2022-009 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Construction projects did not obtain certified payrolls documenting compliance with wage rate requirements. Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted construction requires that nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (Which still may be referenced as Davis-Bacon Act). Which includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each which in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Cause: The District had a letter from the contractor certifying compliance with Davis-Bacon Act but were unaware of need to obtain certified payrolls. Effect: The expenditures may be disallowed. Context: Unable to determine labor costs included in applications for payment from the contractor. Repeat Finding from Prior Year: No Recommendation Obtain certified payrolls for construction projects funded with federal awards. Determine that contracts for construction using federal funds include the appropriate clauses to be in compliance with federal procurement guidelines. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools obtained contractor certification of Davis-Bacon Act compliance, but did not obtain certified payrolls. The district identified this issue early in FY23 and immediately changed funding sources for the project. District construction bidding procedures for federally funded construction have been updated to include verbiage required by the Davis-Bacon Act.
2022-005 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Expenditures were paid without supporting invoices and proper District authority?s approval. Criteria: 2 CFR ?200.403 (g) Costs that meet general criteria in order to be allowable under federal awards must be adequately documented. Cause: Procedures in place for proper approval and documentation were not followed. Effect: The expenditures may be disallowed. Context: A sample of 32 expenditures totaling $3,037,928 was selected for audit from a population of $9,261,024. The test found 25 items that were not in compliance with questioned costs totaling $107,000. Questioned Costs: $107,000 Recommendation Expenditures should not be paid without the proper approval and supporting invoices. The District should follow procedures regarding requiring appropriate staff with authority to approve expenditures and requiring support for expenditures. Repeat Finding from Prior Year: No Views of Responsible Officials And Planned Corrective Action: Certain one-time COVID funds required several departments to make purchases. The lack of specific and clear guidance as to which department was directly responsible resulted in questioned expenditures. District Financial procurement procedures have been updated and implemented that require all federal expenditures to be approved through Lawton Public Schools? Federal Programs office. In addition, all supporting invoices for said expenditures must be provided to and approved by Lawton Public Schools? Federal Programs office. Lawton Public Schools will reimburse the State Department of Education for the total of these questioned costs.
2022-007 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Allowable costs/cost principles of indirect costs was overclaimed. Criteria: 34 CFR 76.569a Indirect costs= (restricted indirect cost rate) x (total direct costs of the grant minus capital outlays, subgrants, and other distorting or unallowable items as specified in the grantee?s indirect cost rate agreement). Cause: Failure to properly exclude construction activities from direct costs before the indirect costs were claimed. Effect: Indirect costs reimbursements were in excess of allowable amounts and may have to be returned. Context: Total expenditures, net of indirect cost and equipment capital expenditures, claimed were $23,578,870. Total construction capital expenditures claimed in this total were $2,341,866. The approved indirect cost rate was 2.74%. Total claimed indirect costs were $630,897. After excluding construction capital expenditures, overclaimed indirect cost found not to be in compliance was $49,003. Questioned Costs: $49,003 Repeat Finding from Prior Year: Yes; 2021-005 Recommendation Indirect costs should be claimed in accordance with allowable cost principles. Construction capital expenditures should be excluded from costs included in indirect cost claims. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools utilized the Oklahoma State Department of Education?s guidance and charged indirect costs for ?capital expenditures? and received reimbursement for those direct costs. The auditor has identified $49,003 as unallowable. Lawton Public Schools will reimburse the State Department of Education for the total of these unallowable costs regardless of SDE?s guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. Criteria: 2 CFR ?200.430(i)(1)(vii) Standards for Documentation of Personnel Expenses (1) Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-008 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Property acquired with federal funds were not tracked in property records. Criteria: 2 CFR 200.313(d)(1) requires property records must be maintained that include a description of the property, serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, the cost of the property, percentage of the federal project costs under which property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Cause: Failure to identify construction in progress as capital outlay for property. Effect: The expenditures may be disallowed. Context: A sample of $2,908,079 was selected for audit from a population of $3,035,125. The test found $2,341,866 was not in compliance. Questioned Costs: $2,341,866 Repeat Finding from Prior Year: Yes; 2021-006 Recommendation We recommend that property be properly tracked. We also recommend reconciliations procedures be implemented of property paid with federal funds and federal property listing. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools failed to identify ?Construction in Progress? paid for with federal funds as federal. Procedures will be updated to ensure ?Construction in Progress? paid with federal funds is identified and recorded as federal immediately rather than at the completion of the construction. While this finding is identified as a repeat finding from FY2021 (2021-006), the prior year was in reference to fixed assets while this year?s finding is in reference to ?Construction in Progress?.
2022-009 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Construction projects did not obtain certified payrolls documenting compliance with wage rate requirements. Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted construction requires that nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (Which still may be referenced as Davis-Bacon Act). Which includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each which in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Cause: The District had a letter from the contractor certifying compliance with Davis-Bacon Act but were unaware of need to obtain certified payrolls. Effect: The expenditures may be disallowed. Context: Unable to determine labor costs included in applications for payment from the contractor. Repeat Finding from Prior Year: No Recommendation Obtain certified payrolls for construction projects funded with federal awards. Determine that contracts for construction using federal funds include the appropriate clauses to be in compliance with federal procurement guidelines. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools obtained contractor certification of Davis-Bacon Act compliance, but did not obtain certified payrolls. The district identified this issue early in FY23 and immediately changed funding sources for the project. District construction bidding procedures for federally funded construction have been updated to include verbiage required by the Davis-Bacon Act.
2022-005 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Expenditures were paid without supporting invoices and proper District authority?s approval. Criteria: 2 CFR ?200.403 (g) Costs that meet general criteria in order to be allowable under federal awards must be adequately documented. Cause: Procedures in place for proper approval and documentation were not followed. Effect: The expenditures may be disallowed. Context: A sample of 32 expenditures totaling $3,037,928 was selected for audit from a population of $9,261,024. The test found 25 items that were not in compliance with questioned costs totaling $107,000. Questioned Costs: $107,000 Recommendation Expenditures should not be paid without the proper approval and supporting invoices. The District should follow procedures regarding requiring appropriate staff with authority to approve expenditures and requiring support for expenditures. Repeat Finding from Prior Year: No Views of Responsible Officials And Planned Corrective Action: Certain one-time COVID funds required several departments to make purchases. The lack of specific and clear guidance as to which department was directly responsible resulted in questioned expenditures. District Financial procurement procedures have been updated and implemented that require all federal expenditures to be approved through Lawton Public Schools? Federal Programs office. In addition, all supporting invoices for said expenditures must be provided to and approved by Lawton Public Schools? Federal Programs office. Lawton Public Schools will reimburse the State Department of Education for the total of these questioned costs.
