Audit 390658

Criteria: 2 CFR 200.430 requires that costs of compensation be reasonable and properly supported to ensure charges are accurate, allowable, and properly allocated. Condition: During testing, it was noted that the Board was unable to provide a periodic certification for 11 employees who were paid under the Elementary and Secondary School Emergency Program (ESSER) - a subprogram of the Education Stabilization Fund (ESF). Cause: Documentation was not available to current management. Prior management was not available for inquiry. Effect: Costs for employees paid with ESSER funds is not able to be substantiated. Questioned Costs: $150,091 which includes known costs of $110,809 and likely questioned costs of $39,282. Recommendation: Management should implement a process and appropriate controls to ensure costs charged to federal awards are substantiated, accurate, allowable, and properly allocated and documentation of such is properly maintained. View of Responsible Officials: The Board concurs with this finding and has taken steps towards the reassessment of controls and will review these accounts and implement controls to ensure timely signatures on award certifications.

Criteria: 2 CFR 200.305 requires entities requesting reimbursements to do so in a manner to minimize time elapsing between the transfer of funds to the entity and the payment of funds by the entity. Requests should be properly supported and approved prior to submission. Condition: Substantiating support was only available for one draw for reimbursement of funds. Cause: Documentation was not available to support draws for total expenditures. Effect: Not all reimbursement requests met the criteria to be properly supported and approved. Questioned Costs: $97,220. Recommendation: The entity should strengthen controls and procedures surrounding the cash management (or reporting) function. View of Responsible Officials: The Board concurs with this finding and has taken steps towards the reassessment of controls and will review these accounts and implement controls to ensure proper submission and approval over ESSER funds for reimbursement.

Criteria: For construction contractors exceeding $2,000, the contracting entity is required to communicate prevailing wage requirements in accordance with the Davis-Bacon Act. Additionally, the contractor is required to submit weekly certified payroll reports. Condition: During testing, 3 projects we identified for which no Davis-Bacon disclosure were made and no certified payrolls were provided. Cause: The entity did not identify the contracts as requiring compliance with the Davis-Bacon Act. Effect: See above condition. Questioned Costs: $282,074 which includes $247,708 of known and $34,366 of questioned costs. Recommendation: We recommend management implement a system of controls and procedures to ensure compliance with Davis-Bacon requirements. View of Responsible Officials: The Board concurs with this finding and has taken steps towards the reassessment of controls and will review these accounts and implement controls to ensure appropriate conditions are met according to the Davis-Bacon Act.