Finding Text
SCHEDULE OF FEDERAL AWARD FINDINGS AND
QUESTIONED COSTS
West Valley School District No. 363
September 1, 2023 through August 31, 2024
2024-001 The District did not have adequate internal controls for ensuring compliance with federal Title I assessment system security requirements.
Assistance Listing Number and Title: 84.010 Title I Grants to Local
Educational Agencies
Federal Grantor Name: U.S. Department of Education
Federal Award/Contract Number: N/A
Pass-through Entity Name: Office of Superintendent of Public
Instruction
Pass-through Award/Contract Number:
S010A220047
Known Questioned Cost Amount: $0
Prior Year Audit Finding: N/A
Background
The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and live in areas with high concentrations of children from low-income families. During the 2023-2024 school year, the District spent $781,266 in Title I program funds.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls.
States, in consultation with school districts, must establish and maintain an assessment system that is valid, reliable and consistent with relevant professional and technical standards. States must have formal, well-documented policies and procedures to maintain test security and ensure districts implement them for all standardized tests. The Office of Superintendent of Public Instruction (OSPI) provides templates for all districts to document their Test Security and Building Plans for each assessment they administer. OSPI also provides detailed guidance and manuals on test security.
Description of Condition
The District did not have adequate controls for ensuring it complied with assessment system security requirements. Specifically, the District did not have a required written Test Security and Building Plan in place for one of the 11 schools we reviewed that administered the World-Class Instructional Design and Assessment standardized test, as OSPI requires.
We consider this internal control deficiency to be a significant deficiency.
Cause of Condition
District staff are aware of the requirement to have written Test Security Building Plans for each assessment but overlooked preparing one for the assessment performed at the Millwood Kindergarten Center. This was due to a staffing transition in the District’s assessment position and that staff thought a plan was not required since District-level multilingual learner specialists administered tests at this building rather than building staff.
Effect of Condition
Without a documented Test Security and Building Plan, the District cannot demonstrate it implemented and complied with OSPI’s assessment system security requirements for the standardized test it administered at the Millwood Kindergarten Center in the 2023-2024 school year.
Recommendation
We recommend the District improve its internal controls and follow its established policies and procedures to comply with OSPI’s assessment system security requirements. Specifically, the District should establish written Test Security and Building Plans for all standardized tests it will administer.
District’s Response
The district acknowledges that a Test Security Building Plan (TSBP) was not on file for our Kindergarten Center during the 2023–24 school year. While all required testing assurances were submitted and staff received appropriate test security training, we recognize that the omission of a formal TSBP represents a lapse in documentation and controls.
This oversight occurred during a period of staffing transition in the district’s assessment position, which contributed to the gap in plan submission for the Kindergarten Center. We appreciate the auditor's recommendation and have taken corrective action to address this issue.
For the 2024–25 school year, we have verified that TSBPs are on file for all buildings where standardized assessments will be administered, including the Kindergarten Center.
Looking ahead to the 2025–26 school year, our Kindergarten Center will no longer administer standardized assessments, as kindergarten students will transition back to their neighborhood elementary schools. This organizational change will further streamline compliance with OSPI’s assessment system security requirements.
We remain committed to maintaining strong internal controls and full compliance with all assessment security protocols.
Auditor’s Remarks
We appreciate the District’s commitment to resolving this finding and thank the District for its cooperation and assistance during the audit. We will review the status of the District’s corrective action during the next audit.
Applicable Laws and Regulations
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.
Title 20 U.S. Code section 6311(b)(2)(B)(iii) requires state and local education agencies to establish and maintain valid and reliable assessment systems, consistent with relevant professional and technical standards.