Finding Text
2024-001 Lack of Written Methodology for Title I Funds (Material Weakness)
Federal Agency: Department of Education
Pass-through Agency: State of New Hampshire Department of Education
Cluster/Program: Title I Grants to Local Educational Agencies
Assistance Listing Number: 84.010
Passed-through Identification: 20230169 & 20240071
Compliance Requirement: Special Tests – Supplement, Not Supplant
Type of Finding:
Internal Control over Compliance – Material Weakness
Material Noncompliance
Criteria or Specific Requirement: Under the Elementary and Secondary Education Act (ESEA), as amended by Every Student Succeeds Act (ESSA), districts are required to demonstrate compliance with the Supplement, Not Supplant provision for Title I funds (Section 1118[b][1]). This provision mandates that federal funds be used to supplement, not supplant, the funds that would otherwise be made available from state and local resources. To meet this requirement, the School District must have a written methodology for allocating state and local funds to its schools to ensure Title I schools receive the same level of support as non-Title I schools, without regard to Title I funding.
Condition: During the audit, it was noted that the School District does not have a written methodology for allocating state and local funds to its schools. Consequently, there is no documented process to ensure that state and local funds are allocated to schools without consideration of their Title I status.
Cause: The School District has not established written policies or procedures to formalize the allocation methodology for state and local funding. This may be due to oversight, or a lack of resources dedicated to compliance monitoring in this area.
Effect: Without a written methodology, the School District cannot demonstrate compliance with the Supplement, Not Supplant requirement. This exposes the School District to the risk that Title I funds may inadvertently be used to supplant state or local funds.
Questioned Costs: $9,661,722.
Identification as Repeat Finding: This is not a repeat finding from the prior year.
Recommendation: We recommend that the School District develop and implement a written methodology for allocating state and local funds to schools to ensure compliance with the Supplement, Not Supplant requirement. This methodology must demonstrate that Title I schools receive the same level of funding as non-Title I schools without consideration of their Title I status. Additionally, the School District should provide training to key staff on the requirement and the methodology, establish periodic reviews of funding allocations to verify compliance, and implement monitoring controls to ensure ongoing adherence to federal regulations.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.