Condition: The District’s accounts payable process does not have a procedure that clearly documents when and by whom the expenditure was authorized nor does the process include cut-off procedures to apply the expenditure to the proper period. Criteria: Controls should be in place to ensure that expenses are recorded in the period in which the expenses are incurred and to ensure that staff with the appropriate level of authority approves the transaction. 2 CFR 200.302. Cause of Condition: Procurement transactions are initiated by several individuals within the District at times without review and approval by a District or program supervisor. Procurement transactions are not entered into the account system with the date the liability was incurred. Effect of Condition: Expenditures could be processed and paid without proper authorization and posted to an improper period. Questioned Costs: none. Recommendation: Develop procedures to ensure purchases are authorized prior to recording and paying the invoice. The procedures may include development of lines of authority whereby an individual is approved to authorize purchases up to a particular dollar threshold and require that all invoices/documentation be signed/initialed by authorized approver. Accounts payable process should include cutoff procedures to ensure expenditure is recorded in period that liability is incurred. Corrective Action Plan: Policies and procedures will be clearly defined both administratively and within each department to ensure purchases are authorized prior to recording and paying the invoice. The procedures will include development of lines of authority for approval and to authorize purchases, including up to a particular dollar threshold where applicable. The procedures will also require that all invoices/documentation, purchase order forms and packing slips be signed/initialed by authorized approver. Accounts payable process will include cutoff procedures to ensure expenditure is recorded in period that liability is incurred. All department managers and administrative staff will attend training and routine follow-up training on purchasing policies and procedures. A sign in sheet will be required for those attending. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
Condition: Capital assets are not tracked adequately for proper presentation in the financial statements. Criteria: GASB Code section 1400. Cause of Condition: Capital assets, as defined by the District’s capitalization policy, are not adequately tracked for presentation in the government-wide financial statements. Effect of Condition: The potential exists to overstate expenditures and understate capital assets in the government-wide statements. Questioned Costs: none. Recommendation: We recommend contemporaneously adding capital assets to a subledger for tracking which should include assigning a useful life to the asset. Additionally, we recommend scanning relevant expenditure accounts for uncapitalized expenditures. Corrective Action Plan: Capital assets will be added as invoices occur and added to a subledger for tracking which will include assigning a useful life to the asset. Additionally, relevant expenditure accounts for uncapitalized expenditures will be scanned. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
Condition: Bank reconciliations are not always performed in the subsequent month. Bank reconciliations or copies of bank statements are not reviewed by anyone outside the accounting department. Criteria: Generally accepted control procedures. Cause of Condition: Bank reconciliations are not performed in a timely manner (within subsequent month) and nonaccounting staff are not involved in control procedures surrounding the cash accounts.Effect of Condition: The potential exists for fraud or errors to go undiscovered and uncorrected in a timely manner. Questioned Costs: none. Recommendation: We recommend that bank reconciliations be performed in the subsequent month and also that bank statements (and possibly bank reconciliations) be reviewed by non-accounting staff (District Director and/or Board member). Corrective Action Plan: Beginning January 2026, all bank accounts will be reconciled within 15 business days of month-end. Completed reconciliations and corresponding bank statements will be reviewed and signed by the District Director, with quarterly oversight by the Board. All documentation will be stored electronically for audit verification. The Financial Procedures Manual will be created and updated to reflect these requirements and establish clear timelines and responsibilities for review. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
Condition: Support for expenditure transactions does not indicate approval from an appropriate manager with authority over the department/program. Auditor tested 57 transactions of which 17 did not include evidence of approval (excluding routine expenditures such as utility bills). Criteria: Generally accepted control procedures and 2 CFR 200.302. Cause of Condition: Initiating procurement transactions without proper approval or failing to document that approval was obtained prior to initiating the transaction. Effect of Condition: Unapproved charges, including potential unallowable costs, may be incurred and charged to the District, including federal or state programs. Additionally, the potential exists for fraud or errors to go undiscovered and uncorrected in a timely manner. Questioned Costs: none.Recommendation: We recommend that a purchase order or purchase requisition system be devised to ensure all expenditures, including those paid for by credit cards, are approved by an appropriate manager prior to making the purchase. Corrective Action Plan: Beginning January 2026, all purchases, including credit card transactions, will require Purchase approval by the Program Manager and administration prior to purchase. A Purchase Order tracking process will be implemented in Blackbaud Financial Edge NXT by April 2026 to ensure all expenditures are properly documented. All department managers and administrative staff will attend training and routine follow-up training on purchasing policies and procedures. A sign in sheet will be required for those attending. The Financial Procedures Manual will be created and updated by June 2026 to include revised procurement approval requirements. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 06/01/2026
