WESTBURY UNION FREE SCHOOL DISTRICTLocal Government

Reference: 2021-002 Eligibility Criteria - Section 1113(c) of the Elementary and Secondary Education Act of 1065 (ESEA) requires local educational agencies to allocate Title 1 funds to eligible attendance school areas or schools in rank order, on the basis of the total number of children form low-income families in each area or school. Condition - Although the Title I funds allocation by buildings as calculated in the District?s Title I Supplement Application filing with New York State was prepared on the basis of the total number of children from low-income families in each school, the District?s actual expenditures of Title I funds by buildings were not in proportion to the allocation as calculated in their Title I Supplement Application. Cause - The District did not make the required adjustments during the 2020-21 school year to comply with the allocation methodology prescribed in the Title I funding supplement. Effect - The District is not in compliance with Section 1113(c) of ESEA. Repeat Finding - This is a repeat finding of 2019-002 from the year ended June 30, 2019. Recommendation - The District should develop procedures to ensure that Title I funds are allocated by building to each Title I eligible school in accordance with the allocation amounts established in their Title I funding supplement. Reason for Reoccurrence - Change in staff. Planned Corrective Action - The newly appointed Director of K-12 ENL and Funded Programs will coordinate the grant allocation and actual expenditures on a monthly basis with the Assistant Business Administrator for Finance. Person(s) Responsible - Director of K-12 ENL/Assistant Business Administrator for Finance /Assistant Superintendent for Curriculum and Instruction. Anticipated Completion Date - June 30, 2022

Reference: 2021-003 Internal Control Over Compliance Criteria - Non-federal entities other than states, including those operating federal programs of subrecipient states, must follow procurement standards as set by Uniform Guidance. Condition - The District?s current procurement policy does incorporate the Uniform Guidance procurement standards. Additionally, the District did not have a formal conflict of interest policy that also addresses the administration of Federal awards, or written procedures for documenting time and effort for payroll costs charged to Federal awards and cash management procedures to minimize the time elapsed between the receipts and disbursements of Federal Funds to conform to Uniform Guidance requirements. Cause - The District did not make policy updates as required. Effect - The District is not in compliance with Uniform Guidance. Repeat Finding - This is a repeat of finding 2019-003 from the year ended June 30, 2019. Recommendation - The District must review the Uniform Guidance requirements as well as its existing written policies and procedures, and update them where applicable in order to comply with requirements of the Uniform Guidance. Reason for Reoccurrence - The District assigned the incorrect staff person to address the issue. Planned Corrective Action - The Purchasing Agent will review the current policy and incorporate the Uniform Guidance procurement standards. The Director of Funded programs will develop a conflict of interest policy that addresses the administration of Federal awards. The Director of funded programs will develop written procedures for documenting time and effort for payroll costs charged to Federal awards. The Assistant Business Administrator for Finance will develop written cash management procedures to minimize the time elapsed between the receipts and disbursements of Federal Funds to conform to Uniform Guidance requirements. Person(s) Responsible - Assistant Business Administrator for Finance - Purchasing Agent Director of K-12 ENL and Funded Programs. Anticipated Completion Date - June 30, 2022

2019-002. Eligibility Department of Education, Passed-through New York State, Department of Education Title I Grants to Local Educational Agencies CFDA No. 84.010 Condition: The District has designated six schools within the District as Title I-eligible schools. These schools have more than thirty-five percent poverty rate. Five of these six schools operate targeted assistance programs. Although the Title I funds allocation by buildings as calculated in the District?s Title I Supplement Application filing with New York State was prepared on the basis of the total number of children from low-income families in each school, the District?s 2018-19 actual expenditures of Title I funds by buildings were not in proportion to the allocation as calculated in their Title I Supplement Application. Criteria: The District is required to identify eligible Title I school attendance areas and schools, and allocate funds to these schools as prescribed in Title I, Part A, Section 1113 of the Elementary and Secondary Education Act (ESEA), as amended by No Child Left Behind Act, and 34 CFR Part 200 Paragraphs 200.77 and 200.78 of the Title I regulations published in the Federal Register on December 2, 2002. If an LEA serves only areas with a poverty rate greater than 35 percent, the LEA must allocate funds, in rank order, on the basis of the total number of children from low-income families in each school. Cause: The District budgeted the amount of Title I grant expenditures for each school based on their expected needs and internal budget estimates. However, there were inadequate procedures in place and insufficient communication between the Title I grant administrator and the District?s Business Office to ensure that actual expenditures of Title I funds by building were in alignment with the allocation in the Title I Funding Supplement. Effect: Non-compliance with the allocation of Title I Funds could result in loss of funds or having to refund federal monies. Identification of a Repeat Finding: This is a repeat finding from the previous year?s audit, finding reference no. 2018-001. Recommendation: The District must develop procedures to ensure that Title I funds are allocated by building to each Title I eligible school in accordance with the allocation amounts established in its Title I funding supplement. Views of Responsible Officials: The District implemented the following adjustments during the fiscal 2017-18 and the 2018-2019 school years to address the findings of the audits: ? The Office of Instruction, Assessments, & Funded Programs provided each building with their annual allocation and has held meetings with the building principals to discuss the expenditures; ? The Office of Instruction, Assessments, & Funded Programs had improved record keeping to track expenditures by building through a Google sheet; and ? A tiered level of accountability and assurances was implemented with a minimum of four signatures prior to the submission of purchase orders to the business office: (1) teacher, (2) Principal, (3) Director, (4) Assistant Superintendent, and (5) Business office. The Office of Instruction, Assessments, & Funded programs did not have access to expense reports from the Business Office in order to routinely monitor expenses in real-time. Also, the Director of Instruction, Assessments, & Funded Programs was not a part of the FS-10F final expenditure report filing process.