2022-007 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Allowable costs/cost principles of indirect costs was overclaimed. Criteria: 34 CFR 76.569a Indirect costs= (restricted indirect cost rate) x (total direct costs of the grant minus capital outlays, subgrants, and other distorting or unallowable items as specified in the grantee?s indirect cost rate agreement). Cause: Failure to properly exclude construction activities from direct costs before the indirect costs were claimed. Effect: Indirect costs reimbursements were in excess of allowable amounts and may have to be returned. Context: Total expenditures, net of indirect cost and equipment capital expenditures, claimed were $23,578,870. Total construction capital expenditures claimed in this total were $2,341,866. The approved indirect cost rate was 2.74%. Total claimed indirect costs were $630,897. After excluding construction capital expenditures, overclaimed indirect cost found not to be in compliance was $49,003. Questioned Costs: $49,003 Repeat Finding from Prior Year: Yes; 2021-005 Recommendation Indirect costs should be claimed in accordance with allowable cost principles. Construction capital expenditures should be excluded from costs included in indirect cost claims. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools utilized the Oklahoma State Department of Education?s guidance and charged indirect costs for ?capital expenditures? and received reimbursement for those direct costs. The auditor has identified $49,003 as unallowable. Lawton Public Schools will reimburse the State Department of Education for the total of these unallowable costs regardless of SDE?s guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. Criteria: 2 CFR ?200.430(i)(1)(vii) Standards for Documentation of Personnel Expenses (1) Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-008 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Property acquired with federal funds were not tracked in property records. Criteria: 2 CFR 200.313(d)(1) requires property records must be maintained that include a description of the property, serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, the cost of the property, percentage of the federal project costs under which property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Cause: Failure to identify construction in progress as capital outlay for property. Effect: The expenditures may be disallowed. Context: A sample of $2,908,079 was selected for audit from a population of $3,035,125. The test found $2,341,866 was not in compliance. Questioned Costs: $2,341,866 Repeat Finding from Prior Year: Yes; 2021-006 Recommendation We recommend that property be properly tracked. We also recommend reconciliations procedures be implemented of property paid with federal funds and federal property listing. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools failed to identify ?Construction in Progress? paid for with federal funds as federal. Procedures will be updated to ensure ?Construction in Progress? paid with federal funds is identified and recorded as federal immediately rather than at the completion of the construction. While this finding is identified as a repeat finding from FY2021 (2021-006), the prior year was in reference to fixed assets while this year?s finding is in reference to ?Construction in Progress?.
2022-009 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Construction projects did not obtain certified payrolls documenting compliance with wage rate requirements. Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted construction requires that nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (Which still may be referenced as Davis-Bacon Act). Which includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each which in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Cause: The District had a letter from the contractor certifying compliance with Davis-Bacon Act but were unaware of need to obtain certified payrolls. Effect: The expenditures may be disallowed. Context: Unable to determine labor costs included in applications for payment from the contractor. Repeat Finding from Prior Year: No Recommendation Obtain certified payrolls for construction projects funded with federal awards. Determine that contracts for construction using federal funds include the appropriate clauses to be in compliance with federal procurement guidelines. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools obtained contractor certification of Davis-Bacon Act compliance, but did not obtain certified payrolls. The district identified this issue early in FY23 and immediately changed funding sources for the project. District construction bidding procedures for federally funded construction have been updated to include verbiage required by the Davis-Bacon Act.
2022-005 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Expenditures were paid without supporting invoices and proper District authority?s approval. Criteria: 2 CFR ?200.403 (g) Costs that meet general criteria in order to be allowable under federal awards must be adequately documented. Cause: Procedures in place for proper approval and documentation were not followed. Effect: The expenditures may be disallowed. Context: A sample of 32 expenditures totaling $3,037,928 was selected for audit from a population of $9,261,024. The test found 25 items that were not in compliance with questioned costs totaling $107,000. Questioned Costs: $107,000 Recommendation Expenditures should not be paid without the proper approval and supporting invoices. The District should follow procedures regarding requiring appropriate staff with authority to approve expenditures and requiring support for expenditures. Repeat Finding from Prior Year: No Views of Responsible Officials And Planned Corrective Action: Certain one-time COVID funds required several departments to make purchases. The lack of specific and clear guidance as to which department was directly responsible resulted in questioned expenditures. District Financial procurement procedures have been updated and implemented that require all federal expenditures to be approved through Lawton Public Schools? Federal Programs office. In addition, all supporting invoices for said expenditures must be provided to and approved by Lawton Public Schools? Federal Programs office. Lawton Public Schools will reimburse the State Department of Education for the total of these questioned costs.
2022-007 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Allowable costs/cost principles of indirect costs was overclaimed. Criteria: 34 CFR 76.569a Indirect costs= (restricted indirect cost rate) x (total direct costs of the grant minus capital outlays, subgrants, and other distorting or unallowable items as specified in the grantee?s indirect cost rate agreement). Cause: Failure to properly exclude construction activities from direct costs before the indirect costs were claimed. Effect: Indirect costs reimbursements were in excess of allowable amounts and may have to be returned. Context: Total expenditures, net of indirect cost and equipment capital expenditures, claimed were $23,578,870. Total construction capital expenditures claimed in this total were $2,341,866. The approved indirect cost rate was 2.74%. Total claimed indirect costs were $630,897. After excluding construction capital expenditures, overclaimed indirect cost found not to be in compliance was $49,003. Questioned Costs: $49,003 Repeat Finding from Prior Year: Yes; 2021-005 Recommendation Indirect costs should be claimed in accordance with allowable cost principles. Construction capital expenditures should be excluded from costs included in indirect cost claims. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools utilized the Oklahoma State Department of Education?s guidance and charged indirect costs for ?capital expenditures? and received reimbursement for those direct costs. The auditor has identified $49,003 as unallowable. Lawton Public Schools will reimburse the State Department of Education for the total of these unallowable costs regardless of SDE?s guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. Criteria: 2 CFR ?200.430(i)(1)(vii) Standards for Documentation of Personnel Expenses (1) Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-008 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Property acquired with federal funds were not tracked in property records. Criteria: 2 CFR 200.313(d)(1) requires property records must be maintained that include a description of the property, serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, the cost of the property, percentage of the federal project costs under which property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Cause: Failure to identify construction in progress as capital outlay for property. Effect: The expenditures may be disallowed. Context: A sample of $2,908,079 was selected for audit from a population of $3,035,125. The test found $2,341,866 was not in compliance. Questioned Costs: $2,341,866 Repeat Finding from Prior Year: Yes; 2021-006 Recommendation We recommend that property be properly tracked. We also recommend reconciliations procedures be implemented of property paid with federal funds and federal property listing. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools failed to identify ?Construction in Progress? paid for with federal funds as federal. Procedures will be updated to ensure ?Construction in Progress? paid with federal funds is identified and recorded as federal immediately rather than at the completion of the construction. While this finding is identified as a repeat finding from FY2021 (2021-006), the prior year was in reference to fixed assets while this year?s finding is in reference to ?Construction in Progress?.
