West Hempstead Union Free School District

Significant Deficiency 2024-001. 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 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 ALN: 84.425U COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief – Homeless Youth and Children ALN: 84.425W Condition: The District did not include the capital expenditures for the “Unit Ventilators Replacement Project” paid with CRRSA ESSER 2 funds in its current year’s capital assets inventory record. Criteria: Education Stabilization Fund (ESF) grant awards authorized under the federal Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act and American Rescue Plan Act of 2021 (ARP) may be used for equipment purchases and capital expenditures, consistent with federal regulations 2 CFR §200.313 and 2 CFR §200.439. In accordance with 2 CFR §200.313, non-federal entities receiving federal awards are required 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 non-federal entities 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. A physical inventory of the property acquired with federal awards must also be taken and the results reconciled with the property inventory records at least once every two years. Cause: The District recorded expenditures relating to the “Unit Ventilators Replacement Project” as purchased services instead of equipment based on instructions from the pass-through agency. As a result, the District did not identify these capital expenditures as capital assets that should be added to the capital assets inventory listing. Effect: The failure to include capital assets acquired with federal awards in the District’s capital assets inventory records could lead to improper or non-compliant procedures for assets inventory management and the subsequent disposal of those capital assets. Questioned Costs: None reported. Context: The District uses specific expenditure codes in its special aid fund to identify and track various categories of expenditures incurred that are reimbursable under various federal grants, including the CRRSA ESSER 2 grant award. The District was instructed by the New York State Education Department to include its unit ventilators replacement project costs in the District’s CRRSA ESSER 2 budget application as purchased services instead of equipment; thus, the District recorded the expenditures for the unit ventilators replacement project in a contractual expenditures object code (.400) instead of the standard expenditure object code (.200) for equipment purchases. As a result, when District personnel performed the annual review of the equipment expenditure codes of the District’s governmental funds to compile the listing of equipment additions during the year to update its capital assets inventory record, the cost of the unit ventilators replacement project was not included. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should revise its existing procedures for compiling annual capital assets additions information to ensure equipment and capital expenditures purchased with federal funds are considered and evaluated for inclusion in the District’s annual capital assets inventory records. Views of Responsible Officials of Auditee: Management agrees with the finding. The District’s Assistant Superintendent for Business and Operations will review and update the existing procedures relating to the recording and tracking of capital assets purchased with federal funds.

Significant Deficiency 2024-001. 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 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 ALN: 84.425U COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief – Homeless Youth and Children ALN: 84.425W Condition: The District did not include the capital expenditures for the “Unit Ventilators Replacement Project” paid with CRRSA ESSER 2 funds in its current year’s capital assets inventory additions. Planned Corrective Action: The District’s Assistant Superintendent for Business and Operations will review and update existing procedures relating to the recording and tracking of capital assets purchased with federal funds. The cost of the unit ventilators replacement project and pertinent information will be added to the District’s capital assets inventory report. Responsible Contact Person: Brian Phillips Assistant Superintendent for Business and Operations West Hempstead Union Free School District 252 Chestnut Street West Hempstead, NY 11552 Anticipated completion date: September 1, 2025.

Significant Deficiency 2019-001. Internal Control Over Compliance Department of Education Passed-through New York State, Department of Education Title I Grants to Local Educational Agencies CFDA No. 84.010 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?s current procurement policy did not incorporate the Uniform Guidance procurement standards. The District also did not have written procedures related to the spending of federal awards as required by the Uniform Guidance. Cause: The District was unable to complete a timely review of the policies and written procedures during the year. Context: Staffing constraints limited the District management?s ability to perform a timely review of its existing policies and written procedures and present the updated policies to the Board of Education for approvals during the 2018-19 fiscal year. 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. Identification of a 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 agrees with the finding. The District?s Assistant Superintendent for Business will review all policies and procedures relating to U.S. Office of Management and Budget Uniform Guidance to ensure policies are in compliance with these guidelines. The required policy was adopted by the Board of Education at its December 17, 2019 meeting.

2019-001. Internal Control Over Compliance Department of Education Passed-through New York State, Department of Education Title I Grants to Local Educational Agencies CFDA No. 84.010 Child Nutrition Cluster School Breakfast Program CFDA No. 10.553 National School Lunch Program CFDA No. 10.555 Condition: The District?s current procurement policy did not incorporate the Uniform Guidance procurement standards and did not have written procedures related to the spending of federal awards as required by the Uniform Guidance. Planned Corrective Action: The District will adopt an appropriate policy with written procedures as required by the Uniform Guidance. Responsible Contact Person: Joel Press, Assistant Superintendent for Business Anticipated Completion Date: The required policy was adopted by the Board of Education at its December 17, 2019 meeting.

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