2019-003. Internal Control Over Compliance Department of Education, Passed-through New York State, Department of Education Adult Education ? Basic Grants to States CFDA No. 84.002 Title I Grants to Local Educational Agencies CFDA No. 84.010 Special Education Cluster (IDEA): Special Education Grants to States CFDA No. 84.027 Special Education Preschool Grants CFDA No. 84.173 Condition: The District?s current procurement policy did not incorporate the Uniform Guidance procurement standards. Additionally, the District does not have a formal conflict of interest policy that also addresses the administration of federal awards, or written procedures for documenting time and effort for payroll costs charged to Federal awards and cash management procedures to minimize the time elapsed between the receipts and disbursements of Federal Funds to conform to Uniform Guidance requirements. Criteria: 2 CFR section 200.303 of the Uniform Guidance requires non-Federal entities receiving Federal awards to establish and maintain internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Under the Uniform Guidance, Federal awards recipients must maintain written documentation of internal control policies and procedures, such as procurement policies that adhere to state and local law as well as federal regulations and statutes; procedures for documenting how costs are to be allocated to federal awards, documenting actual time and effort for payroll costs charged to federal awards; cash management procedures to minimize the time elapsed between the receipts and disbursements of federal funds; and how to safeguard personally identifiable information. Cause: Staffing constraints limited the District?s ability to perform a timely review of its existing policies and written procedures. Effect: Having insufficient or non-compliant written policies and procedures weaken the internal controls over Federal awards, increasing the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During our review of the District?s policies and our inquiries of District personnel regarding procedures, it was noted that District policies had not been updated to include changes as a result of the implementation of the Uniform Guidance. Although the District has procedures in place for administering Federal funds and documenting related costs, those procedures were not documented in writing. Identification of a Repeat Finding: This is not a repeat finding from the previous year?s audit. Recommendation: The District must review the Uniform Guidance requirements as well as its existing written policies and procedures and update them where applicable in order to comply with requirements of the Uniform Guidance. Views of Responsible Officials of Auditee: Policies and procedures regarding the Uniform Guidance were set to approved by the Board of Education, but with internal transition, these were not approved by the Board. The documents are ready and will be submitted to Board for approval.

2019-004. Documentation of Compensation for Personal Services ? Allowable Costs Department of Education, Passed-through New York State, Department of Education Title I Grants to Local Educational Agencies CFDA No. 84.010 Condition: The District did not maintain adequate documentation to support the personnel expenses for one employee charged to the Title I program in accordance with 2 CFR ?200.430(i). Criteria: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed by the employees. Cause: Due to an oversight, adequate documentation of time and effort was not maintained for one employee whose payroll costs were charged to multiple cost objectives including the Title I grant. Context: The District requires personnel activity reports (PARs) to be completed for employees whose salaries and wages are charged to Federal award programs to document their time and effort. During our testing of personnel costs charged to the Title I program, we noted that PARs for one of the fourteen sampled were not prepared. The individual?s salary was charged to multiple cost objectives including the Title I program. Effect: Insufficient or lack of documentation for personnel expenses charged to the Federal award could result in disallowed costs and possibly having to refund Federal monies. Questioned Costs: $39,394, which is the amount of the individual?s payroll costs charged to the Title I program for the year ended June 30, 2019. Identification of a Repeat Finding: This is not a repeat finding from the previous year?s audit. Recommendation: The District should review its procedures to ensure that proper documentation of time and effort supporting all personnel expenses charged to the Title I program are obtained timely and maintained in accordance with the Uniform Guidance provisions in 2 CFR ?200.430(i). Views of Responsible Officials: The Office of Instruction, Assessments, & Funded programs did not have access to professional personnel expense reports from the Business Office, nor were they provided, and therefore could not routinely monitor expenses. This will be changed going forward.

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