2022-009 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Construction projects did not obtain certified payrolls documenting compliance with wage rate requirements. Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted construction requires that nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (Which still may be referenced as Davis-Bacon Act). Which includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each which in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Cause: The District had a letter from the contractor certifying compliance with Davis-Bacon Act but were unaware of need to obtain certified payrolls. Effect: The expenditures may be disallowed. Context: Unable to determine labor costs included in applications for payment from the contractor. Repeat Finding from Prior Year: No Recommendation Obtain certified payrolls for construction projects funded with federal awards. Determine that contracts for construction using federal funds include the appropriate clauses to be in compliance with federal procurement guidelines. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools obtained contractor certification of Davis-Bacon Act compliance, but did not obtain certified payrolls. The district identified this issue early in FY23 and immediately changed funding sources for the project. District construction bidding procedures for federally funded construction have been updated to include verbiage required by the Davis-Bacon Act.
2022-005 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Expenditures were paid without supporting invoices and proper District authority?s approval. Criteria: 2 CFR ?200.403 (g) Costs that meet general criteria in order to be allowable under federal awards must be adequately documented. Cause: Procedures in place for proper approval and documentation were not followed. Effect: The expenditures may be disallowed. Context: A sample of 32 expenditures totaling $3,037,928 was selected for audit from a population of $9,261,024. The test found 25 items that were not in compliance with questioned costs totaling $107,000. Questioned Costs: $107,000 Recommendation Expenditures should not be paid without the proper approval and supporting invoices. The District should follow procedures regarding requiring appropriate staff with authority to approve expenditures and requiring support for expenditures. Repeat Finding from Prior Year: No Views of Responsible Officials And Planned Corrective Action: Certain one-time COVID funds required several departments to make purchases. The lack of specific and clear guidance as to which department was directly responsible resulted in questioned expenditures. District Financial procurement procedures have been updated and implemented that require all federal expenditures to be approved through Lawton Public Schools? Federal Programs office. In addition, all supporting invoices for said expenditures must be provided to and approved by Lawton Public Schools? Federal Programs office. Lawton Public Schools will reimburse the State Department of Education for the total of these questioned costs.
2022-007 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Allowable costs/cost principles of indirect costs was overclaimed. Criteria: 34 CFR 76.569a Indirect costs= (restricted indirect cost rate) x (total direct costs of the grant minus capital outlays, subgrants, and other distorting or unallowable items as specified in the grantee?s indirect cost rate agreement). Cause: Failure to properly exclude construction activities from direct costs before the indirect costs were claimed. Effect: Indirect costs reimbursements were in excess of allowable amounts and may have to be returned. Context: Total expenditures, net of indirect cost and equipment capital expenditures, claimed were $23,578,870. Total construction capital expenditures claimed in this total were $2,341,866. The approved indirect cost rate was 2.74%. Total claimed indirect costs were $630,897. After excluding construction capital expenditures, overclaimed indirect cost found not to be in compliance was $49,003. Questioned Costs: $49,003 Repeat Finding from Prior Year: Yes; 2021-005 Recommendation Indirect costs should be claimed in accordance with allowable cost principles. Construction capital expenditures should be excluded from costs included in indirect cost claims. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools utilized the Oklahoma State Department of Education?s guidance and charged indirect costs for ?capital expenditures? and received reimbursement for those direct costs. The auditor has identified $49,003 as unallowable. Lawton Public Schools will reimburse the State Department of Education for the total of these unallowable costs regardless of SDE?s guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. Criteria: 2 CFR ?200.430(i)(1)(vii) Standards for Documentation of Personnel Expenses (1) Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-008 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Property acquired with federal funds were not tracked in property records. Criteria: 2 CFR 200.313(d)(1) requires property records must be maintained that include a description of the property, serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, the cost of the property, percentage of the federal project costs under which property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Cause: Failure to identify construction in progress as capital outlay for property. Effect: The expenditures may be disallowed. Context: A sample of $2,908,079 was selected for audit from a population of $3,035,125. The test found $2,341,866 was not in compliance. Questioned Costs: $2,341,866 Repeat Finding from Prior Year: Yes; 2021-006 Recommendation We recommend that property be properly tracked. We also recommend reconciliations procedures be implemented of property paid with federal funds and federal property listing. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools failed to identify ?Construction in Progress? paid for with federal funds as federal. Procedures will be updated to ensure ?Construction in Progress? paid with federal funds is identified and recorded as federal immediately rather than at the completion of the construction. While this finding is identified as a repeat finding from FY2021 (2021-006), the prior year was in reference to fixed assets while this year?s finding is in reference to ?Construction in Progress?.
2022-009 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Construction projects did not obtain certified payrolls documenting compliance with wage rate requirements. Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted construction requires that nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (Which still may be referenced as Davis-Bacon Act). Which includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each which in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Cause: The District had a letter from the contractor certifying compliance with Davis-Bacon Act but were unaware of need to obtain certified payrolls. Effect: The expenditures may be disallowed. Context: Unable to determine labor costs included in applications for payment from the contractor. Repeat Finding from Prior Year: No Recommendation Obtain certified payrolls for construction projects funded with federal awards. Determine that contracts for construction using federal funds include the appropriate clauses to be in compliance with federal procurement guidelines. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools obtained contractor certification of Davis-Bacon Act compliance, but did not obtain certified payrolls. The district identified this issue early in FY23 and immediately changed funding sources for the project. District construction bidding procedures for federally funded construction have been updated to include verbiage required by the Davis-Bacon Act.