Condition: 1- Gross payroll calculations could not be supported for several employees tested due to missing pay rate support. 2- Gross payroll calculations could not be supported for several employees tested due to missing timesheets. 3- Classification errors were noted in 2 of 11 periods tested (34 of 86 individuals tested). Criteria: Generally accepted control procedure and 2 CFR 200.302 Cause of Condition: Missing documentation resulted in conditions 1 and 2. The cause of the classification differences between the accounting department’s payroll worksheet and the general ledger postings are unknown. Due to staff turnover, the cause could not be determined. Effect of Condition: Employees may be paid at unapproved rates or for unworked time. Classification errors may result in over/under charging grant programs.Questioned Costs: Condition 1: Known: $ 412.54 Questioned: $ 5,580.24 Condition 2: Known: $ 20,357.31 Questioned: n/a Condition 3: Known: $ 91,593.05 Questioned: n/a Recommendation: We recommend: - Records be retained to support all transactions recorded to the general ledger. - Department managers review and approve all payroll-related source documents (personnel action forms, timesheets, etc.) prior to finalizing the payroll run. - Administrative manager review and approve payroll worksheet prior to finalizing the payroll run and posting to the general ledger. Corrective Action Plan: Beginning January 2025, the District strengthened payroll documentation and review procedures to ensure compliance with 2 CFR 200.302. Personnel Action Forms and timesheets will be required, approved by department managers, and retained electronically for all employees. The Administrative staff reviews and approves payroll worksheets prior to posting to the general ledger. All department managers and administrative staff will attend training and routine follow-up training on purchasing policies and procedures. A sign in sheet will be required for those attending. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
Condition: The District has not adopted written policies or procedures regarding procurements or the determination of allowable costs in accordance with the Uniform Guidance. Criteria: 2 CFR 200.302(b)(7), 2 CFR 200.318(a), and 2 CFR 200.319(d). Cause of Condition: Unfamiliarity with requirements stated in 2 CFR 200 of the Uniform Guidance.Effect of Condition: Effect is a state of noncompliance which may impact future grant awards or failure to identify and reject un-allowed costs charged to grant programs. Questioned Costs: none. Recommendation: Draft and adopt policies and procedures to become compliant with Uniform Guidance. Corrective Action Plan: Agency policies and procedures, including a guidance template will be clearly defined to ensure compliance with Uniform Guidance. All department managers and administrative staff will attend training and routine follow-up training on purchasing policies and procedures. A sign in sheet will be required for those attending. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
Condition: The District has not adopted formal controls to detect and prevent unallowable costs from being charged to grant programs. Auditor substantively tested 29 expenditures, including indirect costs, across all major programs noting that all items tested were for allowable costs. Criteria: 2 CFR 200.303(a). Cause of Condition: Unfamiliarity with requirements stated in 2 CFR 200 of the Uniform Guidance. Effect of Condition: Effect is a state of noncompliance which may impact future grant awards or failure to identify and reject un-allowed costs charged to grant programs. Questioned Costs: none. Recommendation: Draft and adopt policies and procedures to become compliant with Uniform Guidance.Corrective Action Plan: Agency policies and procedures, including a guidance template will be clearly defined to ensure compliance with Uniform Guidance. All department managers and administrative staff will attend training and routine follow-up training on purchasing policies and procedures. A sign in sheet will be required for those attending. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
Condition: The District has not retained transaction support for all expenditures related to federal programs. Auditor substantively tested 29 expenditures across all major programs noting that 10 items did not have proper supporting documentation. Criteria: 2 CFR 200.334. Cause of Condition: Records retention procedures were not sufficient to ensure fiscal year 2022 transactions were retained through October 2025. Effect of Condition: Records supporting expenditures of federal awards were not located. Consequently, the auditors could not adequately test these items. Questioned Cost: $ 35,017.55 Recommendation: Draft and adopt policies and procedures to ensure compliance with record retention requirements. Corrective Action Plan: The District will adopt updated record retention policies. Procedures will require all supporting documentation for federal expenditures to be retained for a minimum of five years after final closeout, in both electronic and hard-copy form. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
Condition: An audit of the financial statements of the District along with the required single audit, as required by the Uniform Guidance, was not filed within the required time frame. Criteria: 2 CFR 200.512. Cause of Condition: The District’s books and records were not prepared in time to perform the financial statement audit and single audit. Fiscal year 2022 financial statement audit and single audit was performed in 2025. Effect of Condition: Delinquent filing with the federal audit clearinghouse (FAC), potential for lost records and other information needed to perform and complete the financial statement audit and single audit. Questioned Cost: none. Recommendation: Draft and adopt policies and procedures to ensure the District’s financial records are ready for audit with sufficient time to timely file with the FAC. Corrective Action Plan: The District will implement procedures to ensure financial records are closed and ready for audit within 90 days of fiscal year-end. A calendar of key audit deadlines will be established, and staff will coordinate with the external auditor each quarter to maintain audit readiness and ensure timely FAC submission. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 11/01/2026