Root Cause Analysis: The condition resulted from a lapse in the execution of an established control rather than the absence of a control framework. The EPI Center had formal memoranda of understanding in place with participating districts that defined match requirements, including in-kind contributi...
Root Cause Analysis: The condition resulted from a lapse in the execution of an established control rather than the absence of a control framework. The EPI Center had formal memoranda of understanding in place with participating districts that defined match requirements, including in-kind contributions of personnel time and effort, and contemplated periodic certification of those contributions. While the MOUs indicated that districts would confirm match contributions on a quarterly basis, The EPI Center did not consistently obtain those confirmations during the audit period. Since the audit period, The EPI Center has obtained written attestations from participating districts confirming the source and amount of the personnel contributions used as match and has implemented procedures to ensure that such certifications are collected and retained based on funder requirements. Response, with details: ☒Corrective Active Plan ☒Clarification 46 Management believes the match contributions reported are valid, reasonable, and allocable to the program. Match was calculated using verifiable district salary schedules and a consistently applied methodology (e.g., 25% effort allocation tied to program outcomes, participation, and service delivery). No evidence was identified indicating that federal funds were used to meet match requirements or that match contributions were applied to other federal programs. Importantly: There is no evidence that these salaries were charged to federal funds, mitigating the risk of double counting or supplanting. All personnel included as match were employees of public-school districts, whose compensation structures are governed by transparent, state- and locally- funded salary schedules. Services provided by these personnel supported program implementation and intended outcomes (e.g., coaching, mentoring, instructional support aligned with grant objectives). This finding reflects a documentation and control execution gap rather than a deficiency in the allowability or validity of match contributions. Corrective Actions The EPI Center has implemented, or is in the process of implementing, the following corrective actions to ensure full compliance moving forward: 1. Retroactive Certification (Completed - March 2026) Developed standardized district attestation forms for match contributions. Initiated collection of retroactive certifications from all participating districts to formally validate previously reported match. 2. Match Verification Process (Completed - April 2026) Established a certification process requiring district-level verification of match contributions. Management will align match verification with financial reconciliation and reporting in accordance with funder requirements. 3. Strengthened Partner Guidance and Agreements (Completed - April 2026) Updated MOUs and partnership agreement templates to include explicit federal documentation requirements for match that align to reporting requirements. Provided technical assistance to district partners to ensure consistent understanding and compliance. While the reported questioned cost exposure (approximately $3.4M) is acknowledged, The EPI Center notes that the condition relates to documentation rather than the underlying validity of the costs. There is no indication of unallowable costs, fraud, or misuse of funds, and no evidence that federal funds were used to meet match requirements. 47 All match contributions are based on public school district salary structures, which are subject to established oversight and accountability. Accordingly, the underlying match amounts are supported by objective and verifiable data sources. This finding reflects a documentation and timing matter, rather than concerns related to allowability, allocability, or program integrity. The EPI Center requests that this distinction be considered in assessing the overall severity and classification of the finding. Responsible Party: Project Lead, Finance Specialist Timeline for Completion: Ongoing with an expected completion date for all items by April 2026