The District did not have adequate internal controls and did not
comply with time-and-effort and private school requirements.
Assistance Listing Number and Title: 84.010 – Title I Grants to Local
Educational Agencies
Federal Agency Name: U.S. Department of Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public
Instruction (OSPI)
Pass-through Award/Contract
Number: N/A
Questioned Cost Amount: $2,932,172
Prior Year Audit Finding: N/A
Background
The objective of the Title I program is to improve the teaching and learning of
children who are at risk of not meeting state academic standards and who live in
areas with high concentrations of children from low-income families. During the
2023-2024 school year, the District spent $2,932,172 in federal funds from the Title
I program.
Federal regulations require recipients to establish and maintain internal controls
that ensure compliance with program requirements. These controls include
understanding program requirements and monitoring the effectiveness of
established controls.
Time and Effort
The District is responsible for ensuring it supports all payroll costs it charges to the
program with adequate time-and-effort documentation, as required by federal
regulations and the awarding agency. Depending on the number and types of
activities employees perform, time-and-effort documentation can be a semiannual
certification or a monthly personnel activity report, such as a detailed timesheet.
Time-and-effort documentation must also be signed and dated after the employee
completes the work.
Private Schools
Federal regulations require districts using Title I funds to consult with private
schools located within their boundaries to provide their eligible students, teachers
and families with equitable services. The District must maintain documentation
supporting that it contacted the private schools.
Description of Condition
Time and Effort
The District’s internal controls were ineffective for ensuring it supported all salaries
and benefits it charged to the program with appropriate time-and-effort
documentation, as federal regulations and the Office of Superintendent of Public
Instruction (OSPI) require.
Private Schools
The District’s internal controls were ineffective for ensuring it consulted with
private schools within its boundaries to identify if students in the schools were
eligible to receive Title I services.
We consider these deficiencies in internal controls to be material weaknesses that
led to material noncompliance.
Cause of Condition
The District experienced turnover in the key position responsible for managing the
program. As a result, the current staff were unable to locate supporting
documentation for time-and-effort or to indicate it contacted the private schools.
Effect of Condition and Questioned Costs
Time and Effort
The District did not obtain time-and-effort documentation for 235 employees
whose payroll and benefits costs totaling $2,932,172 were charged to the program.
Federal regulations require the State Auditor’s Office to report known questioned
costs that are greater than $25,000 for each type of compliance requirement. We
question costs when we find the District does not have adequate documentation to
support expenditures.
Private Schools
The District did not contact three private schools within its boundaries to determine
if there were eligible students that could have received Title I services. During our
audit, the District contacted all three private schools and one of them would have
been interested in participating if its students met eligibility requirements.
Recommendation
Time and Effort
We recommend the District establish and follow internal controls to ensure it
complies with federal and OSPI requirements for obtaining signed time-and-effort
documentation timely.
Private Schools
We recommend the District establish and follow internal controls to ensure it
complies with federal and OSPI requirements for contacting private schools within
its boundaries to determine whether eligible schools would like to participate in
Title I services.
District’s Response
The District concurs with the finding. In response, the District has established a
regularly updated list of private schools within our boundaries. We will be
proactively reaching out to these schools each year to determine interest and
eligibility for Title I services, and are documenting all correspondence. In addition,
we have strengthened time-and-effort documentation procedures as described in
2024-001. Our new internal controls include multi-layered reviews and program
director oversight to ensure timely, complete compliance. The District is committed
to equity in services and transparency in all federal programming.
Auditor’s Remarks
We thank the District for its cooperation and assistance during the audit and
acknowledge its commitment to resolve this finding. We will review the corrective
action taken during our next audit.
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards
(Uniform Guidance), section 516, Audit findings, establishes reporting
requirements for audit findings.
Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes
the requirements for auditees to maintain internal controls over federal programs
and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant
deficiencies and material weaknesses in its Codification of Statements on Auditing
Standards, section 935, Compliance Audits, paragraph 11.
Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes
requirements for determining allowable costs and supporting costs allocated to
federal programs.
Office of Superintendent of Public Instruction Addendum to Bulletin 048-17,
Guidelines for Charging Employee Compensation to Federal Grants establishes
requirements for documenting time-and-effort, including fixed schedule systems.
Title 34 CFR, Part 200, Title I – Improving the Academic Achievement of the
Disadvantaged, Subpart A – Improving Basic Programs Operated by Local
Education Agencies, Section 78 – Allocation of funds to school attendance areas
and schools
Title 34 CFR, Part 200, Title I – Improving the Academic Achievement of the
Disadvantaged, Subpart A – Improving Basic Programs Operated by Local
Education Agencies, Section 64 – Factors for determining equitable participation
of private school children