2022-005 Time and Effort Documentation Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425C/84.425D/84.425U/84.425W Federal Award Identification Number and Year: N/A Pass-Through Agency: New Mexico Public Education Department Pass-Through Number(s): 24301/24308/24355 Award Period: July 1, 2021-June 30, 2022 Type of Finding: -Significant Deficiency in Internal Control over Compliance, Other Matter Criteria or specific requirement: Per 2 C.F.R. ? 200.430 Compensation - personal services: charges to Federal awards for salaries and wages must be based on records that comply with the established accounting policies and procedures of the non-Federal entity and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated and reasonably reflect the total activity for which the employee is compensated by the non- Federal entity. Condition: During our audit of the Education Stabilization Fund program, we noted the following: -Out of 40 payroll selections tested, three selections were not supported by a Biannual Certification necessary for Time and Effort documentation. Questioned costs: None. Context: See ?Condition.? Cause: Management oversight. Effect: Noncompliance with applicable grant regulations and District Policy. Recommendation: We recommend tracking employees that have payroll disbursements charged to the grant and performing a review twice a year to ensure the Biannual Certifications are obtained for all employees that are required to submit one. Views of responsible officials: The Data Specialist position in the Federal Programs Department was vacant during the time of Biannual certification period and these 3 selections were unintentionally not included in the Biannual Certification necessary for Time and Effort documentation. The Federal Programs Department conducts a review twice a year and will continue to do so with more diligence to detail. When the position is filled, Executive Director of Federal Programs will ensure this individual is properly trained on the reporting procedures and will verify that all reports are completed correctly and in a timely manner before signing. The Executive Director of Federal Programs will ensure the corrective action plan is implemented in the next Biannual Certification period of January 2023.
2022-006 Policies on Internal Control Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425C/84.425D/84.425U/84.425W Federal Award Identification Number and Year: N/A Pass-Through Agency: New Mexico Public Education Department Pass-Through Number(s): 24308/24316 Award Period: July 1, 2021-June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matter Criteria or specific requirement: Per 29 C.F.R. ? 5.5 - Construction contracts greater than $2,000 must have a contract clause pertaining to prevailing wage rates. For each week in which work was performed under the contract, the contractor must be required to submit certified payrolls. Condition: During our audit of the Education Stabilization Fund program, we noted the following: ? The district did not have formal written policies or procedures in place for procurement to require contractors and subcontractors to submit certified payrolls for each week in which work was performed for construction contracts in excess of $2,000.. Questioned costs: None. Context: See ?Condition.? Cause: Management oversight. Effect: Noncompliance with applicable grant regulations. Recommendation: We recommend updating policies and procedures related to procurement to include the necessary clauses and requirements for construction contracts in excess of $2,000 when federal funds are being utilized. Views of responsible officials: A standard operating procedure (SOP) will be developed with the appropriate departments to ensure contractors are submitting their weekly payrolls to the District for any construction project that is federally funded or assisted in excess of $2,000.00. The Chief Procurement Officer will ensure the corrective action plan is completed by June 30, 2023.
2022-007 Special Provisions Testing ? Annual Report Card Federal agency: U.S. Department of Education Federal Program Title: Title I, Part A Assistance Listing Number: 84.010 Federal Award Identification Number and Year: N/A Pass-Through Agency: New Mexico Public Education Department Pass-Through Number(s): 24101 Award Period: July 1, 2021-June 30, 2022 Type of Finding: ? Significant deficiency in internal control over compliance, other matter Criteria or specific requirement: Per ESEA section 8101(23)(B) - To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain documentation from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or is deceased. Condition: During our audit of the Title I, Part A program, we noted the following: ? Out of 20 student removals from the cohort tested, six removals were not supported by appropriate written documentation and were thus inappropriately removed from the cohort. Questioned costs: None. Context: See ?Condition.? Cause: Management oversight. Effect: Noncompliance with applicable grant regulations and District Policy Recommendation: We recommend providing training to school sites to ensure personnel who are responsible for obtaining appropriate documentation for changes to a student file that result in removal from the cohort are aware of the requirement. Views of responsible officials: Las Cruces Public Schools (LCPS) uses the NM Graduation Technical Manual to guide expectations and processes for graduation cohort review for all schools. The District currently supports each registrar with live data dashboards to monitor students who have withdrawn across which includes the NM State code. The LCPS Information Operations Department, who over sees STARS collections, meets with all registrars yearly to review the dashboards, review the NM graduation Technical Manual, along with all internal process of where the documentation needs to occur. After findings from the audit, the following will be added to our process.