2022-005 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Expenditures were paid without supporting invoices and proper District authority?s approval. Criteria: 2 CFR ?200.403 (g) Costs that meet general criteria in order to be allowable under federal awards must be adequately documented. Cause: Procedures in place for proper approval and documentation were not followed. Effect: The expenditures may be disallowed. Context: A sample of 32 expenditures totaling $3,037,928 was selected for audit from a population of $9,261,024. The test found 25 items that were not in compliance with questioned costs totaling $107,000. Questioned Costs: $107,000 Recommendation Expenditures should not be paid without the proper approval and supporting invoices. The District should follow procedures regarding requiring appropriate staff with authority to approve expenditures and requiring support for expenditures. Repeat Finding from Prior Year: No Views of Responsible Officials And Planned Corrective Action: Certain one-time COVID funds required several departments to make purchases. The lack of specific and clear guidance as to which department was directly responsible resulted in questioned expenditures. District Financial procurement procedures have been updated and implemented that require all federal expenditures to be approved through Lawton Public Schools? Federal Programs office. In addition, all supporting invoices for said expenditures must be provided to and approved by Lawton Public Schools? Federal Programs office. Lawton Public Schools will reimburse the State Department of Education for the total of these questioned costs.
2022-007 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Allowable costs/cost principles of indirect costs was overclaimed. Criteria: 34 CFR 76.569a Indirect costs= (restricted indirect cost rate) x (total direct costs of the grant minus capital outlays, subgrants, and other distorting or unallowable items as specified in the grantee?s indirect cost rate agreement). Cause: Failure to properly exclude construction activities from direct costs before the indirect costs were claimed. Effect: Indirect costs reimbursements were in excess of allowable amounts and may have to be returned. Context: Total expenditures, net of indirect cost and equipment capital expenditures, claimed were $23,578,870. Total construction capital expenditures claimed in this total were $2,341,866. The approved indirect cost rate was 2.74%. Total claimed indirect costs were $630,897. After excluding construction capital expenditures, overclaimed indirect cost found not to be in compliance was $49,003. Questioned Costs: $49,003 Repeat Finding from Prior Year: Yes; 2021-005 Recommendation Indirect costs should be claimed in accordance with allowable cost principles. Construction capital expenditures should be excluded from costs included in indirect cost claims. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools utilized the Oklahoma State Department of Education?s guidance and charged indirect costs for ?capital expenditures? and received reimbursement for those direct costs. The auditor has identified $49,003 as unallowable. Lawton Public Schools will reimburse the State Department of Education for the total of these unallowable costs regardless of SDE?s guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. Criteria: 2 CFR ?200.430(i)(1)(vii) Standards for Documentation of Personnel Expenses (1) Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-008 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Property acquired with federal funds were not tracked in property records. Criteria: 2 CFR 200.313(d)(1) requires property records must be maintained that include a description of the property, serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, the cost of the property, percentage of the federal project costs under which property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Cause: Failure to identify construction in progress as capital outlay for property. Effect: The expenditures may be disallowed. Context: A sample of $2,908,079 was selected for audit from a population of $3,035,125. The test found $2,341,866 was not in compliance. Questioned Costs: $2,341,866 Repeat Finding from Prior Year: Yes; 2021-006 Recommendation We recommend that property be properly tracked. We also recommend reconciliations procedures be implemented of property paid with federal funds and federal property listing. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools failed to identify ?Construction in Progress? paid for with federal funds as federal. Procedures will be updated to ensure ?Construction in Progress? paid with federal funds is identified and recorded as federal immediately rather than at the completion of the construction. While this finding is identified as a repeat finding from FY2021 (2021-006), the prior year was in reference to fixed assets while this year?s finding is in reference to ?Construction in Progress?.
2022-010 Federal Agency: Federal Communication Commission Pass Thru Entity: Universal Service Administrative Company Program: COVID-19 Emergency Connectivity Fund Program Assistance Listing: 32.009 Grant Period: Year ending June 30, 2022 Condition: Devices/Services acquired with federal funds were not tracked to appropriate population of unmet needs. Criteria: FCC-ECF Program is to fund devices and services must be used primarily for off-campus educational purposes and by students, school staff with otherwise unmet needs; Who would otherwise lack access to connected device and/or broadband connectivity sufficient to engage in remote learning. Also requires that on device and service per user. 47 CFR 54.1715 Records retention?a) equipment and service inventory requirements. Schools, libraries and consortia shall keep asset and service inventories identified with the eligible student or staff member. Cause: The District failed to properly track the devices/services to the eligible population. Effect: The expenditures may be disallowed. Context: All expenditures related to the purchasing of devices or services were tested. 3900 Devices were purchased, and 1,877 devices were found not to be in compliance resulting in questioned costs of $557,333. Services provided of 5 months were not tracked and resulted in $90,531 of questioned costs. Questioned Costs: $647,864 Repeat Finding from Prior Year: No Recommendation Assets acquired with federal funds need to be tracked following the guidelines of the award. The District needs to develop procedures to identify devices/services are distributed to eligible students/staff as required by program. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools procedures require tracking of items with an acquisition cost of $5,000 or higher. These one-time FCC-ECF funds included specific criteria requiring specific tracking of all purchases including hotspots. These criteria were not identified immediately by the district. The district has updated procedures to include the tracking of all of these items even though they do not have an acquisition cost of $5,000 or higher.
2022-009 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Construction projects did not obtain certified payrolls documenting compliance with wage rate requirements. Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted construction requires that nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (Which still may be referenced as Davis-Bacon Act). Which includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each which in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Cause: The District had a letter from the contractor certifying compliance with Davis-Bacon Act but were unaware of need to obtain certified payrolls. Effect: The expenditures may be disallowed. Context: Unable to determine labor costs included in applications for payment from the contractor. Repeat Finding from Prior Year: No Recommendation Obtain certified payrolls for construction projects funded with federal awards. Determine that contracts for construction using federal funds include the appropriate clauses to be in compliance with federal procurement guidelines. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools obtained contractor certification of Davis-Bacon Act compliance, but did not obtain certified payrolls. The district identified this issue early in FY23 and immediately changed funding sources for the project. District construction bidding procedures for federally funded construction have been updated to include verbiage required by the Davis-Bacon Act.
