CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Coupeville School District No. 204 September 1, 2024 through August 31, 2025 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal R...
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Coupeville School District No. 204 September 1, 2024 through August 31, 2025 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort and procurement requirements. Name, address, and telephone of District contact person: Stacy Larsen 501 S Main St Coupeville, WA 98239 (360) 678-2404 Corrective action the auditee plans to take in response to the finding: The District acknowledges the above finding related to time-and-effort documentation and procurement requirements under the Special Education program cluster (CFDA 84.027 – Special Education Grants to States and CFDA 84.173 – Special Education Preschool Grants), pass-through award GT-03882 administered by OSPI. The District acknowledges that due to turnover in key positions, time-and-effort documentation for two employees whose payroll and benefits costs totaling $83,902 were charged to the program was not retained and readily available. The District has since obtained and provided signed time-and-effort records to the auditor to support all payroll costs charged to the program. To prevent recurrence, the Business Manager has implemented a monthly checklist to ensure time-and-effort certifications are completed and signed by applicable staff within required timeframes, in compliance with OSPI Bulletin 039-24 and 2 CFR Part 200, Subpart E. This checklist will be maintained on file as documentation of ongoing compliance.The District acknowledges that price or rate quotations were not retained for two contractors providing speech-language pathology and occupational therapy services, totaling $134,444 in federal program funds, as required for personal services contracts between $10,000 and $250,000 under 2 CFR Part 200, section 320, and Board Policy 6220. To address this, the Business Manager will provide written guidance to special education leadership and applicable staff by June 12, 2026, outlining price and rate quotation requirements for personal services contracts and the District's documentation retention obligations under Board Policy 6220 and federal procurement standards. Going forward, the Business Manager will verify that all personal services contracts procured with federal funds include required price or rate quotation documentation prior to execution. The District is committed to maintaining these strengthened internal controls to ensure full and ongoing compliance with federal program requirements under the Special Education program cluster. Anticipated date to complete the corrective action: June 12, 2026