2025-001 The District did not have adequate internal controls and did not comply with federal eligibility requirements. Assistance Listing Number and Title: 12.558, Department of Defense Impact Aid (Supplement, CWSD, BRAC) Federal Grantor Name: U.S. Department of Defense Federal Award/Contract Number: N/A Pass-through Entity Name: N/A Pass-through Award/Contract Number: N/A Known Questioned Cost Amount: $277,368 Prior Year Audit Finding: N/A Background The purpose of the Department of Defense Impact Aid (Supplement, CWSD, BRAC) program is to supplement the U.S. Department of Education Impact Aid program, by providing additional funding to military connected children. Within this program is a subprogram to provide additional funding to military connected children with severe disabilities (CWSD). CWSD funding is provided to reimburse school districts for money previously spent on military connected children with severe disabilities. Only children of active duty military personnel are eligible for program funds. Further, children must also have a severe disability to be eligible for CWSD program funds. The District received $1,196,574 under the Department of Defense Impact Aid program, of which $961,187 was CWSD program funds. Federal regulations require recipients to establish, document and maintain effective internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Description of Condition Our audit found the District’s internal controls were ineffective for ensuring compliance with federal eligibility requirements. Specifically, the District included ineligible students in its application for CWSD funds. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition The District experienced turnover in positions responsible for completing and reviewing the District’s CWSD application during 2024. Staff were not aware of all requirements and did not follow the District’s established practice to obtain a secondary review of the application before submission. Effect of Condition and Questioned Costs The District included 22 students in its application for CWSD funding and although the District requested reimbursement for $1,016,178, the grantor reimbursed the District $961,187. Using a nonstatistical sample, we selected seven students for testing. We found six students whose costs were claimed for reimbursement in the application totaling $293,236 but were not eligible for program funds as they were not dependents of active-duty military personnel. To determine questioned costs we assumed funding was provided in the same proportion as the District requested. Known questioned costs for the six students tested totaled $277,368. Based on the projection of our sample, we identified an additional $594,359 of estimated overpayments for funding provided to ineligible students. Federal regulations require the State Auditor’s Office to report known and likely questioned costs that are more than $25,000 for each type of compliance requirement. We question costs when we find the District received funding for ineligible students. Recommendation We recommend the District strengthen and follow internal controls to ensure it complies with federal eligibility requirements. District’s Response The South Kitsap School District acknowledges the audit finding and agrees with the recommendation to strengthen and follow internal controls to ensure compliance with federal eligibility requirements for the Department of Defense Impact Aid CWSD program. The District has a legitimate population of active-duty military-connected students and incurs significant costs in providing services to students with disabilities. The District believes the issue identified was an administrative and internal control error in the application process, rather than an absence of eligible military-connected students or related service costs. However, the District recognizes that the specific students included on the application were not adequately reviewed against eligibility documentation prior to submission. The District cannot determine with certainty why ineligible students were included on the application. The application was completed by a former Special Services administrator who is no longer employed by the District. During the period under audit, the District also experienced turnover in positions involved in completing and reviewing the application, which contributed to the District’s established review process not being followed. The District takes this finding seriously and has implemented corrective action to ensure future applications are reviewed for eligibility before submission. Going forward, the Business Services Department will perform a secondary review of CWSD application data prior to submission. This review will include comparing the students included on the CWSD application to the District’s source documentation for military-connected students, including the data maintained from the U.S. Department of Education Impact Aid process. The District will also retain documentation supporting student eligibility, review, and approval of the application. The District will strengthen its written procedures to clearly identify the staff responsible for preparing, reviewing, and approving the application. The procedures will require documented review by both the Special Services Department and the Business Department prior to submission. These additional controls are intended to ensure that only eligible students are included on future applications and that the District maintains adequate documentation to support compliance with program requirements. The District will continue to cooperate with the grantor and the State Auditor’s Office regarding any required follow-up or resolution of questioned costs. 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. U.S. Department of Defense DOW Impact Aid provides guidance for eligibility requirements for students under the CWSD program.