Bellmore-Merrick Central High School District

Significant Deficiency 2019-001. Internal Control Over Compliance Department of Education, Passed-through New York State, Department of Education Special Education Grants to States CFDA No. 84.027 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 referenced the Uniform Guidance procurement standards. However, the District?s existing conflicts of interest policy does not have provisions specifically addressing the administration of Federal awards, and the District does not have other 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 inquiries of District personnel regarding policies and procedures, it was noted that District policies had not been sufficiently updated to include changes as a result of the implementation of the Uniform Guidance. Although District has procedures and controls in place for administering Federal awards, those procedures were not documented in writing. Identification of a Repeat Finding: This is not a repeat finding from previous audit. Recommendation: The District must review its existing written policies and procedures related to the spending and administering of Federal awards, and update them as needed in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District is in agreement with this recommendation as it will help us further strengthen our internal controls and assure us that we are adhering to all regulations with regards to federal awards.

CORRECTIVE ACTION PLAN For the Year Ended June 30, 2019 2019-001. Internal Control Over Compliance Department of Education, Passed-through New York State Department of Education Special Education Grants to States CFDA No. 84.027 Condition: The District?s current procurement policy referenced the Uniform Guidance procurement standards. However, the District?s existing conflicts of interest policy does not have provisions specifically addressing the administration of federal awards, and the District does not have other written procedures to conform to Uniform Guidance requirements. 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. Planned Corrective Action: The District will utilize the template created by the New York State Association of School Business Officials (NYSASBO) to update its current policies and written procedures to comply with the Uniform Guidance requirements for all Federal awards. Responsible Contact Person: Kate Freeman, Assistant Superintendent for Business, Mikaela Coni, School Business Administrator & Purchasing Agent. Anticipated Completion Date: June 30, 2020.