Lawrence Union Free School District

Significant Deficiency 2025-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010A United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster Non-Cash Assistance (food distribution) National School Lunch Program ALN: 10.555 Cash Assistance School Breakfast Program ALN: 10.553 National School Lunch Program ALN: 10.555 Criteria: 2 CFR §200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award 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. Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: Staffing constraints have 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 internal controls over the federal awards received, increasing the risk of noncompliance with federal statutes and regulations. Questioned Costs: Dollar amount undetermined, as adequate documentation was not available. Identification of a Repeat Finding: This is a repeat finding from the previous audit referenced, 2024-001 in connection with the audit of the Educational Stabilization Fund awards expended, ALN: 84.425D, ALN: 84.425U, and ALN: 84.425W. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District has developed a policy entitled “Procurement: Uniform Grant Guidance for Federal Awards” that addresses the Uniform Guidance requirements related to procurement. This policy was adopted by the Board of Education at the November 17, 2025 Board meeting.

Significant Deficiency 2024-001. Procurement United States Department of Education, passed through New York State Department of Education Education Stabilization Fund COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief – Homeless Youth and Children ALN: 84.425W Criteria: 2 CFR §200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award 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. Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: Staffing constraints have 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 internal controls over the federal awards received, increasing the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding from the previous audit referenced 2023-001. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District’s Assistant Superintendent for Business will work on updating all policies and procedures relating to U.S. Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.

Significant Deficiency 2023-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010 Special Education Cluster Special Education Grants to States: IDEA, Part B ALN: 84.027A Special Education Grants to States: IDEA 611 ARP Allocations ALN: 84.027X Special Education Preschool Grants: IDEA Preschool ALN: 84.173A Special Education Preschool Grants: IDEA 619 ARP Allocations ALN: 84.173X Education Stabilization Fund (ESF) COVID-19: Governor’s Emergency Education Relief Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster School Breakfast Program ALN: 10.553 National School Lunch Program ALN: 10.555 COVID-19: National School Lunch Program ALN: 10.555 COVID-19: Summer Food Service Program for Children ALN: 10.559 Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Criteria: 2 CFR §200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award 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 have 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 internal controls over the federal awards received, increasing the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding from the previous audit referenced 2022-001. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District’s Assistant Superintendent for Business will work on updating all policies and procedures relating to U.S. Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.

2022-001. Procurement United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010 Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Preschool Grants ALN: 84.173A Education Stabilization Fund COVID-19: Governor?s Emergency Education relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief - Homeless Children and Youth ALN: 84.425W United States Department of Agriculture, passed through New York State Department of Education Child Nutrition Cluster COVID-19: School Breakfast Program (SSO) ALN: 10.553 National School Lunch Program ALN: 10.555 COVID-19: National School Lunch Program ALN: 10.555 COVID-19: Summer Food Service Program for Children ALN: 10.559 Criteria: 2 CFR ?200.303 of the Uniform Guidance requires non-federal entities receiving federal awards to establish and maintain internal control over the federal award 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. Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Cause: Staffing constraints have 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 internal controls over the federal awards received, increasing the risk of noncompliance with federal statutes and regulations. Questioned Costs: None reported. Identification of a Repeat Finding: This is a repeat finding from the previous audit referenced 2021-001. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District?s Assistant Superintendent for Business will work on updating all policies and procedures relating to US Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.

2022-002. Allowable Costs/Cost Principles United States Department of Education, passed through New York State Department of Education Title I Grants to Local Educational Agencies ALN: 84.010 Special Education Cluster Special Education Grants to States ALN: 84.027A Special Education Preschool Grants ALN: 84.173A Criteria: 2 CFR ?200.400 of the Uniform Guidance issued by the U.S. Office of Management and Budget requires management to have adequate documentation to support costs charged to federal awards. In consideration of this, the District is required to make purchases using federal funds that comply with program guidelines established by federal and state agencies, and all purchases made using federal funds should be reviewed and approved by an administrator familiar with those program guidelines. Condition: Based on our sample testing of the expenditures charged to the Special Education Cluster and the Title I Grants to Local Educational Agencies, we noted that some expenditures did not show evidence of a grant administrator?s review and approval. Cause: The District did not have a consistent process in place to ensure that all expenditures charged to the federal programs were reviewed and approved by the appropriate administrator prior to payment. Effect: This could result in the District potentially submitting unallowable expenditures for reimbursement. Questioned Costs: None reported. Context: Total population size of purchase expenditures for the Special Education Cluster was 63. The audit sample size was 10% of the population, which totaled 6 samples that were haphazardly selected for audit testing. The finding was identified in 2 of the 6 samples selected. Total population size of purchase expenditures for the Title I grants to Local Educational Agencies was 11. Audit sample size was 10% of the population, which totaled 2 samples that were haphazardly selected for audit testing. The finding was identified in the 2 samples selected. Recommendation: The District should implement procedures whereby all expenditures charged to federal grant programs show documented evidence of review and approval for payment by the appropriate grant administrator responsible for the oversight of that grants. Views of Responsible Officials of Auditee: Management agrees with the finding. The District?s Assistant Superintendent for Business has begun implementing procedures to ensure all expenditures charged to federal programs show evidence of review and approval of an appropriate grant administrator responsible for the oversight of these grants.

