was not accurate per supporting documentation of time certifications.
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.430(g)(1)(i) requires that salaries and wages charged to federal awards must be supported by a system of internal controls that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The School’s time certifications meet this regulation but these time certifications do not support the allocation of pay for these employees.
Cause of condition: Procedures are in place for personnel to review the accuracy of the time certification and to ensure accuracy in the recording of how salaries and wages are allocated in accordance with the time certifications. However, there was a breakdown in this control.
Effect of condition: During testing, it was noted that time certifications for employees who were paid with Title I, Part A funds were not supported by time certifications which state actual time worked by program for each employee.
Context: A sample of 40 employees paid with Title I, Part A funds were selected for testing. The audit testing found that 8 of the employees’ time certifications indicated that they worked less hours in the program than what was actually charged to the program. This resulted in questioned costs of $3,225. Recommendation: To ensure that salaries and wages charged to federal award programs are supported by time certifications, a review of completed time certifications should be compared to salaries and wages recorded to the program.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will review time certifications in comparison to salaries and wages recorded to federal programs. See 2024-005 for management's detailed action plan surrounding the time certification findings.
Statement of condition: Management was unable to provide evidence of formal policies or procedures governing test security or the administration of assessments.
Criteria: According to Title I, Section 1111(b)(2)(B)(iii) of the ESEA (Elementary and Secondary Education Act), federal grantees are required to establish and maintain an assessment system that is valid, reliable, and consistent with relevant professional and technical standards. Within their assessment system, they must have policies and procedures to maintain test security and ensure that those policies and procedures are implemented.
Cause of condition: Management was unable to provide evidence of whether policies and procedures were in place to ensure that test security measures were implemented.
Effect of condition: The School does not appear to be in compliance with federal regulations surrounding test security and assessment administration.
Context: Per discussion with management, there is no evidence of formal policies or procedures governing test security or assessment administration.
Recommendation: To ensure compliance with federal regulations, we recommend the School develop and implement formal policies and procedures for test security and assessment administration.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to implement and maintain evidence of formal policies or procedures governing test security or assessment administration.
Statement of condition: Management was unable to provide sufficient documentation evidencing the proper allocation of funds in accordance with federal ranking and allocation requirements. Criteria: Under Title I, Part A of the Elementary and Secondary Education Act (ESEA), funds must be allocated to eligible schools in rank order based on the percentage of students from low-income families. The allocation process must ensure that the highest-poverty schools, those above 75 percent poverty, are served before any schools with a poverty percentage at or below 75 percent. Sufficient documentation must be maintained to verify compliance with these requirements.
According to federal regulations, school districts must provide clear documentation and justification
for the allocation process.
Cause of condition: The School did not allocate funds to eligible schools in rank order. Schools with poverty levels below 75 percent were allocated more funds per pupil than schools with poverty levels above 75 percent, and management was unable to produce supporting documentation and justification regarding the allocation of funds.
Effect of condition: Without proper documentation of the allocation of Title I, Part A funds, it is difficult to determine whether the School is in compliance with federal requirements. It cannot be verified that funds were correctly allocated in accordance with the poverty ranking of eligible schools. Additionally, failure to allocate funds properly could lead to the under-serving of eligible students, impacting educational opportunities for students from low-income families.
Context: Management provided documentation of their 2023-2024 Title I, Part A budget that was entered into the Federal Grant Management System. According to the provided documentation, schools with poverty levels below 75 percent were allocated more funds per pupil than schools with poverty levels above 75 percent. Additionally, there was $751,709 of available funds that were not allocated to schools.
Recommendation: The School should implement a process to ensure all Title I, Part A funds are properly allocated to eligible schools in accordance with the federal ranking requirements. Furthermore, the School should maintain detailed documentation and justification for any unallocated funds to ensure transparency and accountability.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to ensure the proper allocation of funds and maintain sufficient documentation evidencing the proper allocation.
Statement of condition: Supporting documentation for expenditures paid from the Education Stabilization Fund did not contain evidence of appropriate review and approval performed. Additionally, supporting documentation was not maintained for all expenditures.
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.302-303 requires non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Additionally, all recipients and subrecipients of federal awards must maintain sufficient records to track expenditures to establish that funds have been used in accordance with Federal statutes,
regulations, and the terms and conditions of the Federal award. Sound internal control procedures should include a documented review and approval process for expenditures to ensure that funds are used appropriately and in accordance with program requirements.
Cause of condition: Procedures are in place which require all federal program expenditures to be reviewed and approved by appropriate personnel and supported by appropriate documentation. However, due to turnover of key personnel, these procedures were not appropriately followed.
Effect of condition: Without proper review and approval of expenditures and maintenance of supporting documentation, there is an increased risk of noncompliance with federal regulations.
