Finding 1175758 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-02-27

AI Summary

  • Core Issue: The District failed to maintain proper documentation for enrollment and low-income counts reported for Title I funding.
  • Impacted Requirements: This affects compliance with eligibility criteria under Title I of the ESEA, specifically the accurate allocation of funds based on poverty measures.
  • Recommended Follow-Up: The District should ensure all necessary documentation is retained to support enrollment and low-income counts for future eligibility assessments.

Finding Text

Repeat Finding: No Program Name/Assistance Listing Title: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.010 Federal Agency: U.S. Department of Education Federal Award Number: S010A240003 Pass‐Through Agency: Arizona Department of Education Questioned Costs: N/A Type of Finding: Significant Deficiency Compliance Requirement: Eligibility Criteria According to Title I, §1113(a)‐(c) of the ESEA (20 USC 6313(c)), a local educational agency shall allocate funds to eligible schools in rank order and to determine allocations using the same measure of poverty, which measure shall be the number of children ages five through 17 in poverty counted in the most recent census data approved by the Secretary, the number of children eligible for free and reduced priced lunches under the Richard B. Russell National School Lunch Act, the number of children in families receiving assistance under the state program funded under part A of Title IV of the Social Security Act, or the number of children eligible to receive medical assistance under the Medicaid program, or a composite of such indicators, with respect to all school attendance areas in the local educational agency. Condition The District was not readily able to provide support for the enrollment and low‐income counts reported on the Title I School Eligibility worksheet submitted to the Arizona Department of Education. Cause The District did not maintain proper support for the enrollment and low‐income counts. Effect The District was determined to be in compliance with the eligibility of school attendance provisions of Title I, Part A. Context The District did not maintain proper support for the enrollment and low‐income counts. The District attempted to recalculate the enrollment and low‐income counts but were unable to match the figures originally reported. Upon using the recalculated figures on the Title I School Eligibility worksheet, it was determined that the District's school site selection and allocation was still accurate as originally completed. The updated figures provided were agreed back to supporting documentation. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should retain all documentation to support enrollment and low‐income student counts for eligibility purposes. Views of Responsible Officials See Corrective Action Plan.

Corrective Action Plan

While the District maintained the requisite supporting documentation, limitations arising from the internal record retention policies in place at the time, coupled with the retirement of key personnel, resulted in certain enrollment records not being readily locatable. The District acknowledges that these factors limited the availability of prior-year supporting data. This issue has since been addressed through updated retention practices to ensure that this does not occur going forward. Beginning with the next fiscal year cycle, the District has implemented a documented procedure that specifies the data sources, query parameters, and data pull dates; requires that all supporting extracts and calculations be retained in a centralized, version-controlled folder; and establishes a formal review and approval process to verify that enrollment and low-income counts reconcile to source documentation before submission to ADE. Staff in Federal Programs and Finance have been trained on the new procedure, and an annual internal review has been established to confirm compliance. The Director of Finance and the Director of Federal Programs are responsible for implementing and monitoring this corrective action, which will be completed prior to the next Title I eligibility submission.

Categories

School Nutrition Programs Student Financial Aid Allowable Costs / Cost Principles Eligibility Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.555 NATIONAL SCHOOL LUNCH PROGRAM $9.76M
84.027 SPECIAL EDUCATION GRANTS TO STATES $7.51M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $3.92M
10.553 SCHOOL BREAKFAST PROGRAM $1.95M
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $731,395
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $566,788
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $466,778
84.371 COMPREHENSIVE LITERACY DEVELOPMENT $415,708
93.778 MEDICAL ASSISTANCE PROGRAM $280,650
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $273,325
12.357 ROTC LANGUAGE AND CULTURE TRAINING GRANTS $218,923
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $190,211
84.011 MIGRANT EDUCATION STATE GRANT PROGRAM $184,545
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $156,870
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $155,447
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $155,076
84.425 COVID-19 EDUCATION STABILIZATION FUND $40,004
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $17,707
15.130 INDIAN EDUCATION ASSISTANCE TO SCHOOLS $15,541