2022-005 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Expenditures were paid without supporting invoices and proper District authority?s approval. Criteria: 2 CFR ?200.403 (g) Costs that meet general criteria in order to be allowable under federal awards must be adequately documented. Cause: Procedures in place for proper approval and documentation were not followed. Effect: The expenditures may be disallowed. Context: A sample of 32 expenditures totaling $3,037,928 was selected for audit from a population of $9,261,024. The test found 25 items that were not in compliance with questioned costs totaling $107,000. Questioned Costs: $107,000 Recommendation Expenditures should not be paid without the proper approval and supporting invoices. The District should follow procedures regarding requiring appropriate staff with authority to approve expenditures and requiring support for expenditures. Repeat Finding from Prior Year: No Views of Responsible Officials And Planned Corrective Action: Certain one-time COVID funds required several departments to make purchases. The lack of specific and clear guidance as to which department was directly responsible resulted in questioned expenditures. District Financial procurement procedures have been updated and implemented that require all federal expenditures to be approved through Lawton Public Schools? Federal Programs office. In addition, all supporting invoices for said expenditures must be provided to and approved by Lawton Public Schools? Federal Programs office. Lawton Public Schools will reimburse the State Department of Education for the total of these questioned costs.
2022-007 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Allowable costs/cost principles of indirect costs was overclaimed. Criteria: 34 CFR 76.569a Indirect costs= (restricted indirect cost rate) x (total direct costs of the grant minus capital outlays, subgrants, and other distorting or unallowable items as specified in the grantee?s indirect cost rate agreement). Cause: Failure to properly exclude construction activities from direct costs before the indirect costs were claimed. Effect: Indirect costs reimbursements were in excess of allowable amounts and may have to be returned. Context: Total expenditures, net of indirect cost and equipment capital expenditures, claimed were $23,578,870. Total construction capital expenditures claimed in this total were $2,341,866. The approved indirect cost rate was 2.74%. Total claimed indirect costs were $630,897. After excluding construction capital expenditures, overclaimed indirect cost found not to be in compliance was $49,003. Questioned Costs: $49,003 Repeat Finding from Prior Year: Yes; 2021-005 Recommendation Indirect costs should be claimed in accordance with allowable cost principles. Construction capital expenditures should be excluded from costs included in indirect cost claims. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools utilized the Oklahoma State Department of Education?s guidance and charged indirect costs for ?capital expenditures? and received reimbursement for those direct costs. The auditor has identified $49,003 as unallowable. Lawton Public Schools will reimburse the State Department of Education for the total of these unallowable costs regardless of SDE?s guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. Criteria: 2 CFR ?200.430(i)(1)(vii) Standards for Documentation of Personnel Expenses (1) Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-008 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Property acquired with federal funds were not tracked in property records. Criteria: 2 CFR 200.313(d)(1) requires property records must be maintained that include a description of the property, serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, the cost of the property, percentage of the federal project costs under which property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Cause: Failure to identify construction in progress as capital outlay for property. Effect: The expenditures may be disallowed. Context: A sample of $2,908,079 was selected for audit from a population of $3,035,125. The test found $2,341,866 was not in compliance. Questioned Costs: $2,341,866 Repeat Finding from Prior Year: Yes; 2021-006 Recommendation We recommend that property be properly tracked. We also recommend reconciliations procedures be implemented of property paid with federal funds and federal property listing. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools failed to identify ?Construction in Progress? paid for with federal funds as federal. Procedures will be updated to ensure ?Construction in Progress? paid with federal funds is identified and recorded as federal immediately rather than at the completion of the construction. While this finding is identified as a repeat finding from FY2021 (2021-006), the prior year was in reference to fixed assets while this year?s finding is in reference to ?Construction in Progress?.
2022-009 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Construction projects did not obtain certified payrolls documenting compliance with wage rate requirements. Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted construction requires that nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (Which still may be referenced as Davis-Bacon Act). Which includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each which in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Cause: The District had a letter from the contractor certifying compliance with Davis-Bacon Act but were unaware of need to obtain certified payrolls. Effect: The expenditures may be disallowed. Context: Unable to determine labor costs included in applications for payment from the contractor. Repeat Finding from Prior Year: No Recommendation Obtain certified payrolls for construction projects funded with federal awards. Determine that contracts for construction using federal funds include the appropriate clauses to be in compliance with federal procurement guidelines. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools obtained contractor certification of Davis-Bacon Act compliance, but did not obtain certified payrolls. The district identified this issue early in FY23 and immediately changed funding sources for the project. District construction bidding procedures for federally funded construction have been updated to include verbiage required by the Davis-Bacon Act.
2022-005 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Expenditures were paid without supporting invoices and proper District authority?s approval. Criteria: 2 CFR ?200.403 (g) Costs that meet general criteria in order to be allowable under federal awards must be adequately documented. Cause: Procedures in place for proper approval and documentation were not followed. Effect: The expenditures may be disallowed. Context: A sample of 32 expenditures totaling $3,037,928 was selected for audit from a population of $9,261,024. The test found 25 items that were not in compliance with questioned costs totaling $107,000. Questioned Costs: $107,000 Recommendation Expenditures should not be paid without the proper approval and supporting invoices. The District should follow procedures regarding requiring appropriate staff with authority to approve expenditures and requiring support for expenditures. Repeat Finding from Prior Year: No Views of Responsible Officials And Planned Corrective Action: Certain one-time COVID funds required several departments to make purchases. The lack of specific and clear guidance as to which department was directly responsible resulted in questioned expenditures. District Financial procurement procedures have been updated and implemented that require all federal expenditures to be approved through Lawton Public Schools? Federal Programs office. In addition, all supporting invoices for said expenditures must be provided to and approved by Lawton Public Schools? Federal Programs office. Lawton Public Schools will reimburse the State Department of Education for the total of these questioned costs.
