Criteria or specific requirement: Title 2 CFR §200.318(c)(1)–(2) requires non-Federal entities to maintain written standards of conduct governing conflicts of interest for employees, officers, and agents engaged in the selection, award, and administration of contracts supported by Federal awards. The standards must prohibit participation in procurement actions where a real or apparent conflict of interest exists, restrict the solicitation or acceptance of gratuities or items of monetary value, provide for disciplinary actions for violations, and address District conflicts of interest when applicable. Condition: The District did not maintain written standards of conduct covering conflicts of interest related to procurement activities. Specifically, the District lacked formal written policies addressing employee and District conflicts of interest, acceptance of gifts or gratuities from contractors, and disciplinary actions for violations of conflict-of-interest requirements. Questioned costs: None Context: The District does not have a policy in place surrounding conflict of interest. Cause: The District had not established or formally adopted procurement policies incorporating the conflict-of-interest requirements of Uniform Guidance. Effect: The absence of written standards of conduct increases the risk that procurement actions may be influenced by real or apparent conflicts of interest and may result in noncompliance with Federal procurement requirements. Repeat Finding: No Recommendation: We recommend that the District develop, approve, and implement written standards of conduct in compliance with 2 CFR §200.318(c)(1)–(2). The standards should address individual and District conflicts of interest, restrictions on gifts and gratuities, and disciplinary actions for violations, and should be communicated to all personnel involved in procurement activities. Views of responsible officials: [There is no disagreement with the audit finding.] Action taken in response to finding: We will create a policy for conflict of interest requirements of Uniform Guidance. Name of the contact person responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025
Criteria or specific requirement: Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal controls should include procedures in place to ensure the required certifications for covered contracts and subawards are received, documented, and contracts are not made with a debarred or suspended party. Condition: During our testing of three covered transactions, we noted one vendor did not have proper supporting documentation for suspension and debarment procedures for vendors. Questioned costs: None. Context: One covered transaction tested did not have proper supporting documentation for suspension and debarment procedures. Cause: Lack of sufficient controls in place to ensure that suspension and debarment checks were performed prior to entering into contracts. Effect: Failure to obtain the required certifications or perform verification procedures with the SAM could result in the payment of federal funds to vendors that are suspended or debarred from participation in federal assistance programs. Repeat Finding: No Recommendation: We recommend the District obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on SAM.gov. Views of responsible officials: [There is no disagreement with the audit finding.]
Criteria or specific requirement: 2 CFR §200.302(b)(3) and §200.303 require non-Federal entities to maintain effective internal control over Federal awards, including written documentation supporting the review and approval of transactions prior to submission for reimbursement. Condition: During our testing over reimbursement requests, we noted the review and approval was not formally documented before submission of the requests. Questioned costs: None Context: There was no formal documentation for review and approval of reimbursement requests before submission. Cause: The District does not have a formalized process requiring documented evidence of review and approval of reimbursement requests before submission. Effect: Without documented review and approval, the District increases the risk that reimbursement requests may include unallowable, inaccurate, or unsupported costs, resulting in potential noncompliance with Federal requirements. Repeat Finding: No Recommendation: We recommend the District implement a formal process requiring documented evidence of review and approval of all reimbursement requests prior to submission, such as dated sign-offs or electronic approval records, to strengthen internal controls and ensure compliance with Federal requirements. Views of responsible officials: [There is no disagreement with the audit finding.] Action taken in response to finding: The District will provide formal documentation by reviewing and signing the claims for approval of reimbursement requests before submission to the state. Name of the contact person responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025
Criteria or specific requirement: 2 CFR §200.512(a)(1) requires non-Federal entities to submit the data collection form (SF-SAC) and the reporting package to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period. Condition: The District did not submit the data collection form and reporting package to the Federal Audit Clearinghouse within the required timeframe for the audit period tested. Questioned costs: None Context: The District did not submit their Data Collection Form on time for FY2024. Cause: The District did not have effective procedures in place to monitor and ensure timely submission of the data collection form and reporting package to the Federal Audit Clearinghouse. Effect: The late submission caused the District to be a high risk auditee for FY2025. Repeat Finding: No Recommendation: We recommend the District implement procedures to monitor audit reporting deadlines and ensure the data collection form and reporting package are submitted to the Federal Audit Clearinghouse within the required timeframe. Views of responsible officials: [There is no disagreement with the audit finding.] Action taken in response to finding: We had a different auditing firm and were under the impression they had submitted it. We will ensure we will not be late again and submit it on time. Name of the contact person responsible for corrective action: Stacy Rodriguez (Director of Finance) Planned completion date for corrective action plan: September 2025
