The District overcharged indirect costs and fringe benefits to the Education Stabilization Fund program. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Education Pass-through Award/Contract Number: COVID-19, 84.425U-0712284 COVID-19, 84.425D-0120430 COVID-19, 84.425U-0137112 COVID-19, 84.425U-0138201 COVID-19, 84.425W-0459590 COVID-19, 84.425U-0140040 Known Questioned Cost Amount: $106,654 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for, and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent $6,028,068 of its ESF awards. This included $3,168,931 in the Elementary and Secondary School Emergency Relief Fund (ESSER I and II) subprogram (84.425D), $2,856,437 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U), and $2,700 in the American Rescue Plan Elementary and Secondary School Emergency Relief ? Homeless Children and Youth (ARP ESSER ? HCY I and II) subprogram (84.425W). Federal regulations establish principles and standards for determining allowable direct and indirect costs for federal awards. The Office of Superintendent of Public Instruction (OSPI) establishes the indirect cost rate for each award, and districts cannot exceed this approved rate when claiming reimbursement. If there are changes to the rate during a multi-year award, districts must adjust the amount claimed, if needed, to ensure they do not exceed the approved rate. During the audit period, the District entered into a memorandum of understanding with the paraeducators? union. Under the memorandum, every bargaining unit member was provided two additional discretionary days, which members could cash out if unused, in recognition of the substantial additional workload during the COVID-19 pandemic. The District is responsible for ensuring it equitably allocates fringe benefits to all related activities, including federal awards. Description of Condition The District?s internal controls were adequate for ensuring it materially complied with the program?s allowable activities and allowable costs requirements. However, we found the District: ? Charged the incorrect indirect cost rate for its ESSER II award (84.425D) ? Did not equitably allocate fringe benefits to all related activities for paraeducators charged to the program This issue was not reported as a finding in the prior audit. Cause of Condition Management and staff did not know the District needed to manually adjust its OSPI-issued unrestricted indirect cost rate for ESSER awards that covered two fiscal years. Instead, the District relied on the rate posted in the iGrants system. Additionally, management did not know that the District needed to allocate discretionary day cash outs equitably based on employees? normal distribution of time charges. Effect of Condition and Questioned Costs The District charged: ? $65,279 more in indirect costs than allowable because it did not charge the correct indirect cost rate for its ESSER II program ? $41,375 of payroll and associated benefits for paraeducator discretionary day cash outs that were not allocated equitably based on employees? normal distribution of time charges We are questioning these costs. Federal regulations require the State Auditor?s Office to report known questioned costs that are greater than $25,000 for each type of compliance requirement. We question costs when we find the District has not complied with grant regulations and/or when it does not have adequate documentation to support expenditures. Recommendation We recommend the District: ? Ensure it uses the correct OSPI-issued unrestricted indirect cost rate for the fiscal period when charging costs to the program ? Equitably allocate fringe benefits based on employees? normal distribution of time charges District?s Response We acknowledge the finding and are in the process of implementing procedures to address these recommendations. Auditor?s Remarks We appreciate the steps the District is taking to resolve this issue. We will review the condition during our 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.