Finding 1201504 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396085
Auditor: AUDITOR GENERAL

AI Summary

  • Core Issue: The District under allocated Title I funding by $220,333 to three schools, violating federal regulations on funding distribution based on poverty levels.
  • Impacted Requirements: Title 34, Section 200.78 mandates that funding must be allocated in rank order according to the percentage of low-income students, which was not followed.
  • Recommended Follow-Up: Establish monitoring procedures for Title I allocations and provide documentation to support questioned costs or reallocate funds to underfunded schools.

Finding Text

FINDING - The District under allocated Title I Program funding to three schools by a total of $220,333, resulting in questioned costs of that amount. CRITERIA - Title 34, Section 200.78, Code of Federal Regulations, requires the District to allocate Title I schoolwide program funds to schools, identified as eligible and selected to participate, in rank order based on the total number of children from low-income families in each school. The District is not required to allocate the same per-pupil amount (PPA) to each participating school provided that it allocates higher PPAs to schools with higher concentrations of poverty than to schools with lower concentrations of poverty. CONDITION - The District annually applies for Title I Program funding and the application includes a budget and an eligibility survey to document the amounts budgeted per participating school. During the 2024-25 fiscal year, the District expended $1,967,074 from the Title I Program, including $1,784,371 expended for District schools. As part of our audit, we requested for examination District records supporting the budget allocation amounts to the seven Title I Program schools and final budget amounts evidencing the allocations provided. However, District records indicated that the ranking of three District Title I Program schools did not agree with the ranking based on the percent of students from low-income families. Specifically, three schools had poverty concentrations of 74.9, 72.6, and 68.1 percent but were allocated and received $27,352, $82,630, and $110,351 less funding, respectively, than a school with a lower poverty concentration of 67 percent. CAUSE - The District had not established procedures for monitoring Title I Program budget amounts allocated to participating schools. EFFECT - The District did not comply with Federal regulations by appropriately allocating Title I Program funding, resulting in three schools being underfunded by a total of $220,333 and educational services that were not funded at required levels. RECOMMENDATION - The District should establish monitoring procedures for ensuring and documenting that Title I Program funding is properly allocated to schools. In addition, the District should provide documentation to the FDOE supporting the allowability of the questioned costs totaling $220,333 or allocate that amount to the applicable underfunded Title I Program schools. DISTRICT RESPONSE - Title I rank and serve must be established in both the initial and final budgets and consistently maintained throughout the fiscal year. Any adjustments to school allocations must preserve rank order and per-pupil allocations. During the 2024-2025 fiscal year, an allocation to a lower-ranked school resulted in PSES not being fully maintained. While the District has historically monitored Title I budgets, this finding identified a need to strengthen internal controls to ensure continued alignment with Federal requirements. In response, the District will implement monthly monitoring of Title I school budgets to verify that rank and serve requirements and PSES calculations are maintained throughout the year. Additionally, the District will seek technical assistance from the Florida Department of Education Federal Programs Office to ensure full compliance moving forward.

Corrective Action Plan

The District appreciates the opportunity to respond to the audit finding regarding inconsistencies between Title I rank order and the allocation of funds based on low-income student percentages for the 2024-2025 fiscal year. Our review indicates that the variance in allocations resulted from a budget decision to provide additional Title I funding to Bowling Green Elementary to support after-school programming, without fully accounting for per-pupil allocation. Historically, Bowling Green Elementary has served one of the highest concentrations of students from low-income families in the District, and the additional allocation was intended to ensure continuity of extended learning opportunities for students with significant academic need. While this decision was grounded in student need, the District recognizes that the additional funds were not fully reconciled with updated poverty data and required rank-order calculations. The District has demonstrated compliance with rank and serve requirements in prior years; however, to prevent recurrence, we are strengthening our internal controls. Beginning immediately, the District will implement a structured monthly review of Title I school allocations involving the Title I Program Specialist, the Finance Director, and the Deputy Superintendent to ensure that the 2025-2026 allocations align with current poverty data and PSES calculations. Additionally, the District will seek guidance from the Florida Department of Education Title I Office to confirm that our procedures fully meet all regulatory expectations. The District is confident that these corrective actions will ensure full compliance in 2025-2026 moving forward and will strengthen the integrity of our allocation processes.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
10.555 NATIONAL SCHOOL LUNCH PROGRAM $2.52M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $1.97M
10.553 SCHOOL BREAKFAST PROGRAM $643,755
84.011 MIGRANT EDUCATION STATE GRANT PROGRAM $420,425
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $259,296
84.358 RURAL EDUCATION $159,499
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $134,579
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $116,495
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $111,941
12.U02 AIR FORCE JUNIOR RESERVE OFFICERS TRAINING CORPS $92,110
84.196 EDUCATION FOR HOMELESS CHILDREN AND YOUTH $59,562
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $43,747
10.579 CHILD NUTRITION DISCRETIONARY GRANTS LIMITED AVAILABILITY $43,663
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $37,805
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $37,632
84.425 EDUCATION STABILIZATION FUND $2,500
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $1,028
84.027 SPECIAL EDUCATION GRANTS TO STATES $246