Finding 2025-003: Allocating Funds to Eligible School Attendance Areas and Schools Information on the Federal Program: U.S. Department of Education, passed through the Illinois State Board of Education (ISBE) Title I – Low Income 84.010A, 24-4300-00 and 25-4300-00 Criteria: Title I eligibility requirements require the LEA to allocate funds to participating school attendance areas or schools in rank order based on the number of public school children from low-income families residing in the area or attending the school. The district’s approved Title I application established school-level building allocations. The District must follow the building allocations outlined and should document school-level expenditures to verify that the per-pupil allocation is followed. Condition: The District’s approved Title I application established school-level building allocations under Title I Targeting Step 5 using a per-pupil allocation methodology based on low-income counts. The District should document school-level expenditures to verify that the per-pupil allocation is followed. The District does not have effective controls to monitor school-level expenditures for compliance with approved Title I building allocations. Six of the 20 schools overspent their allocation by approximately $554,000. The other schools were under their allocations as a result. Cause: The District did not implement an effective control to monitor school-level expenditures against approved Title I building allocations throughout the year. Labor and staffing/FTE charges were recorded in a manner that caused expenditures by school to differ from the approved allocation methodology, and the District did not have a compensating review control to identify and resolve those variances timely. Effects or Potential Effect: The District could not demonstrate that school-level Title I expenditures were monitored and maintained in accordance with the approved building allocations. As a result, the District was noncompliant with Title I school allocation requirements. Questioned Costs: The amount of the overages of the allocation at six schools: $554,146 Context: During PPA testing, school-level actual expenditures were compared to the approved allocation methodology, excluding districtwide set-asides. Significant variances were identified between expected and actual school-level expenditures. The District stated that staffing/FTE distribution caused the allocation established in the budget to be distorted. ISBE correspondence further stated that the District must follow the building allocations in Targeting Step 5 and document school-level expenditures to verify compliance. Identification as a repeat finding, if applicable: Not a repeat finding Recommendation: We recommend the District strengthen its internal control over compliance by implementing procedures to monitor school-level Title I expenditures throughout the year against approved building allocations in the grant application. Monitoring should include timely comparison of budgeted and actual expenditures by school, review of staffing/FTE distributions charged to each school, investigation of significant variances, and documented corrective action when expenditures are not aligned with approved allocations. If revisions to school allocations are necessary, the District should maintain documentation supporting the revision and confirm that revised allocations remain consistent with Title I compliance requirements. View of responsible officials and planned corrective actions: The district is working with ISBE to ensure that our site-based resource allocations align with the district’s budget.