Finding Text
Finding: District records did not demonstrate compliance with the Special Education Cluster Maintenance of Effort (MOE) requirement for the 2021-22 fiscal year. Criteria: Title 34, Sections 300.203 and 300.204, Code of Federal Regulations, provide that the amount of State and local funds or the combined State and local funds expended by the District on Special Education-related services during any fiscal year must be at least the same, either in total or per capita, as the amount spent in the most recent fiscal year. Allowances for decreases in the MOE may be made for certain reasons including the departure of Special Education personnel, a decrease in the enrollment of children with disabilities, the termination of costly expenditures for long-term purchases, such as expenditures for the acquisition of equipment and the construction of school facilities, and the termination of District services for particular students who required costly programs and services but are no longer in the District. Condition: We examined District records and determined that the District did not demonstrate compliance with the MOE requirement for the 2021-22 fiscal year. Specifically, the amount of State and local funds spent toward Special Education services, both in aggregate and on a per student basis, decreased in the 2021 22 fiscal year when compared to the 2020-21 fiscal year and, although we requested, District records were not provided to identify qualified allowances that would justify the decrease in the required effort. Cause: The District had not established procedures to adequately monitor and document compliance with the MOE requirement. According to District personnel, the primary methodology for ensuring that the MOE compliance requirement is maintained is through annual staffing allocations. However, Education Stabilization Funds were utilized to pay employees raises and the District inadvertently did not consider the impact this action would have on meeting the MOE requirement. Effect: There was a $925,152 MOE deficiency in State and local expenditures for the 2021-22 fiscal year, resulting in questioned costs of that amount. District personnel agreed with our questioned cost calculations. When State and local funds are not properly allocated and expended for Special Education services, there is an increased risk that the grantor may reduce future Special Education Cluster awards. Recommendation: The District should strengthen controls over State and local resources allocated and expended for the Special Education Cluster to ensure compliance with the Federal MOE requirement. In addition, the District should document to the grantor (FDOE) how the District complied with the Federal MOE requirement or restore $925,152 to the Special Education Cluster programs. District Response: The District Business Services office will perform periodic reviews on expenditures related to the Special Education services, to ensure compliance with the Special Education ? MOE requirement and that State and Local Funds are properly allocated and utilized for Special Education services. The District will review and utilize annual staffing allocations to assist with compliance of the Special Education ? MOE requirement.