Corrective Action Plan and Views of Responsible Officials
Views of Responsible Officials
The District acknowledges the audit finding regarding insufficient retention of financial records
supporting the annual ESSER expenditure reports submitted to the California Department of
Education. We understand that maintaining accurate and accessible documentation is essential
to federal compliance under Title 2, Code of Federal Regulations (CFR) §200.334. The District
takes full responsibility for this oversight and is taking immediate steps to strengthen its internal
controls and documentation practices.
Corrective Action Plan
1. Reason for the Finding:
This issue arose due to high turnover in the position responsible for federal reporting. As a
result, institutional knowledge and documentation practices were disrupted, making it difficult
to locate supporting financial records for the annual ESSER expenditure report. While the
quarterly reports submitted throughout the year were accurate and properly supported, the
annual report was not fully aligned with available documentation due to incomplete record
retention during the staffing transitions.
2. Actions to be Taken to Correct the Issue:
Centralized Document Management System:
The District will implement a centralized, secure electronic document management
system (e.g., Google Drive, SharePoint, or a financial records database) specifically for
tracking and retaining federal program documentation. All financial records supporting
ESSER and similar federal grants will be stored here and categorized by funding source,
fiscal year, and reporting period.
Standard Operating Procedure (SOP):
A formal SOP for federal grants management will be created and distributed to all
relevant departments. This will include clear guidelines for documentation, record
retention timelines, and roles/responsibilities for financial reconciliation and audit
readiness.
Staff Training:
District staff responsible for federal program management and reporting will be trained
on the new SOP, federal compliance regulations (including CFR §200.334), and the use
of the document management system. Refresher trainings will be conducted annually or
as needed.
Pre-Submission Review:
A dual review process will be instituted where both the Business Services and Federal
Programs teams confirm the availability and accuracy of supporting documentation
before any reports are submitted to oversight agencies.
3. Timeline for Implementation:
All corrective actions will be in place within 90 days. The centralized document storage system
and SOPs will be finalized and rolled out within 60 days. Staff training will be completed within
the following 30 days. Immediate measures to retain ESSER documentation have already been
initiated.