2022-007 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Allowable costs/cost principles of indirect costs was overclaimed. Criteria: 34 CFR 76.569a Indirect costs= (restricted indirect cost rate) x (total direct costs of the grant minus capital outlays, subgrants, and other distorting or unallowable items as specified in the grantee?s indirect cost rate agreement). Cause: Failure to properly exclude construction activities from direct costs before the indirect costs were claimed. Effect: Indirect costs reimbursements were in excess of allowable amounts and may have to be returned. Context: Total expenditures, net of indirect cost and equipment capital expenditures, claimed were $23,578,870. Total construction capital expenditures claimed in this total were $2,341,866. The approved indirect cost rate was 2.74%. Total claimed indirect costs were $630,897. After excluding construction capital expenditures, overclaimed indirect cost found not to be in compliance was $49,003. Questioned Costs: $49,003 Repeat Finding from Prior Year: Yes; 2021-005 Recommendation Indirect costs should be claimed in accordance with allowable cost principles. Construction capital expenditures should be excluded from costs included in indirect cost claims. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools utilized the Oklahoma State Department of Education?s guidance and charged indirect costs for ?capital expenditures? and received reimbursement for those direct costs. The auditor has identified $49,003 as unallowable. Lawton Public Schools will reimburse the State Department of Education for the total of these unallowable costs regardless of SDE?s guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. Criteria: 2 CFR ?200.430(i)(1)(vii) Standards for Documentation of Personnel Expenses (1) Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-008 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Property acquired with federal funds were not tracked in property records. Criteria: 2 CFR 200.313(d)(1) requires property records must be maintained that include a description of the property, serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, the cost of the property, percentage of the federal project costs under which property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Cause: Failure to identify construction in progress as capital outlay for property. Effect: The expenditures may be disallowed. Context: A sample of $2,908,079 was selected for audit from a population of $3,035,125. The test found $2,341,866 was not in compliance. Questioned Costs: $2,341,866 Repeat Finding from Prior Year: Yes; 2021-006 Recommendation We recommend that property be properly tracked. We also recommend reconciliations procedures be implemented of property paid with federal funds and federal property listing. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools failed to identify ?Construction in Progress? paid for with federal funds as federal. Procedures will be updated to ensure ?Construction in Progress? paid with federal funds is identified and recorded as federal immediately rather than at the completion of the construction. While this finding is identified as a repeat finding from FY2021 (2021-006), the prior year was in reference to fixed assets while this year?s finding is in reference to ?Construction in Progress?.
2022-009 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Construction projects did not obtain certified payrolls documenting compliance with wage rate requirements. Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted construction requires that nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (Which still may be referenced as Davis-Bacon Act). Which includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each which in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Cause: The District had a letter from the contractor certifying compliance with Davis-Bacon Act but were unaware of need to obtain certified payrolls. Effect: The expenditures may be disallowed. Context: Unable to determine labor costs included in applications for payment from the contractor. Repeat Finding from Prior Year: No Recommendation Obtain certified payrolls for construction projects funded with federal awards. Determine that contracts for construction using federal funds include the appropriate clauses to be in compliance with federal procurement guidelines. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools obtained contractor certification of Davis-Bacon Act compliance, but did not obtain certified payrolls. The district identified this issue early in FY23 and immediately changed funding sources for the project. District construction bidding procedures for federally funded construction have been updated to include verbiage required by the Davis-Bacon Act.
2022-005 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Expenditures were paid without supporting invoices and proper District authority?s approval. Criteria: 2 CFR ?200.403 (g) Costs that meet general criteria in order to be allowable under federal awards must be adequately documented. Cause: Procedures in place for proper approval and documentation were not followed. Effect: The expenditures may be disallowed. Context: A sample of 32 expenditures totaling $3,037,928 was selected for audit from a population of $9,261,024. The test found 25 items that were not in compliance with questioned costs totaling $107,000. Questioned Costs: $107,000 Recommendation Expenditures should not be paid without the proper approval and supporting invoices. The District should follow procedures regarding requiring appropriate staff with authority to approve expenditures and requiring support for expenditures. Repeat Finding from Prior Year: No Views of Responsible Officials And Planned Corrective Action: Certain one-time COVID funds required several departments to make purchases. The lack of specific and clear guidance as to which department was directly responsible resulted in questioned expenditures. District Financial procurement procedures have been updated and implemented that require all federal expenditures to be approved through Lawton Public Schools? Federal Programs office. In addition, all supporting invoices for said expenditures must be provided to and approved by Lawton Public Schools? Federal Programs office. Lawton Public Schools will reimburse the State Department of Education for the total of these questioned costs.
2022-007 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Allowable costs/cost principles of indirect costs was overclaimed. Criteria: 34 CFR 76.569a Indirect costs= (restricted indirect cost rate) x (total direct costs of the grant minus capital outlays, subgrants, and other distorting or unallowable items as specified in the grantee?s indirect cost rate agreement). Cause: Failure to properly exclude construction activities from direct costs before the indirect costs were claimed. Effect: Indirect costs reimbursements were in excess of allowable amounts and may have to be returned. Context: Total expenditures, net of indirect cost and equipment capital expenditures, claimed were $23,578,870. Total construction capital expenditures claimed in this total were $2,341,866. The approved indirect cost rate was 2.74%. Total claimed indirect costs were $630,897. After excluding construction capital expenditures, overclaimed indirect cost found not to be in compliance was $49,003. Questioned Costs: $49,003 Repeat Finding from Prior Year: Yes; 2021-005 Recommendation Indirect costs should be claimed in accordance with allowable cost principles. Construction capital expenditures should be excluded from costs included in indirect cost claims. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools utilized the Oklahoma State Department of Education?s guidance and charged indirect costs for ?capital expenditures? and received reimbursement for those direct costs. The auditor has identified $49,003 as unallowable. Lawton Public Schools will reimburse the State Department of Education for the total of these unallowable costs regardless of SDE?s guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. Criteria: 2 CFR ?200.430(i)(1)(vii) Standards for Documentation of Personnel Expenses (1) Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-008 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Property acquired with federal funds were not tracked in property records. Criteria: 2 CFR 200.313(d)(1) requires property records must be maintained that include a description of the property, serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, the cost of the property, percentage of the federal project costs under which property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Cause: Failure to identify construction in progress as capital outlay for property. Effect: The expenditures may be disallowed. Context: A sample of $2,908,079 was selected for audit from a population of $3,035,125. The test found $2,341,866 was not in compliance. Questioned Costs: $2,341,866 Repeat Finding from Prior Year: Yes; 2021-006 Recommendation We recommend that property be properly tracked. We also recommend reconciliations procedures be implemented of property paid with federal funds and federal property listing. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools failed to identify ?Construction in Progress? paid for with federal funds as federal. Procedures will be updated to ensure ?Construction in Progress? paid with federal funds is identified and recorded as federal immediately rather than at the completion of the construction. While this finding is identified as a repeat finding from FY2021 (2021-006), the prior year was in reference to fixed assets while this year?s finding is in reference to ?Construction in Progress?.
