Finding Text
The District’s internal controls were inadequate for ensuring compliance with priority of service federal requirements.
Assistance Listing Number and Title: 84.011 Migrant Education State Grant Program
Federal Grantor Name: U.S. Department of Education Office of Elementary and Secondary Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public Instruction
Pass-through Award/Contract Number: GT-00241
Known Questioned Cost Amount: $0
Prior Year Audit Finding: N/A
Background
The objective of the Migrant Education State Grant Program is to support high-quality and comprehensive educational programs for migratory children to help reduce education disruptions and ensure that migratory children receive full and appropriate opportunities to meet the same state student academic content and achievement standards that all students are expected to meet. In fiscal year 2023, the District spent $1,265,311 in federal funding through the Migrant Education State Grant Program.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding the program requirements and monitoring the effectiveness of established controls.
Federal regulations require the District to define, properly identify and count, “priority for services” migratory children so that priority in the provision of Migrant Education Program (MEP) services is given to those migratory children who made a qualifying move within the previous one-year period; and who are failing, or most at risk of failing, to meet the state’s academic standards, or who have dropped out of school (priority children).
Description of Condition
Our audit found the District’s internal controls were ineffective for ensuring staff offered or provided services for all priority for services students. The District did not have adequate support for three of 28 students sampled to verify that these students were offered or provided services under the federal program.
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 program staff responsible for documenting priority for services information and it did not retain documentation.
Additionally, the District did not have Migrant program staff at all school buildings. When the new staff were hired, they were not aware of the requirements to document services provided to students that were identified as priority for services.
Effect of Condition
Using a statistical sample of students identified as having met the “priority for services” criteria, we found the District did not have supporting documentation showing that the three of 28 students were offered and/or provided services. Without adequate documentation, the District cannot demonstrate it complied with the priority of service requirements
Recommendation
We recommend the District improve its internal controls to ensure compliance with federal priority of services requirements. This should include retaining documentation supporting its compliance with program requirements. We also recommend the District provide training to staff responsible for program requirements.
District’s Response
Wenatchee School District agrees with the Office of the State Auditor’s recommendation.
The District will put controls into place to ensure that all PFS students are receiving services in an adequate and timely manner.
Auditor’s Remarks
We appreciate the District’s commitment to resolve this finding and thank the District for its cooperation and assistance during the audit. We will review the corrective action taken during our next regular audit.
Applicable Laws and Regulations
Title I, Part C, Section 1304(d) of ESEA (20 USC 6394(d)
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.
20 U.S. Code section 6394(d) Priority for Services.