Context: A total of 20 non-payroll expenditures were selected for testing of the Education Stabilization Fund. Of these, 16 expenditures lacked evidence of review or approval. These expenditures total $1,017,291. Additionally, management was unable to provide adequate supporting documentation for 1 of the 20 non-payroll expenditures selected for testing totaling $200.Recommendation: To ensure that non-payroll expenditures charged to federal award programs are accurate, all expenditures should be reviewed and approved by the appropriate School personnel. Documentation of this review and approval should be maintained. Furthermore, expenditures paid
with federal funds should be reviewed and approved by personnel with the appropriate training necessary to identify allowable expenditures. We also recommend that the Federal Program Director position is filled by an individual that has training and knowledge of the federal program they are administrating.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place for the review and approval of expenditures and maintenance of supporting documentation surrounding federal awards.
Statement of condition: Time certifications that support salaries and wages charged to the Education Stabilization program were not maintained.
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.430(g)(1)(i) requires that salaries and wages charged to federal awards must be supported by a system of internal controls that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Cause of condition: Policies and procedures are in place which require time certifications to be maintained for all employees paid from federal funds. However, due to turnover of key personnel, these policies and procedures were not followed in the current year.
Effect of condition: Without proper documentation, it cannot be verified that salaries and wages charged to the Education Stabilization program were based on actual time spent on allowable program-related activities. Context: Time certifications were not maintained for any employees paid from Education Stabilization Funds. This resulted in questioned costs of $2,548,644.
Recommendation: To ensure that salaries and wages charged to federal award programs are accurate, time certifications should be maintained for all employees paid from federal funds. All time certifications should be signed by the employee and reviewed and approved by the appropriate School personnel, as evidenced by the School personnel’s signature. We also recommend that the Federal Program Director position is filled by an individual that has training and knowledge of the federal program they are administering.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place for the review and approval of time certifications.
Statement of condition: Time certifications that support salaries and wages charged to Title I, Part A were not maintained for all employees. Of the time certifications that were maintained, not all showed evidence of review and approval performed.
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.430(g)(1)(i) requires that salaries and wages charged to federal awards must be supported by a system of internal controls that provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
Cause of condition: Policies and procedures are in place which require time certifications to be maintained for all employees paid from federal funds. However, due to turnover of key personnel, these policies and procedures were not followed in the current year.
Effect of condition: Without proper documentation, it cannot be verified that salaries and wages charged to Title I, Part A were based on actual time spent on allowable program-related activities.
Context: A sample of 40 employees paid with Title I, Part A funds were selected for testing. The audit testing found that time certifications were not maintained for 22 of the 40 employees. This resulted in questioned costs of $40,403. Additionally, the audit testing found that one employee’s time certification had no evidence of review and approval from appropriate School personnel.
Recommendation: To ensure that salaries and wages charged to federal award programs are accurate, time certifications should be maintained for all employees paid from federal funds. All time certifications should be signed by the employee and reviewed and approved by the appropriate School personnel, as evidenced by the School personnel’s signature. We also recommend that the Federal Program Director position is filled by an individual that has training and knowledge of the federal program they are administrating.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place for the maintenance, review, and approval of time certifications. See 2024-005 for management's detailed action plan surrounding the time certification findings.
Statement of condition: Property records for equipment acquired under the Education Stabilization Fund program were not maintained.
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.313(d)(1) requires that property records be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Per the School’s policies, property records should be maintained for all
equipment and theft-sensitive assets.
Cause of condition: Procedures are in place for property records to be maintained for all equipment acquired during the fiscal year. However, these procedures do not include maintaining all of the information required by 2 CFR 200.313(d)(1).
Effect of condition: During testing, it was noted that property records including all required information were not maintained for capital assets acquired under the Education Stabilization Fund program.
Context: Property including HVAC units and various other equipment and furniture and fixtures was acquired under the Education Stabilization Fund program. The audit testing found that for all property acquired during the fiscal year, records including a description of the property, the acquisition date, and the cost of the property are being maintained. However, the property records do not include various additional information as required by 2 CFR 200.313(d)(1).
Recommendation: Procedures should be put in place to ensure that property records including all required information are maintained for all capital assets purchased by the School in accordance with 2 CFR 200.313(d)(1). Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to maintain adequate property records.
Statement of condition: A physical inventory of property was not performed within the last two years. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.313(d)(2) requires that a physical inventory of property must be conducted, and the results must be reconciled with the property records at least once every two years.
Cause of condition: A physical inventory of property was planned for the current fiscal year, however, due to employee turnover, this inventory was never performed.
