Audit 374232

CONDITION: The District used a local exemption in procuring one of its costs related to its ESSER program for the year ended June 30, 2025. CRITERIA: The South Carolina Department of Education (“SDE”) had issued a memorandum (“Memorandum”) in August 2023 notifying school districts that local exemptions could not be used in procurement activities related to federal programs. If a school district wanted to use noncompetitive procurements, they would need to (a) meet the exceptions noted in this Memorandum and as more fully detailed in Office of Management and Budget (“OMB”) 2 CFR 200.320 or (b) request and receive an approved waiver from the SDE on the “Request for Noncompetitive Procurement Approval” form. CONTEXT AND EFFECT: The OMB 2025 compliance supplement did not list in the compliance matrix a requirement to test the “Procurement and Suspension and Debarment” compliance requirement for this program. However, the SDE required that this compliance requirement be tested. For the year ended June 30, 2025, the District’s auditors tested approximately $390,000 in key items related to the ESSER program and noted one procurement for approximately $26,000 where the District used a local exemption. The District’s auditors tested a random sample of approximately $1,000 of other ESSER expenditures and noted no exceptions where the District used local exemptions. The actual known or likely questioned costs is not determinable – as it would be less than the total noncompetitive procurement. CAUSE: The District inadvertently used its local exemption for this federal purchase in this program. RECOMMENDATION: Even though the ESSER program is over, we would remind the District that procurements related to any federal programs should not use local exemptions – as these procurements should provide for full and open competition. RESPONSE: The District agrees with this finding and will adhere to the corrective action plan on page 123 in this audit report.

CONDITION: For the District’s Title I grants, the District did not properly obtain semi-annual certifications or personnel activity reports supporting the time and effort of 8 transactions (5 employees) that worked on this federal program. CRITERIA: The District was not fully complying with the Office of Management and Budget (“OMB”) and the South Carolina State Department of Education’s (“SDE”) requirements for proper support for federal salaries and wages for this program. CONTEXT, CAUSE, AND EFFECT: Where employees are expected to work solely on a single federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications. These certifications are to be prepared at least semi-annually and will be signed by the employee or the supervisory official having first-hand knowledge of the work performed by the employee. Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports. The District had reasonable supporting documentation for the payroll charged to this program, but inadvertently did not complete the time and effort documents as required by the SDE. RECOMMENDATION: The District is implementing procedures to ensure compliance with OMB and SDE requirements and to ensure time and effort documents are obtained for all Title I employees. RESPONSE: The District agrees with this finding and will adhere to the corrective action plan beginning on page 123 in this audit report.