FAC Explorer

Finding 1073074 (2023-008)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-09-12
Audit: 319431
Organization: City of Boston (MA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: Boston Public Schools (BPS) failed to conduct timely consultations with private school officials, impacting equitable services for eligible private school children.
  • Impacted Requirements: BPS did not maintain necessary documentation to support the counts of eligible private school children, leading to potential inaccuracies in funding calculations.
  • Recommended Follow-Up: BPS should improve tracking of consultation dates and retain correspondence from private schools to ensure compliance and accurate data usage.

Finding Text

Finding number: 2023 008 Federal agency: U.S. Department of Education Pass through agency: Commonwealth Department of Elementary and Secondary Education Program: Title I, Grants to Local Education Agencies ALN #: 84.010 Award number: Various Award year: Various Finding: Internal Control and Compliance over Participation of Private School Children Prior Year Finding: No Type of Finding: Material Weakness Criteria For programs funded under Title I, Part A (Assistance Listing 84.010), an LEA, after timely and meaningful consultation with private school officials, must provide equitable services to eligible private school children, their teachers, and their families. Eligible private school children are those who reside in a participating public school attendance area and have educational needs under Section 1115(c) of the ESEA (20 USC 6315(c)). The amount of funds an LEA makes available for equitable services under Title I, Part A must be equal to the proportion of funds generated by private school children from low income families who reside in participating public school attendance areas. An LEA must determine the proportional share available for services for eligible private school children based on the total amount of Title I funds received prior to any expenditures or transfers of funds within the program, such as reservations for administration, parental involvement, and district wide activities (20 USC 6320(a)(4)(A)). LEAs determine the proportional share by multiplying the proportion of children from low income families who attend private schools and live in participating Title I attendance areas by the LEA’s total Title I allocation (including any funds transferred into Title I). For more information, see Title I, Part A of the ESEA: Providing Equitable Services to Eligible Private School Children, Teachers, and Families (October 7, 2019) (https://oese.ed.gov/files/2020/07/equitable services guidance100419.pdf). The control of funds used to provide equitable services to eligible private school students, teachers and other educational personnel, and families, and title to materials, equipment, and property purchased with those funds must be in a public agency and the public agency must administer the funds, materials, equipment, and property. The provision of equitable services must be by employees of a public agency or through a contract by the public agency with an individual, association, agency, or organization that is independent of the private school. The contract must be under the control of the public agency (Sections 1117(d), and 8501(d) of ESEA (20 USC 6320(d), and 7881(d); section 18005(b) of the CARES Act; 34 CFR sections 76.661, 200.64(b)(3), 200.67, and 299.9). Additionally, 2 CFR 200.303 indicates that non Federal entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition As part of the City of Boston Public School’s (BPS) policy over compliance with private school funding, private school officials are required to fill out the Boston Public Schools: Non Public Grant Assurance and Participation Form attesting BPS provided timely and meaningful consultation with the school officials in making its determination. However, during our testing of 10 private schools in which BPS provides funding to eligible private school children, BPS was unable to locate the submitted form for one school. Additionally, for the 9 private schools where the form was provided, the authorized private school official certified that BPS did not provide timely and meaningful consultation before having made any decision that affected the participation of eligible private school children. Additionally, we were able to verify that the amount of funds available for equitable services for BPS was determined by multiplying the proportion of private school children from low income families residing in participating public school attendance areas by the LEA’s total Title I, Part A allocation. We noted the data on children from low income families who reside in the participating Title I public school attendance area and attend the private school is provided by the private school officials, which is then inputted and calculated by BPS on their Title I application. However, we were unable to confirm completeness and accuracy of the eligible private school children counts used in the calculation as BPS did not retain the correspondence from the schools to support the data ultimately included in their calculation. Cause This appears to be due to an insufficient system in place to ensure consultations are performed timely and all supporting documentation related to compliance with providing equitable services for eligible private school children. Effect BPS is not conducting timely consultations with private school officials in making its determination for private school funding and as such, private school programs are getting delayed. BPS is potentially using inaccurate or incomplete data when calculating the amount of funds available for equitable services for eligible private school children. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation BPS management should enhance their policy to include tracking of when consultations with private school officials are held to ensure timely and meaning consultation. Additionally, when utilizing data provided by private school officials to determine the eligible private school child count, we recommend BPS retain copies of their correspondence to ensure completeness and accuracy of the calculation. View of Responsible Officials from the Auditee BPS has implemented a revised consultation process for the FY24 FY25 cycle to ensure that the consultation process happens with fidelity and that records are properly stored.