2022-009 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Construction projects did not obtain certified payrolls documenting compliance with wage rate requirements. Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted construction requires that nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (Which still may be referenced as Davis-Bacon Act). Which includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each which in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Cause: The District had a letter from the contractor certifying compliance with Davis-Bacon Act but were unaware of need to obtain certified payrolls. Effect: The expenditures may be disallowed. Context: Unable to determine labor costs included in applications for payment from the contractor. Repeat Finding from Prior Year: No Recommendation Obtain certified payrolls for construction projects funded with federal awards. Determine that contracts for construction using federal funds include the appropriate clauses to be in compliance with federal procurement guidelines. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools obtained contractor certification of Davis-Bacon Act compliance, but did not obtain certified payrolls. The district identified this issue early in FY23 and immediately changed funding sources for the project. District construction bidding procedures for federally funded construction have been updated to include verbiage required by the Davis-Bacon Act.
2022-005 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Expenditures were paid without supporting invoices and proper District authority?s approval. Criteria: 2 CFR ?200.403 (g) Costs that meet general criteria in order to be allowable under federal awards must be adequately documented. Cause: Procedures in place for proper approval and documentation were not followed. Effect: The expenditures may be disallowed. Context: A sample of 32 expenditures totaling $3,037,928 was selected for audit from a population of $9,261,024. The test found 25 items that were not in compliance with questioned costs totaling $107,000. Questioned Costs: $107,000 Recommendation Expenditures should not be paid without the proper approval and supporting invoices. The District should follow procedures regarding requiring appropriate staff with authority to approve expenditures and requiring support for expenditures. Repeat Finding from Prior Year: No Views of Responsible Officials And Planned Corrective Action: Certain one-time COVID funds required several departments to make purchases. The lack of specific and clear guidance as to which department was directly responsible resulted in questioned expenditures. District Financial procurement procedures have been updated and implemented that require all federal expenditures to be approved through Lawton Public Schools? Federal Programs office. In addition, all supporting invoices for said expenditures must be provided to and approved by Lawton Public Schools? Federal Programs office. Lawton Public Schools will reimburse the State Department of Education for the total of these questioned costs.
2022-007 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Allowable costs/cost principles of indirect costs was overclaimed. Criteria: 34 CFR 76.569a Indirect costs= (restricted indirect cost rate) x (total direct costs of the grant minus capital outlays, subgrants, and other distorting or unallowable items as specified in the grantee?s indirect cost rate agreement). Cause: Failure to properly exclude construction activities from direct costs before the indirect costs were claimed. Effect: Indirect costs reimbursements were in excess of allowable amounts and may have to be returned. Context: Total expenditures, net of indirect cost and equipment capital expenditures, claimed were $23,578,870. Total construction capital expenditures claimed in this total were $2,341,866. The approved indirect cost rate was 2.74%. Total claimed indirect costs were $630,897. After excluding construction capital expenditures, overclaimed indirect cost found not to be in compliance was $49,003. Questioned Costs: $49,003 Repeat Finding from Prior Year: Yes; 2021-005 Recommendation Indirect costs should be claimed in accordance with allowable cost principles. Construction capital expenditures should be excluded from costs included in indirect cost claims. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools utilized the Oklahoma State Department of Education?s guidance and charged indirect costs for ?capital expenditures? and received reimbursement for those direct costs. The auditor has identified $49,003 as unallowable. Lawton Public Schools will reimburse the State Department of Education for the total of these unallowable costs regardless of SDE?s guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. Criteria: 2 CFR ?200.430(i)(1)(vii) Standards for Documentation of Personnel Expenses (1) Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-008 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Property acquired with federal funds were not tracked in property records. Criteria: 2 CFR 200.313(d)(1) requires property records must be maintained that include a description of the property, serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, the cost of the property, percentage of the federal project costs under which property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Cause: Failure to identify construction in progress as capital outlay for property. Effect: The expenditures may be disallowed. Context: A sample of $2,908,079 was selected for audit from a population of $3,035,125. The test found $2,341,866 was not in compliance. Questioned Costs: $2,341,866 Repeat Finding from Prior Year: Yes; 2021-006 Recommendation We recommend that property be properly tracked. We also recommend reconciliations procedures be implemented of property paid with federal funds and federal property listing. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools failed to identify ?Construction in Progress? paid for with federal funds as federal. Procedures will be updated to ensure ?Construction in Progress? paid with federal funds is identified and recorded as federal immediately rather than at the completion of the construction. While this finding is identified as a repeat finding from FY2021 (2021-006), the prior year was in reference to fixed assets while this year?s finding is in reference to ?Construction in Progress?.
2022-009 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Construction projects did not obtain certified payrolls documenting compliance with wage rate requirements. Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted construction requires that nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (Which still may be referenced as Davis-Bacon Act). Which includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each which in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Cause: The District had a letter from the contractor certifying compliance with Davis-Bacon Act but were unaware of need to obtain certified payrolls. Effect: The expenditures may be disallowed. Context: Unable to determine labor costs included in applications for payment from the contractor. Repeat Finding from Prior Year: No Recommendation Obtain certified payrolls for construction projects funded with federal awards. Determine that contracts for construction using federal funds include the appropriate clauses to be in compliance with federal procurement guidelines. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools obtained contractor certification of Davis-Bacon Act compliance, but did not obtain certified payrolls. The district identified this issue early in FY23 and immediately changed funding sources for the project. District construction bidding procedures for federally funded construction have been updated to include verbiage required by the Davis-Bacon Act.