Criteria or specific requirement: Title 2, Code of Federal Regulations (CFR), Part 200.430(g) requires that charges to federal awards for salaries and wages be based on records that accurately reflect the work performed. This includes time and effort documentation that is supported by a system of internal controls and, for employees working on a single federal program, certifications that are prepared at least semi‑annually and signed by the employee or a supervisory official with first‑hand knowledge of the work performed. Condition: The District did not complete time and effort certifications for the teachers whose salaries and benefits were charged to the grant during the year. Questioned costs: None Context: There were no formal procedures in place surrounding time and effort certifications for teachers under the ESSER grant. Cause: The District did not have formal procedures in place to ensure time and effort certifications were completed for all teachers charged to the ESSER grant. Effect: Without properly signed time and effort certifications, the District cannot adequately support that salary and benefit costs charged to federal programs are allowable and accurately allocated. Repeat Finding: No Recommendation: We recommend the District implement written procedures that require timely preparation and retention of documentation supporting the work performed and allocation methodology and supervisory review/approval consistent with the District's policies. Views of responsible officials: [There is no disagreement with the audit finding.] Action taken in response to finding: The district will ensure we are completing time and effort logs for staff who are federally funded. Name of the contact person responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025
Criteria or specific requirement: Section 18005 of the CARES Act, as amended and extended through the ESSER programs, and implementing guidance issued by the U.S. Department of Education, require local educational agencies (LEAs) receiving ESSER funds to provide equitable services to eligible private school students and teachers. LEAs are required to engage in timely and meaningful consultation with representatives of private schools, determine the proportionate share of funds, and ensure services are provided in accordance with applicable requirements. Condition: The District did not comply with equitable services requirements for ESSER funds. Specifically, the District did not adequately document or perform timely and meaningful consultation with eligible private school officials, and required procedures to determine and provide equitable services to private school students and teachers were not followed for the period tested. Questioned costs: None Context: There was no communication with private schools regarding ESSER funding. Cause: The District did not have sufficient policies, procedures, or monitoring controls in place to ensure compliance with equitable services requirements for ESSER funds. In addition, staff responsible for administering ESSER programs were not adequately trained on the private school participation requirements. Effect: As a result of this condition, the District did not provide assurance that eligible private school students and teachers received equitable services as required. Repeat Finding: No Recommendation: We recommend the District establish and document formal procedures to ensure compliance with equitable services requirements for ESSER funds. These procedures should include timely and meaningful consultation with private school officials, proper documentation of consultation and decision‑making, and ongoing monitoring to ensure services are provided in accordance with federal requirements. Views of responsible officials: [There is no disagreement with the audit finding.] Action taken in response to finding: We will ensure compliance with equitable services to private schools. Name of the contact person responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025
Criteria or specific requirement: For construction, alteration, or repair projects funded with ESSER monies, recipients must comply with applicable federal wage rate requirements, including inclusion of prevailing wage provisions in contracts and maintenance of sufficient documentation to support compliance. Condition: The District did not maintain sufficient documentation to demonstrate compliance with wage rate requirements for ESSER-funded construction activities. The contract reviewed did not include a clause requiring compliance with applicable prevailing wage requirements. Questioned costs: None Context: The contract with the vendor did not include a paragraph acknowledging wage rate requirements. Cause: The District did not have adequate controls in place to ensure that wage rate requirements were incorporated into ESSER-funded contracts. Effect: Because the contract lacked required wage provisions, the District could not demonstrate that workers were compensated in accordance with applicable prevailing wage requirements. Repeat Finding: No Recommendation: We recommend the District strengthen internal controls over ESSER-funded construction projects by ensuring all contracts contain required prevailing wage provisions when applicable. Views of responsible officials: [There is no disagreement with the audit finding.] Action taken in response to finding: If given ESSER funding again we will ensure the district abides by the adequate controls for funded contracts. Name of the contact person responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025