Audit 401215

2025-005 Title I Eligibility CFDA Title: Title I, Part A, Improving Basic Programs CFDA Number: 84.010A Federal Award Number: S010A230026 Federal Agency: US Department of Education Pass-through Entity: The Montana Office of Public Instruction Condition: The District does not have adequate internal controls in place to ensure that eligibility for students receiving targeted Title I services is properly documented and that student eligibility listings are accurate, complete, and reconciled. Context: A sample of 28 students receiving targeted Title I services was tested for eligibility compliance. For three students, the District could not provide supporting documentation to verify eligibility. Additionally, discrepancies were noted across multiple District-maintained Title I student listings, including inconsistencies and inclusion of students who did not meet established eligibility criteria. Criteria: The Elementary and Secondary Education Act and 2 CFR Part 200 require districts to maintain sufficient documentation to support student eligibility and retain records for audit. Questioned Costs: None Effect: The lack of adequate documentation and inconsistent eligibility records increases the risk of noncompliance with federal requirements. This may result in questioned costs, repayment of Title I funds, and the potential for ineligible students receiving services. Cause: The issue appears to be caused by inadequate record retention practices and weak internal controls over documentation management, including lack of standardized procedures for maintaining and reconciling eligibility records. Recommendation: It is recommended the District implement the following: • Implement and enforce standardized procedures for maintaining Title I eligibility documentation. • Ensure all eligibility determinations are fully documented and retained in accordance with federal requirements. • Reconcile all Title I student listings regularly to ensure accuracy and consistency. • Strengthen internal controls to ensure documentation is complete, accurate, and readily accessible for audit. • When eligibility is based on criteria other than assessment scores, formally document the rationale supporting eligibility.