Audit 398964

2025-005 Private/Home School Communications CFDA Title: Title I Grants to Local Educational Agencies CFDA Number: 84.010 Federal Award Number/Year: 2025 Federal Agency: U.S. Department of Education Pass-through Entity: Montana Office of Public Instruction Condition: The District did not communicate with the private/home school students. Context: The District did not send communications to the private/home schools in the Spring of 2024 for the FY24-25 school year to determine if any of those wanted to participate in the federal programs. Criteria: In the 2025 Compliance Supplement, Part 4 - Department of Education, page 22, it states “for programs funded under Title I, Part A (Assistance Listing 84.010), Local Education Agencies (LEA), after timely and meaningful consultation with private school officials, must provide equitable services to eligible private school children, their teachers, and their families. Eligible private school children are those who reside in a participating public school attendance area and have educational needs under Section 1115(c) of the ESEA (20 USC 6315(c)). The amount of funds an LEA makes available for equitable services under Title I, Part A must be equal to the proportion of funds generated by private school children from low-income families who reside in participating public school attendance areas.” Effect: The District is not in compliance with special tests and provisions of the Title I Grant. In addition, there could have been private/home school children that would have participated but were not made aware of the program. Cause: There was a change in staff during the time period that the communication would have occurred and this was an oversight by the new staff member. Recommendation: We recommend that the District, and all responsible employees, review compliance requirements for federal grants to ensure that they understand what they need to do. Also, policies and procedures should be in place to ensure that all requirements of federal grants are met.

2025-006 Program Income (Repeated 2024-004) CFDA Title: Title IV-B Twenty-First Community Learning Centers CFDA Number: 84.287 Federal Award Number/Year: S287C230026 / 2025 Federal Agency: U.S. Department of Education Pass-through Entity: Montana Office of Public Instruction Condition: The District did not comply with the program income compliance requirement for the Twenty-First Century Community Learning Center Grant. Context: As part of the federal compliance testing for the Twenty-First Century Community Learning Centers Grant, we tested to determine if the District charged fees associated with the program. We observed that fees were charged through October 2024 and then stopped. Criteria: In the 2025 Compliance Supplement, under Part 4 Department of Education, page 187 for Program Income related to the Twenty-First Century Community Learning Center grant, it states that a recipient or subrecipient that earns program income must deduct the amount of program income from the amount of the Federal award unless it has received prior written approval from ED to add the amount of program income to the amount of the Federal award. If the recipient or subrecipient receives prior written approval to add the amount of program income to the Federal award, the program income must be used for the purposes and under the conditions of the Federal award. Effect: The District was not incompliance with the program income requirement as they charged $38,205 in fees under the after-school program without approval and did not deduct that amount from the amount requested for reimbursement under the grant. We did also find that OPI has also identified these issues and had thus made a plan to lower the grant amounts for FY26, FY27, and FY28 to rectify the issue. Cause: The District was operating one after school program. There are kids that are free under the program and others that are charged. They kept two separate project reporter codes (PRCs) within their system. One PRC is for the Twenty-First Century Community Learning Centers Grant which is the free kids and the other is for the kids that are charged. They only had one set of coordinators/aides/program directors that runs the overall program through October 2024. They allocate costs for both payroll and other expenses between the two PRCs. The District thought if they kept two separate PRCs that they could charge. In November 2024, they split the program into two; the 21st Century program was held 3 days per week and free and the other after school program in which fees were charged was held the other two days. Recommendation: We recommend that the District ensure that either it gets preapproval from the granting agency prior to charging fees, or they deduct the amount charged for the federal grant and request reimbursement for that much less.