WINCHESTER SCHOOL DISTRICT, SAU #94

Criteria: Per federal regulation 2 CFR section 200.516(b)(1), the School District is required to develop and maintain procedures regarding equipment acquired with federal funds. Condition: The School District has not developed procedures to implement its policies with regard to the inventory and safeguarding of equipment purchased with federal funds. Cause: The School District has not completed the adoption of the required policies. Effect: The School District is not in compliance with the equipment management requirements. Recommendation: We recommend that the School District adopt and implement procedures in accordance with its policies to maintain property records on federally acquired equipment consistent with the required components identified in 2 CFR section 200.516; the safeguarding of such equipment; and perform an inventory of such equipment no less than once every two years. Management’s Response: Management agrees with this finding. The school policy committee will create/review policy.

Criteria: Per federal regulation 2 CFR section 200.430(i)(1)(vii), the School District must maintain time and effort records for employees who work, all or in part, under federal grants. Condition: The School District did not maintain complete time and effort documentation. Cause: The semi-annual certifications provided by an employee were not signed by the employee. Also, time and effort documentation on stipends paid by the grant to employees for summer activity did not include information on the grant funding the activity. Two forms authorizing the stipends did not indicate the dates the work was performed; and of the 32 timesheets prepared by the recipients of the stipends, 29 did not cite the grant that was funding the activity. Effect: The School District was not in compliance with the allowable costs and cost principles requirement. Recommendation: We recommend that all required timesheets and other time and effort documentation include the required grant information; clearly identify the time worked on federal grants; include certifying statements that the information is true; and signatures by both employees and supervisor. Management’s Response: Management agrees with this finding. The Business Administrator will review all the prepared contracts to ensure all grant information is provided.

Criteria: ESSER grantees must submit an annual performance report to the State of New Hampshire with data on expenditures, planned expenditures, and use of funds. Condition: The School District could not demonstrate that an annual report was submitted to the New Hampshire Department of Education with the required information. A review of the NHDOE website indicated that the last report was submitted on January 11, 2023. Cause: The School District was unaware that this information had not been submitted. Effect: The School District is not in compliance with federal and state reporting requirements. Recommendation: We recommend that the School District maintain documentation to support that the annual performance report has been submitted as required. Management’s Response: Management agrees with this finding, and will comply with the report filing requirements.

Criteria: Per federal regulation 2 CFR section 200.516(b)(1), the School District is required to develop and maintain procedures regarding equipment acquired with federal funds. Condition: The School District has not adopted written procedures regarding the inventory and safeguarding of equipment purchased with federal funds. Cause: The School District was unaware of the detailed procedures required with respect to the accountability of federally funded equipment. Effect: The School District is not in compliance with the equipment requirements. Recommendation: We recommend that the School District adopt procedures to maintain property records on federally acquired equipment consistent with the required components identified in 2 CFR section 200.516; the safeguarding of such equipment; and perform an inventory of such equipment no less than once every two years. Management’s Response: Management agrees with this finding. Status: The School District has implemented policies and procedures regarding equipment acquired with federal funds, but has not prepared an existing inventory of equipment acquired with federal funds from past years. There were no purchases that would be applicable that were made during the fiscal year ended June 30, 2023.

Criteria: Per federal regulation 2 CFR section 200.430(i)(1)(vii), the School District must maintain time and effort records for employees who work, all or in part, under federal grants. Condition: The semi-annual certification provided by an employee was not complete and was signed prior to the end of the period worked, as listed on the document. Cause: The School District was not aware of the required detail. Effect: The School District was not in compliance with all of the components of the requirements. Recommendation: We recommend that the School District ensure that all required timesheets include the related employee data and clearly identify the time segregated between federal and non-federal funding. Certification statements should be properly signed and dated and accurately reflect the time period worked. Management?s Response: Management agrees with this finding.

Criteria: Per federal regulation 2 CFR section 200.516(b)(1), the School District is required to develop and maintain procedures regarding equipment acquired with federal funds. Condition: The School District has not adopted written procedures regarding the inventory and safeguarding of equipment purchased with federal funds. Cause: The School District was unaware of the detailed procedures required with respect to the accountability of federally funded equipment. Effect: The School District is not in compliance with the equipment requirements. Recommendation: We recommend that the School District adopt procedures to maintain property records on federally acquired equipment consistent with the required components identified in 2 CFR section 200.516; the safeguarding of such equipment; and perform an inventory of such equipment no less than once every two years. Management?s Response: Management agrees with this finding.

Criteria: The Uniform Guidance under 2 CFR Section 200, Subpart E, states that charges to federal grants must be based on actual costs. Condition: The School District reported Title I grant expenditures in excess of actual costs. Cause: The School District reported expenditures based on an estimate (purchase order) rather than on documentation supporting the actual cost (invoice). Questioned Cost: $1,077, which is the difference between the actual expenditure and the amount claimed for reimbursement. Context: We tested twelve (12) transactions out of seventy-one (71), totaling $72,942, and we tested 100% of the payroll transactions totaling $261,541. Total expenditures tested were $334,483 representing 89.7% of the total CFDA 84:010 Title I grant expenditures of $372,612. Effect: The School District is not in compliance with the allowable costs and cost principles requirement. Moreover, the School District received reimbursement on the overexpenditure which is now due back to the State. Recommendation: The School District should report expenditures based on an invoice or other similar documentation, rather than on purchase orders. Management?s Response: We agree with this finding and accept the Auditor?s recommendation. We are reconciling the grant submissions on a monthly, quarterly, and annual basis.

Criteria: The Uniform Guidance under 2 CFR Section 200.512 requires the submission of the data collection form and reporting package to the Federal Audit Clearinghouse by the earlier of thirty calendar days after receipt of the auditor?s report, or nine months after the end of the audit period. Condition: The Clearinghouse submission was not done within the prescribed timeframe. Cause: The School District did not reconcile its grant financial records for the fiscal year ended June 30, 2018 in a timely enough fashion to meet the deadline. Effect: The School District is not in compliance with the reporting requirements. Recommendation: We recommend that financial information be reconciled timely at the end of each year, to expedite the completion of the audit and subsequent submission to the Clearinghouse. Management?s Response: We agree with the finding. We are working in conjunction with our Auditors to schedule and have our reporting done in a timely manner.

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