Audit 370525

The District did not have adequate internal controls and did not comply with federal requirements for allowable activities. Assistance Listing Number and Title: 84.011 Migrant Education State Grant Program Federal Grantor Name: U.S. Department of Education Office of Elementary and Secondary Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: GT-01428 Known Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Background The objective of the Migrant Education State Grant Program is to support highquality and comprehensive educational programs for migratory children to help reduce education disruptions and ensure that migratory children receive full and appropriate opportunities to meet the same state academic content and achievement standards that all students are expected to meet. In fiscal year 2024, the District spent $1,629,035 in federal funding through the Migrant Education State Grant Program. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding the program requirements and monitoring the effectiveness of established controls. Federal regulations require the District to identify eligible migratory children and their needs, and to provide instructional and support services that address the identified needs of the eligible children. Description of Condition District controls were not adequate to ensure that it identified eligible migratory children and only provided services to eligible students. The District identified students that were included in the program that did not meet eligibility criteria. Subsequently, the District and the Office of the Superintendent of Public Instruction (OSPI) conducted additional interviews to confirm eligibility for all students the program served. Through this review, the District determined a significant number of students participating in the program were not eligible to receive services. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition For most of the year, one employee performed District eligibility interviews and determinations. Duties were not properly segregated nor was there adequate oversight of their responsibilities including student eligibility determinations. Effect of Condition The District later became aware it had provided services to students who were incorrectly determined to be eligible and did not qualify to receive services under the program. This also affects the amount of funding the District was awarded, as funding is based in part on the number of eligible students. We did not question costs charged to the program because eligibility testing was not subject to audit per the Compliance Supplement. OSPI is already working directly with the District to adjust the award amounts based on their review. Recommendation We recommend the District establish controls and ensure adequate oversight to ensure eligibility determinations are accurate and only eligible students are served by the program. District’s Response The district concurs with the finding and has taken corrective action. The employee referenced in the findings is no longer employed by the district. Throughout the months-long investigation performed by OSPI, the district worked to implement changes in our internal controls to ensure strong oversight of Migrant Education Program (MEP) grant compliance, including the eligibility determination process. Changes to internal controls include: • A monthly audit of the families who were visited that month. • A trained program recruiter will conduct the eligibility interviews and home visits. • Recruiter will work with regional trained recruiter for support. • A spot check audit of students determined to be eligible district program director. • Monthly logs from staff identifying students they worked with and services provided. • Monthly meetings between MEP district director and MEP regional program manager to ensure ongoing grant compliance. • Monthly meetings with MEP Parent Advisory Committee for ongoing feedback of services provided. • Appropriate staff including the program director are required to attend Migrant grant training provided by OSPI. We thank OSPI and the Washington State Auditor’s Office for their work and collaboration. We will continue regular monitoring of the Migrant Education Program in the Mount Vernon School district to ensure compliance with all program requirements and only eligible students are being served. Auditor’s Remarks We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Every Student Succeeds Act (ESEA), Title I, Part C, Sections 1304(c)(7) and 1309(2) Title 34 CFR Part 200, sections 81-89, contain the Migrant Education Program requirements.