2022-005 Time and Effort Documentation Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425C/84.425D/84.425U/84.425W Federal Award Identification Number and Year: N/A Pass-Through Agency: New Mexico Public Education Department Pass-Through Number(s): 24301/24308/24355 Award Period: July 1, 2021-June 30, 2022 Type of Finding: -Significant Deficiency in Internal Control over Compliance, Other Matter Criteria or specific requirement: Per 2 C.F.R. ? 200.430 Compensation - personal services: charges to Federal awards for salaries and wages must be based on records that comply with the established accounting policies and procedures of the non-Federal entity and be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated and reasonably reflect the total activity for which the employee is compensated by the non- Federal entity. Condition: During our audit of the Education Stabilization Fund program, we noted the following: -Out of 40 payroll selections tested, three selections were not supported by a Biannual Certification necessary for Time and Effort documentation. Questioned costs: None. Context: See ?Condition.? Cause: Management oversight. Effect: Noncompliance with applicable grant regulations and District Policy. Recommendation: We recommend tracking employees that have payroll disbursements charged to the grant and performing a review twice a year to ensure the Biannual Certifications are obtained for all employees that are required to submit one. Views of responsible officials: The Data Specialist position in the Federal Programs Department was vacant during the time of Biannual certification period and these 3 selections were unintentionally not included in the Biannual Certification necessary for Time and Effort documentation. The Federal Programs Department conducts a review twice a year and will continue to do so with more diligence to detail. When the position is filled, Executive Director of Federal Programs will ensure this individual is properly trained on the reporting procedures and will verify that all reports are completed correctly and in a timely manner before signing. The Executive Director of Federal Programs will ensure the corrective action plan is implemented in the next Biannual Certification period of January 2023.
2022-006 Policies on Internal Control Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing Number: 84.425C/84.425D/84.425U/84.425W Federal Award Identification Number and Year: N/A Pass-Through Agency: New Mexico Public Education Department Pass-Through Number(s): 24308/24316 Award Period: July 1, 2021-June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matter Criteria or specific requirement: Per 29 C.F.R. ? 5.5 - Construction contracts greater than $2,000 must have a contract clause pertaining to prevailing wage rates. For each week in which work was performed under the contract, the contractor must be required to submit certified payrolls. Condition: During our audit of the Education Stabilization Fund program, we noted the following: ? The district did not have formal written policies or procedures in place for procurement to require contractors and subcontractors to submit certified payrolls for each week in which work was performed for construction contracts in excess of $2,000.. Questioned costs: None. Context: See ?Condition.? Cause: Management oversight. Effect: Noncompliance with applicable grant regulations. Recommendation: We recommend updating policies and procedures related to procurement to include the necessary clauses and requirements for construction contracts in excess of $2,000 when federal funds are being utilized. Views of responsible officials: A standard operating procedure (SOP) will be developed with the appropriate departments to ensure contractors are submitting their weekly payrolls to the District for any construction project that is federally funded or assisted in excess of $2,000.00. The Chief Procurement Officer will ensure the corrective action plan is completed by June 30, 2023.
2022-007 Special Provisions Testing ? Annual Report Card Federal agency: U.S. Department of Education Federal Program Title: Title I, Part A Assistance Listing Number: 84.010 Federal Award Identification Number and Year: N/A Pass-Through Agency: New Mexico Public Education Department Pass-Through Number(s): 24101 Award Period: July 1, 2021-June 30, 2022 Type of Finding: ? Significant deficiency in internal control over compliance, other matter Criteria or specific requirement: Per ESEA section 8101(23)(B) - To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain documentation from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or is deceased. Condition: During our audit of the Title I, Part A program, we noted the following: ? Out of 20 student removals from the cohort tested, six removals were not supported by appropriate written documentation and were thus inappropriately removed from the cohort. Questioned costs: None. Context: See ?Condition.? Cause: Management oversight. Effect: Noncompliance with applicable grant regulations and District Policy Recommendation: We recommend providing training to school sites to ensure personnel who are responsible for obtaining appropriate documentation for changes to a student file that result in removal from the cohort are aware of the requirement. Views of responsible officials: Las Cruces Public Schools (LCPS) uses the NM Graduation Technical Manual to guide expectations and processes for graduation cohort review for all schools. The District currently supports each registrar with live data dashboards to monitor students who have withdrawn across which includes the NM State code. The LCPS Information Operations Department, who over sees STARS collections, meets with all registrars yearly to review the dashboards, review the NM graduation Technical Manual, along with all internal process of where the documentation needs to occur. After findings from the audit, the following will be added to our process.