2022-005 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Expenditures were paid without supporting invoices and proper District authority?s approval. Criteria: 2 CFR ?200.403 (g) Costs that meet general criteria in order to be allowable under federal awards must be adequately documented. Cause: Procedures in place for proper approval and documentation were not followed. Effect: The expenditures may be disallowed. Context: A sample of 32 expenditures totaling $3,037,928 was selected for audit from a population of $9,261,024. The test found 25 items that were not in compliance with questioned costs totaling $107,000. Questioned Costs: $107,000 Recommendation Expenditures should not be paid without the proper approval and supporting invoices. The District should follow procedures regarding requiring appropriate staff with authority to approve expenditures and requiring support for expenditures. Repeat Finding from Prior Year: No Views of Responsible Officials And Planned Corrective Action: Certain one-time COVID funds required several departments to make purchases. The lack of specific and clear guidance as to which department was directly responsible resulted in questioned expenditures. District Financial procurement procedures have been updated and implemented that require all federal expenditures to be approved through Lawton Public Schools? Federal Programs office. In addition, all supporting invoices for said expenditures must be provided to and approved by Lawton Public Schools? Federal Programs office. Lawton Public Schools will reimburse the State Department of Education for the total of these questioned costs.
2022-007 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Allowable costs/cost principles of indirect costs was overclaimed. Criteria: 34 CFR 76.569a Indirect costs= (restricted indirect cost rate) x (total direct costs of the grant minus capital outlays, subgrants, and other distorting or unallowable items as specified in the grantee?s indirect cost rate agreement). Cause: Failure to properly exclude construction activities from direct costs before the indirect costs were claimed. Effect: Indirect costs reimbursements were in excess of allowable amounts and may have to be returned. Context: Total expenditures, net of indirect cost and equipment capital expenditures, claimed were $23,578,870. Total construction capital expenditures claimed in this total were $2,341,866. The approved indirect cost rate was 2.74%. Total claimed indirect costs were $630,897. After excluding construction capital expenditures, overclaimed indirect cost found not to be in compliance was $49,003. Questioned Costs: $49,003 Repeat Finding from Prior Year: Yes; 2021-005 Recommendation Indirect costs should be claimed in accordance with allowable cost principles. Construction capital expenditures should be excluded from costs included in indirect cost claims. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools utilized the Oklahoma State Department of Education?s guidance and charged indirect costs for ?capital expenditures? and received reimbursement for those direct costs. The auditor has identified $49,003 as unallowable. Lawton Public Schools will reimburse the State Department of Education for the total of these unallowable costs regardless of SDE?s guidance stating otherwise.
2022-006 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Payroll expenditures did not have time and effort documentation. Criteria: 2 CFR ?200.430(i)(1)(vii) Standards for Documentation of Personnel Expenses (1) Charges to Federal Awards for salaries and wages must be based on records that accurately reflect the work performed. (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal Award. Cause: Employees charged to program left before the semi-annual time and effort was completed according to District policy. Effect: The expenditures may be disallowed. Context: A sample of 28 expenditures totaling $378,391 was selected for audit from a population of $11,846,116. The test found 2 items that were not in compliance with questioned costs totaling $9,549. Questioned Costs: $9,549 Recommendation Time and effort documentation needs to be maintained for payroll expenditures charged to federal awards. The District needs to time and effort documentation to a monthly process if hourly employees. Repeat Finding from Prior Year: Yes; 2021-004 Views of Responsible Officials And Planned Corrective Action: This is a repeat finding from FY2021 (2021-004). The finding was identified during our 2021 audit and corrected in March of 2022. It is important to note that, the United States Department of Education?s ?Frequently Asked Questions Elementary and Secondary School Emergency Relief Programs Governor?s Emergency Education Relief Programs? dated May 26, 2021 stated on page 19 that ?An LEA must maintain time distribution records (sometimes called ?time and effort? reporting) only if an individual employee is splitting his or her time between activities that may be funded under ESSER or GEER and activities that are not allowable under the applicable program.? After the 2021 was complete and 2022 was significantly underway, the auditor indicated that time-and-effort was required and the auditor stated that SDE agreed. Therefore, the district began obtaining time-and-effort for employees paid with federal funds in March of 2022, regardless of SDE and USDE guidance stating otherwise.
2022-008 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Property acquired with federal funds were not tracked in property records. Criteria: 2 CFR 200.313(d)(1) requires property records must be maintained that include a description of the property, serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, the cost of the property, percentage of the federal project costs under which property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Cause: Failure to identify construction in progress as capital outlay for property. Effect: The expenditures may be disallowed. Context: A sample of $2,908,079 was selected for audit from a population of $3,035,125. The test found $2,341,866 was not in compliance. Questioned Costs: $2,341,866 Repeat Finding from Prior Year: Yes; 2021-006 Recommendation We recommend that property be properly tracked. We also recommend reconciliations procedures be implemented of property paid with federal funds and federal property listing. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools failed to identify ?Construction in Progress? paid for with federal funds as federal. Procedures will be updated to ensure ?Construction in Progress? paid with federal funds is identified and recorded as federal immediately rather than at the completion of the construction. While this finding is identified as a repeat finding from FY2021 (2021-006), the prior year was in reference to fixed assets while this year?s finding is in reference to ?Construction in Progress?.
2022-010 Federal Agency: Federal Communication Commission Pass Thru Entity: Universal Service Administrative Company Program: COVID-19 Emergency Connectivity Fund Program Assistance Listing: 32.009 Grant Period: Year ending June 30, 2022 Condition: Devices/Services acquired with federal funds were not tracked to appropriate population of unmet needs. Criteria: FCC-ECF Program is to fund devices and services must be used primarily for off-campus educational purposes and by students, school staff with otherwise unmet needs; Who would otherwise lack access to connected device and/or broadband connectivity sufficient to engage in remote learning. Also requires that on device and service per user. 47 CFR 54.1715 Records retention?a) equipment and service inventory requirements. Schools, libraries and consortia shall keep asset and service inventories identified with the eligible student or staff member. Cause: The District failed to properly track the devices/services to the eligible population. Effect: The expenditures may be disallowed. Context: All expenditures related to the purchasing of devices or services were tested. 3900 Devices were purchased, and 1,877 devices were found not to be in compliance resulting in questioned costs of $557,333. Services provided of 5 months were not tracked and resulted in $90,531 of questioned costs. Questioned Costs: $647,864 Repeat Finding from Prior Year: No Recommendation Assets acquired with federal funds need to be tracked following the guidelines of the award. The District needs to develop procedures to identify devices/services are distributed to eligible students/staff as required by program. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools procedures require tracking of items with an acquisition cost of $5,000 or higher. These one-time FCC-ECF funds included specific criteria requiring specific tracking of all purchases including hotspots. These criteria were not identified immediately by the district. The district has updated procedures to include the tracking of all of these items even though they do not have an acquisition cost of $5,000 or higher.