2022-003. Equipment and Real Property Management United States Department of Education, passed through New York State Department of Education Education Stabilization Fund COVID-19: Governor?s Emergency Education relief (GEER) Fund ALN: 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER) Fund ALN: 84.425U COVID-19: American Rescue Plan ? Elementary and Secondary School Emergency Relief - Homeless Children and Youth ALN: 84.425W Criteria: 2 CFR ?200.313 of the Uniform Guidance issued by the U.S. Office of Management and Budget requires management to have procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place. This includes maintaining property records that include a description of the property, a serial number or other identification number, the source of funding for the property, including the Federal Award Identification Number (FAIN), and who holds title. In addition, it requires the District to track the acquisition date and cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Condition: The District did not include equipment purchased using federal grant funds in its current year additions in the District?s capital assets inventory. Cause: The District uses specific codes to identify and track equipment purchased during the year. Since the District did not have adequate procedures in place to review and reconcile the District?s equipment purchases codes to the annual capital asset additions, the equipment purchased under the federal grant was inadvertently omitted from the current year capital assets inventory additions. Effect: This could result in the improper tracking, use, or disposal for capital assets purchased with federal funds. Questioned Costs: None reported. Context: The District rarely uses federal grant funds for the purchase of equipment. As a result of this, when the District Treasurer was compiling the listing of equipment purchased during the year to be provided to the District?s third party capital asset management company, the equipment purchased using federal grant funds was inadvertently omitted from the listing. Recommendation: The District should implement procedures where there is a formal reconciliation performed annually between all of the District?s equipment expenditure codes and the additions to the District?s capital assets inventory. This will ensure that all equipment purchased with federal funds is captured and included in the capital asset inventory report of the district at year-end. Additionally, all capital assets additions purchased with federal funds should be managed in accordance with 2 CFR ?200.313. Views of Responsible Officials of Auditee: Management agrees with the finding and will ensure that the equipment purchased with federal funds is captured, reconciled, and included in the District?s capital assets inventory records.

2021-001. Procurement United States Department of Education Child Nutrition Cluster: National School Lunch Program Assistance Listing (CFDA) No. 10.555 COVID-19: Summer Food Service Program (SFSP) Assistance Listing (CFDA) No. 10.559 Condition: The District has not updated their existing policies and written procedures 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. In addition, the District was in the process of updating their procurement policy, however, due to the COVID-19 pandemic, there were delays and the policy is still in the process of being updated. Effect: Having insufficient or non-compliant written policies and procedures weaken the internal controls over the Federal award, increasing the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquires 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. The lack of updated policies did not result in any questioned costs or improper reimbursements. Repeat Finding: This is a repeat finding from the previous audit referenced 2020-001. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District?s Assistant Superintendent for Business will continue to work on updating all policies and procedures relating to US Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.

Significant Deficiency 2020-001. Procurement United States Department of Education Child Nutrition Cluster: School Breakfast Program CFDA No. 10.553 National School Lunch Program CFDA No. 10.555 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. Condition: The District has not updated their existing policies and written procedures to conform to Uniform Guidance requirements. Cause: Staffing constraints limited the District?s ability to perform a timely review of its existing policies and written procedures. In addition, the District was in the process of updating their procurement policy, however, due to school closures resulting from the COVID-19 pandemic, there were delays and the policy is still in the process of being updated. Effect: Having insufficient or non-compliant written policies and procedures weaken the internal controls over the Federal award, increasing the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During inquires 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. The lack of updated policies did not result in any questioned costs or improper reimbursements. Repeat Finding: This is a repeat finding from the previous audit referenced 2019-001. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District?s Assistant Superintendent for Business will review all policies and procedures relating to US Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines.

Significant Deficiency 2019-001. Procurement Department of Education Special Education Cluster: Special Education Grants to States CFDA No. 84.027 Special Education Preschool Grants CFDA No. 84.173 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. Condition: The District has not updated their existing policies and written procedures to conform to Uniform Guidance requirements. 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 the Federal award, increasing the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Context: During our inquires 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. The lack of updated policies did not result in any questioned costs or improper reimbursements. Repeat Finding: This is not a repeat finding from the previous audit. Recommendation: The District must review its existing written policies and procedures and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District?s Assistant Superintendent for Business will review all policies and procedures relating to US Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines

GSA_MIGRATION