Finding 513089 (2024-003)

Significant Deficiency
Requirement
P
Questioned Costs
-
Year
2024
Accepted
2024-12-05
Audit: 331026
Organization: Rome City School District (NY)

AI Summary

  • Core Issue: Documentation for Title I compliance was not provided on time, despite no non-compliance found.
  • Impacted Requirements: Key documents like the Consolidated Application and Consultation forms were missing, risking compliance monitoring.
  • Recommended Follow-Up: Implement better filing policies for federal award documents to ensure timely access and compliance.

Finding Text

Single Audit Compliance – Title I Documentation U.S. Department of Education AL# 84.010 Title I Grants to Local Education Agencies Condition: Although no non-compliance was found, the above documentation issues were also noted in our testing of compliance over federal funds. The following items were not timely provided for the audit:  Copy of the 2023-24 Consolidated Application.  Copy of completed Consultation and Collaboration forms.  Copy of Written Affirmation of LEA Consultation with Private School Officials forms.  Copy of Title I Parent and Family Engagement Policy.  Documentation of Private School acceptance or denial of services.  Copy of Funded Administrators Position form (if applicable).  School Improvement Grant Applications.  Copies of any SIG performance reports filed during 2023-24. In addition, an internal control questionnaire was provided to be completed and was not returned despite multiple requests. Criteria: Federal award documentation should be organized and well managed to ensure compliance is monitored in a timely manner. Cause: Unknown Effect or potential effect: When documentation is not readily available, there is a risk of non-compliance. Recommendation: We recommend that management institute policies and procedures for the orderly filing of federal award documents to ensure proper record retention and the ability to timely retrieve record as needed. Managements Response: The District has engaged a grant writer to assist with Title I documentation and questionnaires. We successfully provided the necessary documentation to the auditors on October 25, 2024.

Corrective Action Plan

The District utilizes grant writers through union contracts to write and maintain the Title I grant. We successfully provided the necessary documentation to the auditors on October 25, 2024. Step 1: Development of a Federal Fund Documentation Retention Policy - Create a formalized policy for the retention, organization, and timely retrieval of federal fund documentation, including all documents required for audits and compliance reporting. Step 2: Creation of a Centralized Document Management System - Implement a centralized document management system (either physical or electronic) for all federal award-related documentation. This system will include folders or digital records for each grant, with clearly defined categories for required forms, reports, and applications. Step 3: Implementation for Document Submission and Tracking - Establish a clear timeline for submitting required documentation, including deadlines for each document related to federal funds (e.g., Consolidated Application, Consultation forms, SIG performance reports, etc.). Develop a tracking system to ensure timely submission and to monitor progress. Step 4: Assigning Responsibility for Documentation Compliance - Assign specific responsibility for ensuring the completion, collection, and timely submission of all federal fund documentation to designated staff members. This will include assigning oversight for the internal control questionnaire and ensuring that it is completed and submitted on time. Step 5: Timely Completion and Return of Internal Control Questionnaires - Establish a process for ensuring that all required internal control questionnaires are completed and returned within the required timeline. This may include setting up automatic reminders and follow-up procedures to ensure compliance. Step 6: Training for Staff on Federal Fund Documentation - Provide training for all relevant staff (including grant writers and Business Office personnel) on federal fund documentation requirements, including deadlines and the importance of timely submission. Emphasize the role of proper documentation in ensuring compliance with federal funding regulations. Step 7: Quarterly Review of Federal Fund Documentation - Implement a quarterly review process to assess the completeness and compliance of federal fund documentation. This review will include a check of all required reports, applications, and forms, ensuring that they are filed correctly and on time. Timeline: ○ December 1, 2024: Assign specific responsibilities for federal fund documentation compliance. ○ December 15, 2024: Develop and implement a federal fund documentation retention policy and process for completing internal control questionnaires. ○ January 15, 2025: Implement centralized document management system and complete staff training on documentation requirements. ○ January 31, 2025: Implement the timeline and tracking system for document submission. ○ March 2025: Conduct the first quarterly review of federal fund documentation. ○ June 30, 2025: BOE policy creation or update for Federal Fund Documentation Retention ● Responsible Parties: ○ Dr. Georgia Gonzalez, Director of Business & Finance responsible for oversight of documentation management, responsibility of assignment, and policy implementation ○ Dana Benzo and Jennifer DePerno, Title I Grant Writer responsible for ensuring that all required documents (e.g., Consolidated Application, Consultation forms) are prepared and submitted on time. ● Expected Outcome: By implementing these actions, the District expects to significantly improve the organization, retention, and timely retrieval of federal fund documentation. A well-structured document management system and clear submission timelines will reduce the risk of non-compliance and ensure that the District is prepared for future audits. With regular training and monitoring, the District will strengthen its internal controls over federal funds, providing better oversight, compliance, and accountability.

Categories

Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1089531 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $2.34M
10.553 School Breakfast Program $679,566
10.559 Summer Food Service Program for Children $127,002
84.010 Title I Grants to Local Educational Agencies $92,734
84.424 Student Support and Academic Enrichment Program $66,222
84.196 Education for Homeless Children and Youth $65,826
84.173 Special Education Preschool Grants $64,930
84.027 Special Education Grants to States $58,822
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $13,329
84.365 English Language Acquisition State Grants $718
84.425 Education Stabilization Fund $117