Effect of condition: The School was not in compliance with 2 CFR 200.313(d)(2) as a physical inventory of property had not been performed within the past two years.
Context: Property including HVAC units and various other equipment and furniture and fixtures was acquired under the Education Stabilization Fund program. A physical inventory of this property has not been performed with the past two years as required by 2 CFR 200.313(d)(2).
Recommendation: Procedures should be put in place to ensure that a physical inventory of property is being performed every two years in accordance with 2 CFR 200.313(d)(2). We also recommend that the Federal Program Director position is filled by an individual that has training and knowledge of the federal program they are administrating.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to perform a physical inventory of property at least once very two years. See 2024-007 for management's detailed action plan surrounding the property findings.
Statement of condition: The allocation of salaries and wages charged to the Title I, Part A program for employees tested was not accurate per supporting documentation of time certifications.
Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.430(g)(1)(i) requires that salaries and wages charged to federal awards must be supported by a system of internal controls that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The School’s time certifications meet this regulation but these time certifications do not support the allocation of pay for these employees.
Cause of condition: Procedures are in place for personnel to review the accuracy of the time certification and to ensure accuracy in the recording of how salaries and wages are allocated in accordance with the time certifications. However, there was a breakdown in this control.
Effect of condition: During testing, it was noted that time certifications for employees who were paid with Title I, Part A funds were not supported by time certifications which state actual time worked by program for each employee.
Context: A sample of 40 employees paid with Title I, Part A funds were selected for testing. The audit testing found that 8 of the employees’ time certifications indicated that they worked less hours in the program than what was actually charged to the program. This resulted in questioned costs of $3,225. Recommendation: To ensure that salaries and wages charged to federal award programs are supported by time certifications, a review of completed time certifications should be compared to salaries and wages recorded to the program.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will review time certifications in comparison to salaries and wages recorded to federal programs. See 2024-005 for management's detailed action plan surrounding the time certification findings.
Statement of condition: Management was unable to provide evidence of formal policies or procedures governing test security or the administration of assessments.
Criteria: According to Title I, Section 1111(b)(2)(B)(iii) of the ESEA (Elementary and Secondary Education Act), federal grantees are required to establish and maintain an assessment system that is valid, reliable, and consistent with relevant professional and technical standards. Within their assessment system, they must have policies and procedures to maintain test security and ensure that those policies and procedures are implemented.
Cause of condition: Management was unable to provide evidence of whether policies and procedures were in place to ensure that test security measures were implemented.
Effect of condition: The School does not appear to be in compliance with federal regulations surrounding test security and assessment administration.
Context: Per discussion with management, there is no evidence of formal policies or procedures governing test security or assessment administration.
Recommendation: To ensure compliance with federal regulations, we recommend the School develop and implement formal policies and procedures for test security and assessment administration.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to implement and maintain evidence of formal policies or procedures governing test security or assessment administration.
Statement of condition: Management was unable to provide sufficient documentation evidencing the proper allocation of funds in accordance with federal ranking and allocation requirements. Criteria: Under Title I, Part A of the Elementary and Secondary Education Act (ESEA), funds must be allocated to eligible schools in rank order based on the percentage of students from low-income families. The allocation process must ensure that the highest-poverty schools, those above 75 percent poverty, are served before any schools with a poverty percentage at or below 75 percent. Sufficient documentation must be maintained to verify compliance with these requirements.
According to federal regulations, school districts must provide clear documentation and justification
for the allocation process.
Cause of condition: The School did not allocate funds to eligible schools in rank order. Schools with poverty levels below 75 percent were allocated more funds per pupil than schools with poverty levels above 75 percent, and management was unable to produce supporting documentation and justification regarding the allocation of funds.
Effect of condition: Without proper documentation of the allocation of Title I, Part A funds, it is difficult to determine whether the School is in compliance with federal requirements. It cannot be verified that funds were correctly allocated in accordance with the poverty ranking of eligible schools. Additionally, failure to allocate funds properly could lead to the under-serving of eligible students, impacting educational opportunities for students from low-income families.
Context: Management provided documentation of their 2023-2024 Title I, Part A budget that was entered into the Federal Grant Management System. According to the provided documentation, schools with poverty levels below 75 percent were allocated more funds per pupil than schools with poverty levels above 75 percent. Additionally, there was $751,709 of available funds that were not allocated to schools.
Recommendation: The School should implement a process to ensure all Title I, Part A funds are properly allocated to eligible schools in accordance with the federal ranking requirements. Furthermore, the School should maintain detailed documentation and justification for any unallocated funds to ensure transparency and accountability.
Views of responsible officials and planned corrective actions: Management agrees with this finding and will put procedures in place to ensure the proper allocation of funds and maintain sufficient documentation evidencing the proper allocation.