Audit 391921

Finding Reference: 2025-001 – Procurement, Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program: 84.027 – IDEA Compliance Requirement:Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control Over Compliance and NonCompliance Criteria: The School District is required to maintain and use documented procurement procedures for procurement transactions under federal awards, and those procedures must be consistent with state/local requirements and the federal procurement standards in 2 CFR 200.317-200.327. When a noncompetitive (sole source) procurement method is used, it must be supported by circumstances and documentation consistent with the Uniform Guidance procurement methods requirements in 2 CFR 200.320 (including maintaining sufficient documentation to support the selected procurement method in the procurement file). Statement of Condition: The School District procured IDEA services through the Lincoln Intermediate Unit using a noncompetitive (sole source) approach. The School District did not retain documentation in the procurement file to support the basis for noncompetitive procurement. Statement of Cause: The School District did not consistently follow documented procurement procedures for the IDEA program and the procedures. Possible Asserted Effect: Without documentation supporting the noncompetitive procurement method, the School District is not able to demonstrate compliance with federal procurement requirements applicable to IDEA. Questioned Costs: None noted. Context: One vendor was utilized and there was not appropriate documentation maintained of procurement regarding the services. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that a process be implemented to review the services provided under the IDEA program to ensure procurement documentation is appropriately maintained. Views of Responsible Officials and Planned Corrective Actions: The School District's practice has been to utilize all IDEA funding to support the education of IDEA-qualified students through the use of the Lincoln Intermediate Unit services conducted at the Franklin Learning Center (FLC). 100% of the IDEA funds are utilized to pay for a portion of the services provided by the FLC. The FLC is the only center operating in Franklin County. To ensure compliance with this standard in the future, the Assistant to the Chief Financial and Operations Officer will provide the Director of Special Education and the Superintendent with the Sole Source Justification form by July 1st of each year. The Director of Special Education and the Superintendent will be responsible for completing the Sole Source Justification form and submitting a copy of the signed document to the Business Office. The Special Education Financial Secretary will attach the Sole Source Justification form to the purchase requisition for services from the Franklin Learning Center for the IDEA-qualified students.

Finding Reference: 2025-002 – Special Tests and Provisions Federal Agency: U.S. Department of Education Federal Program: 84.010 – Title I Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control Over Compliance and NonCompliance Criteria: The School District is required to maintain records that support the removal of a student from the adjusted cohort, such as documentation to transfer to another diploma granting program, emigration, consistent with federal reporting requirements. Statement of Condition: We identified instances in which the School District had students removed from the adjusted cohort, but did not maintain sufficient written documentation to support the removal. Statement of Cause: The School District did not have adequate procedures to ensure that the documentation supporting adjusted cohort removals was obtained, reviewed, and retained. Possible Asserted Effect: Without appropriate documentation supporting removal of students from the adjusted cohort, the School District is unable to demonstrate compliance with federal record keeping requirements. Questioned Costs: None noted. Context: A sample of 25 students that had withdrawn was selected and 3 student files were not able to be provided. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that a process be implemented to ensure appropriate written documentation is maintained for all student withdrawals. Views of Responsible Officials and Planned Corrective Actions: Our previous withdrawal process involved keeping a paper copy of the documentation and adding a note in the Student Information System. However, this approach did not provide a designated, centralized location for storing the required records. To ensure compliance going forward, we have created a specific folder within our Student Information System for uploading and maintaining all withdrawal paperwork. All staff responsible for processing withdrawals have received instructions for this updated procedure via email, and the guidance has also been added to the Secretary's Manual.