Categories

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Material Weakness Equipment & Real Property Management Internal Control / Segregation of Duties

Other Findings in this Audit

  • 496626 2023-003
    Material Weakness
  • 496627 2023-004
    Significant Deficiency
  • 496628 2023-004
    Significant Deficiency
  • 496629 2023-005
    Material Weakness
  • 496630 2023-006
    Material Weakness Repeat
  • 496631 2023-007
    Material Weakness Repeat
  • 496632 2023-008
    Material Weakness
  • 496633 2023-009
    Material Weakness Repeat
  • 496634 2023-010
    Material Weakness
  • 496635 2023-011
    Material Weakness
  • 496636 2023-012
    Significant Deficiency
  • 496637 2023-011
    Material Weakness
  • 496638 2023-012
    Significant Deficiency
  • 496639 2023-013
    Significant Deficiency
  • 496640 2023-014
    Material Weakness
  • 496641 2023-015
    Material Weakness
  • 496642 2023-016
    Material Weakness
  • 1073068 2023-003
    Material Weakness
  • 1073069 2023-004
    Significant Deficiency
  • 1073070 2023-004
    Significant Deficiency
  • 1073071 2023-005
    Material Weakness
  • 1073072 2023-006
    Material Weakness Repeat
  • 1073073 2023-007
    Material Weakness Repeat
  • 1073075 2023-009
    Material Weakness Repeat
  • 1073076 2023-010
    Material Weakness
  • 1073077 2023-011
    Material Weakness
  • 1073078 2023-012
    Significant Deficiency
  • 1073079 2023-011
    Material Weakness
  • 1073080 2023-012
    Significant Deficiency
  • 1073081 2023-013
    Significant Deficiency
  • 1073082 2023-014
    Material Weakness
  • 1073083 2023-015
    Material Weakness
  • 1073084 2023-016
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $155.28M
21.027 Coronavirus State and Local Fiscal Recovery Funds $137.12M
84.425 Education Stabilization Fund $95.96M
84.010 Title I Grants to Local Educational Agencies $36.42M
14.267 Continuum of Care Program $33.21M
10.555 National School Lunch Program $30.28M
84.027 Special Education_grants to States $18.48M
97.067 Homeland Security Grant Program $14.25M
21.023 Emergency Rental Assistance Program $13.46M
14.231 Emergency Solutions Grant Program $9.76M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $7.37M
14.218 Community Development Block Grants/entitlement Grants $2.92M
84.367 Improving Teacher Quality State Grants $2.66M
66.443 Reducing Lead in Drinking Water (sdwa 1459b) $2.33M
84.365 English Language Acquisition State Grants $1.97M
84.048 Career and Technical Education -- Basic Grants to States $1.89M
14.248 Community Development Block Grants_section 108 Loan Guarantees $1.81M
10.558 Child and Adult Care Food Program $1.72M
10.582 Fresh Fruit and Vegetable Program $1.42M
84.424 Student Support and Academic Enrichment Program $1.21M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $1.17M
84.173 Special Education_preschool Grants $984,808
84.287 Twenty-First Century Community Learning Centers $975,544
14.905 Lead Hazard Reduction Demonstration Grant Program $932,129
10.559 Summer Food Service Program for Children $847,800
93.053 Nutrition Services Incentive Program $819,095
84.002 Adult Education - Basic Grants to States $637,747
97.106 Securing the Cities Program $633,137
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $529,609
16.833 National Sexual Assault Kit Initiative $419,758
16.034 Coronavirus Emergency Supplemental Funding Program $361,892
16.741 Dna Backlog Reduction Program $304,935
97.111 Regional Catastrophic Preparedness Grant Program (rcpgp) $296,943
94.016 Senior Companion Program $282,802
97.044 Assistance to Firefighters Grant $275,718
16.738 Edward Byrne Memorial Justice Assistance Grant Program $220,692
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $216,589
14.241 Housing Opportunities for Persons with Aids $146,150
94.002 Retired and Senior Volunteer Program $128,436
97.056 Port Security Grant Program $114,220
10.579 Child Nutrition Discretionary Grants Limited Availability $112,182
16.588 Violence Against Women Formula Grants $106,201
84.196 Education for Homeless Children and Youth $101,856
97.024 Emergency Food and Shelter National Board Program $93,705
45.024 Promotion of the Arts_grants to Organizations and Individuals $75,000
16.820 Postconviction Testing of Dna Evidence to Exonerate the Innocent $70,275
10.935 Urban Agriculture and Innovative Production $68,330
16.751 Edward Byrne Memorial Competitive Grant Program $62,566
93.052 National Family Caregiver Support, Title Iii, Part E $54,824
47.076 Education and Human Resources $48,623
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $47,562
14.401 Fair Housing Assistance Program_state and Local $43,110
97.042 Emergency Management Performance Grants $42,546
10.331 Food Insecurity Nutrition Incentive Grants Program $40,575
16.838 Comprehensive Opioid Abuse Site-Based Program $38,947
14.889 Choice Neighborhoods Implementation Grants $38,598
14.261 Homeless Management Information Systems Technical Assistance $38,248
84.305 Education Research, Development and Dissemination $32,566
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $25,988
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $19,965
14.246 Community Development Block Grants/brownfields Economic Development Initiative $13,770
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $12,444
93.566 Refugee and Entrant Assistance_state Administered Programs $9,500
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $7,450
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $6,810
20.205 Highway Planning and Construction $6,244
84.411 Investing in Innovation (i3) Fund $1,192
16.710 Public Safety Partnership and Community Policing Grants $1,068
20.600 State and Community Highway Safety $283
16.817 Byrne Criminal Justice Innovation Program $-17
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $-385,211