Audit 372148

2023-001 – Significant Deficiency and Nonmaterial Noncompliance – Allowable Costs and Activities Program: Title I Grants to Local Educational Agencies (ALN 84.010) – United States Department of Education – Virginia Department of Education; Federal Award Year: 2023. Criteria: Office of Management and Budget's (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subtitle A, Chapter II, Part 200, Subpart E – Cost Principles subsection 200.430 – Compensation – Personal Services subsection (i) – Standards for Documentation of Personnel Expenses subsection (1) states: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vi) 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; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two (2) or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: For a sample of forty (40) payroll and forty (40) non-payroll transactions, grant management could not provide certifications of time incurred and charged to the grant for two (2) employees. Cause: Employees and supervisors did not adhere to School Board time certification policies and procedures. Effect: Time incurred by personnel could be incorrectly allocated to federal programs. Questioned Costs: Two (2) grant charged employees approximating $6,400, from a sample population approximating $132,000. Recommendation: Employees charging time to a grant should have approved timesheets/records prior to payroll certification and processing. Views of Responsible Officials and Planned Corrective Action: Weekly staffing reports are sent to the locations for administrators to identify employees assigned to their location. Title 1 Grant Manager is sent a monthly personnel report that identifies all employees coded to Title 1 by location. There is a semi-annual in-person staff validation process. The team includes the enrollment and planning, Talent, and Budget Departments. The grants team will schedule standing meetings (biweekly) with the grant manager, accountant, and the Director of Budget to ensure all payroll is correct as it relates to Title I Part A. This will begin immediately following the next pay period. When discrepancies are identified, the Title 1 Grant Accountant will prepare an journal entry to move the payroll charges out of the Title 1 fund to the correct fund by journal entry

2023-002 – Significant Deficiency and Nonmaterial Noncompliance – Allowable Costs and Activities Program: Title I Grants to Local Educational Agencies (ALN 84.010) – United States Department of Education – Virginia Department of Education; Federal Award Year: 2023. Criteria: Annual Report Card, High School Graduation Rates – SEAs and LEAS must have implemented appropriate policies and procedures for documenting the removal of a student from the adjusted cohort. Condition: For a sample of four (4) students, grant management could not provide timely documentation for one (1) sample supporting the removal of a student from the regulatory adjusted cohort. Cause: Employees and supervisors did not maintain supporting documentation. Effect: Eligible participants may not receive opportunities to participate. Questioned Costs: None Recommendation: Grant administrator should maintain adequate documentation. Views of Responsible Officials and Planned Corrective Action: The Director of Academic Support will report monthly to the Grants Team during the regularly scheduled meeting the required information pertaining to this finding to make sure RPS is in compliance. This will begin in November at our regularly scheduled meeting.

2023-003 – Significant Deficiency and Compliance Qualification – Reporting Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) – United States Department of Education – Virginia Department of Education; Federal Award Year: 2023. Criteria: Project and Expenditure reports should be submitted to the VDOE quarterly and annually. Condition: The grant administrator was unable to provide quarterly and annual reporting requirements for fiscal year 2023. Cause: Documentation was not maintained for audit purposes. Effect: Accountability for use of the funds can not be demonstrated. Questioned Costs: None Recommendation: Grant administrator should maintain adequate documentation. Views of Responsible Officials and Planned Corrective Action: According to Appendix: American Rescue Plan CSLFRF HVAC Replacement and Improvement Grant Assurances of the 2021 CSLFRF HVAC Application it is stated the LEA/grantee assures: IX. It will submit such reports to the state educational agency as the state educational agency and Secretary may require to enable the state educational agency and the Secretary to perform their duties under the program; The LEA has also submitted an official correspondence to the Auditors from the Commonwealth of Virginia Department of Education’s Director of the Office of Federal Pandemic Relief Programs stating the following: On April 25, 2023, the Virginia Department of Education conducted monitoring to ensure that certain federally funded programs and activities supported with Elementary and Secondary School Emergency Relief (ESSER) formula grants; ESSER and Governor’s Emergency Education Relief (GEER) state setaside grants; and Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) HVAC grants were implemented as stipulated by law. These federally funded programs were reviewed as operated by Richmond City Public Schools. Furthermore, RPS is a subrecipient. As such it is our stance that RPS was not required to create or submit quarterly financial activity reports to US Treasury. We were also not required to submit quarterly financial reports to the recipient (i.e. the Commonwealth of Virginia). Instead, RPS regularly submitted expenditures for reimbursement to VDOE on a nearly monthly basis via OMEGA. We also maintained financial records (invoices, GL transactions) via AS400 and LINQ and conducted annual single audits as required by the Single Audit Act & 2 CFR part 200, subpart F. We also complied with all monitoring activities conducted by VDOE. In turn, VDOE (the award recipient) used these artifacts to create and submit its quarterly financial reports to US Treasury, as required by statute. For more evidence of this "passthrough" structure of reporting, see the attached SLFRF Compliance and Reporting Guidance published by US Treasury and Updated October 2025 Part 2 Section B (p. 21-22) for a detail of which entities are required to submit quarterly reports. The following recipients are required to submit quarterly Project and Expenditure Reports: - States and U.S. territories - Tribal governments that are allocated more than $30 million in SLFRF funding - Metropolitan cities and counties with a population that exceeds 250,000 residents Coronavirus State and Local Fiscal Recovery Funds C - Metropolitan cities and counties with a population below 250,000 residents that are allocated more than $10 million in SLFRF funding - NEUs [Non-Entitlement Units of Government] that are allocated more than $10 million in SLFRF funding RPS does not fall into any of the aforementioned categories. We humble ask that you reconsider this finding.