EIN: 020494977
UEI: ENKJC5SK6826
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 25, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 25, 2026 (36 days from today).
What is a management decision? →2025-003 Lack of Written Methodology for Title I Funds (Material Weakness) Federal Agency: U.S. 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: 20241052, 20240071 & 20250400 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), school 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, and not supplant, the funds that would otherwise be made available from state and local resources. To satisfy this requirement, a school district must develop and maintain a written methodology describing how state and local funds are allocated to schools. The methodology must ensure that Title I schools receive their allocation of state and local funds without regard to the receipt of Title I funds and that the allocation process is applied consistently across all schools. In addition, the New Hampshire Department of Education provides a Supplement, Not Supplant form that districts may utilize to document their methodology for allocating state and local funds to schools and to demonstrate compliance with this requirement. Condition: During the audit, it was noted that the School District has developed a Supplement, Not Supplant procedure document intended to address the Title I requirement. However, the document does not fully meet the criteria of a written methodology as required under ESSA. Specifically, the document does not clearly describe the process or formula used to allocate state and local funds to individual schools, nor does it demonstrate that such allocations are made without consideration of Title I status. As a result, the School District does not currently have a documented methodology that clearly establishes how state and local resources are distributed among schools in a manner that supports compliance with the Supplement, Not Supplant requirement. Additionally, the School District has not completed or maintained documentation utilizing the Supplement, Not Supplant form provided by the New Hampshire Department of Education or a comparable tool to document its allocation methodology. Cause: Although the School District has taken steps to address the Supplement, Not Supplant requirement by developing a procedure document, it has not yet established a comprehensive written methodology that formalizes the process for allocating state and local funds to schools. This appears to be the result of incomplete implementation of the federal requirement and limited documentation of the School District’s budgeting and allocation practices at the school level. Effect: Without a documented methodology that clearly outlines how state and local funds are allocated to schools, the School District cannot demonstrate that Title I schools receive their state and local funding without regard to Title I status. This increases the risk that Title I funds could inadvertently be used to supplant state or local funds and may result in noncompliance with federal program requirements. Questioned Costs: Since the School District does not have a written methodology, questioned costs could not be determined. Identification as Repeat Finding: As identified in Schedule III, Summary Schedule of Prior Audit Findings, this is a repeat of finding 2024-001. Recommendation: We recommend that the School District develop and implement a comprehensive written methodology that clearly describes how state and local funds are allocated to individual schools. The methodology should demonstrate that allocations are determined without regard to Title I status and should include sufficient detail to allow an independent reviewer to understand and replicate the allocation process. While the School District has developed a Supplement, Not Supplant procedure document, it should be expanded or revised to include a clear and documented allocation methodology that meets ESSA requirements. The School District may also utilize the Supplement, Not Supplant form provided by the New Hampshire Department of Education, or a comparable format, to formally document its methodology. Additionally, the School District should provide training to key personnel involved in budgeting and federal program administration, establish periodic reviews of school-level allocations to verify compliance with the methodology, 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.
The District has historically managed our Title I grant as supplemental funding and has a methodology for allocating local funds to schools without regard to whether they receive Title I funds. During fiscal year 2025, the district developed procedures to document our process, however the methodology was not included. The District will update the written procedure with the methodology to be in compliance with the Title I Supplement, Not Supplant requirement.
2024-001
2025-004 Verification of Suspension and Debarment (Material Weakness) Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: N/A Cluster/Program: Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing Number: 93.243 Passed-through Identification: N/A Compliance Requirement: Procurement/Suspension/Debarment Type of Finding: Internal Control over Compliance – Material Weakness Criteria or Specific Requirement: In accordance with 2 CFR 180.300, recipients of federal funds are required to ensure that contractors, subcontractors, or vendors are not suspended or debarred from participating in federal programs before awarding any contract or procurement that exceeds $25,000. This verification must be conducted through the System for Award Management (SAM) or through one of the other permitted methods, including obtaining a certification from the vendor or including a clause in the contract whereby the vendor certifies that it is not suspended or debarred. Condition: During our review of the School District’s procurement process related to federally funded expenditures, we noted that the School District awarded contracts to three vendors that were identified as sole source providers without verifying whether the vendors were suspended or debarred prior to contract execution. No evidence was provided demonstrating that the School District performed a search of the System for Award Management (SAM), obtained a certification from the vendors, or included a contract clause addressing suspension and debarment status as required under 2 CFR 180.300. While the School District utilizes a standard non-exclusion certification form when conducting competitive bid processes, this control is not applied when vendors are selected through non-competitive procurement methods, such as sole source procurements. As a result, the School District does not have a control in place to ensure that suspension and debarment verification is consistently performed for all federally funded procurements exceeding $25,000. This resulted in three instances where the required verification was not performed. Cause: The School District’s procurement procedures do not include clearly defined controls requiring suspension and debarment verification for all federally funded procurements regardless of the procurement method used. Existing procedures incorporate a non-exclusion certification form within the competitive bidding process; however, they do not require equivalent verification when vendors are procured through non-competitive methods, such as sole source procurements. Effect: Failure to verify the suspension or debarment status of vendors prior to contract award increases the risk that federal funds could be awarded to an ineligible entity. If a vendor were determined to be suspended or debarred, the School District could be subject to disallowance of related costs, repayment of federal funds, and potential administrative penalties, which could also negatively impact the School District’s eligibility for future federal funding. Questioned Costs: None identified. The School District subsequently performed a search on SAM.gov and confirmed that all three sole source vendors were not suspended or debarred. Identification as Repeat Finding: This is not a repeat finding from the prior year. Recommendation: We recommend that the School District update and strengthen its procurement policies and procedures to require verification of suspension and debarment status for all contractors and vendors receiving federally funded contracts exceeding $25,000, regardless of the procurement method used. Procedures should require documentation of the verification through one of the three methods permitted under 2 CFR 180.300, including: Checking the vendor’s status in SAM, Obtaining a certification from the vendor, or Including a suspension and debarment clause within the contract or procurement agreement. Additionally, the School District should ensure that its existing non-exclusion certification form, or equivalent documentation, is consistently applied to all federally funded procurements, including sole source and other non-competitive procurement methods, to ensure compliance with federal requirements. Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
District Policy Fiscal 130, Federal Funds Policies and Procedures, requires “documentation that debarment/suspension was queried must be retained for each covered transaction as part of the documentation required under DAF-3, paragraph J. This documentation should include the date(s) queried and copy(ies) of the SAM result report/screen shot, or a copy of the or certification from the vendor. It should be attached to the payment backup and retained for future audit review”. The district will strengthen this policy by conducting training for staff. In addition, the district will develop a check list of purchasing requirements for federal funds.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 25, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 25, 2025, which was (329 days ago).
What is a management decision? →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.
Audit Finding Reference: 2024-001 Management’s Response and Planned Corrective Action: The District has historically managed our Title I grant as supplemental funding. Although we have a methodology for allocating local funds to schools without regard to whether they receive Title I funds, we do not have a formal written plan. The District will establish a written procedure to be in compliance with the Title I Supplement, Not Supplant requirement. Name of Contact Person and Completion Date: Karen DeFrancis, Executive Director of Finance Polly Golden, Title I Manager Anticipated Completion Date – March 31, 2025
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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