East Meadow Union Free School DistrictLocal Government

Significant Deficiency 2024-001. Equipment and Real Property Management United States Department of Education, Passed Through New York State, Department of Education: Special Education Cluster Special Education Grants to States: IDEA Part B ALN: 84.027 Special Education Grants to States: IDEA 611 ARP Allocations ALN:84.027X Special Education Preschool Grants: IDEA Preschools ALN: 84.173 Special Education Preschool Grants: DEA 619 ARP Allocations ALN: 84.173X 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 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, 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 all equipment purchased with federal grant awards during the current year within its capital assets inventory records. Cause: The District uses specific codes to identify and track equipment purchased with federal funds during the year. Since the District did not have procedures in place to review and reconcile the District’s equipment purchases to the annual capital assets additions, some of the equipment purchased under the federal awards was inadvertently omitted from the current year capital assets inventory additions. Effect: The inability to include and differentiate capital assets acquired with federal awards in the capital assets inventory records could lead to improper procedures for disposal of those capital assets. Questioned Costs: None reported. Context: The review of the District’s capital assets additions in the capital assets inventory records indicated 63 transactions; the auditor noted 7 capital assets additions that were not included. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should implement procedures where there is a formal reconciliation performed between the District’s equipment expenditure codes and the additions to the District’s capital assets inventory records. This will ensure that all equipment purchased with federal awards is identified and included in the capital assets inventory records of the District by year end. Additionally, all capital assets additions purchased with federal awards should be managed in accordance with 2 CFR §200.313. Views of Responsible Officials of Auditee: Management is in agreement with the finding. Dr. Patrick Pizzo, Assistant Superintendent for Business and Finance, will oversee the reconciliation of capital equipment purchases to the capital assets additions in the capital assets inventory records.

2022-001. Reporting United States Department of Agriculture, passed-through New York State Department of Education: Child Nutrition Cluster National School Lunch Program Assistance Listing No. 10.555 COVID-19: School Breakfast Program (SSO) Assistance Listing No. 10.553 COVID-19: National School Lunch Program (SSO) Assistance Listing No. 10.555 COVID-19: National School Lunch Program (Emergency Operational Costs Reimbursement) Assistance Listing No. 10.555 COVID-19: Summer Food Service Program Assistance Listing No. 10.559 Criteria: 7 CFR ?210.8 of the Uniform Guidance requires that the School Food Authority shall establish internal controls, which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the School Food Authority; comparisons of daily free, reduced price, and paid meal counts against data that will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts that suggest the likelihood of meal counting problems. Prior to the submission of a monthly Claim for Reimbursement, each school food authority shall review the lunch count data for each school under its jurisdiction to ensure the accuracy of the monthly Claim for Reimbursement. The objective of this review is to ensure that monthly claims include only the number of free, reduced price and paid meals served on any day of operation to children currently eligible for such meals. Condition: Upon testing of the monthly reimbursement claims for meals served, it was noted that due to an error in how certain meals served in one elementary school were input into the District?s point of sale system that not all meals served were included on the monthly breakfast reimbursement claim for one month. This resulted in the District not receiving reimbursement for all breakfast meals served. Cause: The District did not have a procedure in place where an individual independent from the preparation of the monthly reimbursement claim verified the information to the detailed meals served information by building in the District?s point of sale system. Effect: Not having an updated independent review of the monthly Claim for Reimbursement could result in the District receiving the incorrect reimbursement of federal funds. Questioned Costs: None reported. Context: Total sample size was for three months of meal reimbursement claims. The sample size was expanded to an additional two months of meal reimbursement claims. In one month, it was noted that 525 breakfast meals were inadvertently coded in the point of sale system as snacks and not included on the monthly claim for reimbursement. This resulted in the District being under reimbursed for meals served by $1,368. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: The District should update its existing procedures to ensure that the meal reimbursement claims are reviewed and compared to the detailed information in the point of sale system for accuracy prior to being submitted to the State. Views of Responsible Officials of Auditee: The District is implementing additional procedures where all meal reimbursement claims are reviewed and approved by an individual independent of the preparation of the reimbursement claim prior to it being submitted to the State.

2021-001. Internal Control Over Compliance Department of Education: Special Education Cluster Special Education Grants to States Assistance Listing (CFDA) No. 84.027 Special Education Preschool Grants Assistance Listing (CFDA) No. 84.173 Education Stabilization Fund (ESF) COVID-19: Governor?s Emergency Education Relief (GEER) Fund Assistance Listing (CFDA) No. 84.425C COVID-19: Elementary and Secondary School Emergency Relief (ESSER) Fund Assistance Listing (CFDA) No. 84.425D 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 updated written documentation of internal control policies and procedures, which include 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, procedures for 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 recently adopted a Uniform Grant Guidance for Federal Awards Policy which addresses the Uniform Guidance requirements with respect to procurement; other requirements should be addressed. Cause: Staffing constraints as well as the District switching to a remote work format due to the State mandated closure of the District as a result of the COVID-19 pandemic limited the District?s ability to develop additional new policies and procedures. Potential Effect: Not having updated written policies and procedures weaken the internal controls over the Federal award and could increase 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 2020-001, related to the Special Education Cluster. Recommendation: The District should update its existing policies and procedures in order to comply with requirements of Uniform Guidance. Views of Responsible Officials: The District implemented additional policies and related procedures in order to comply with the requirements of Uniform Guidance, and these were included in the Federal Funds Procedural Manual, which was adopted by the Board of Education on June 15, 2022.

2020-001. Internal Control Over Compliance 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 updated written documentation of internal control policies and procedures, which include 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 recently adopted Uniform Grant Guidance for Federal Awards Policy addresses the Uniform Guidance requirements with respect to procurement; other requirements should be addressed. Cause: Staffing constraints as well as the District switching to a remote work format due to the State mandated closure of the District as a result of the COVID-19 pandemic limited the District?s ability to develop additional new policies and procedures. Potential Effect: Not having updated written policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. Identification of a Repeat Finding: This is part of the finding from the previous audit referenced 2019- 001, related to the Special Education Cluster. Recommendation: The District should implement additional updated policies and procedures in order to comply with requirements of Uniform Guidance. Views of Responsible Officials of Auditee: The District is aware of this finding and is implementing a policy and related procedures in order to comply.

Significant Deficiency 2019-001. Internal Control Over Compliance 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 updated written documentation of internal control policies and procedures, which include 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 and update of its existing policies and written procedures. Potential Effect: Not having updated written policies and procedures weaken the internal controls over the Federal award and could increase the risk of noncompliance with Federal statutes and regulations. Questioned Costs: None reported. 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 is aware of this finding and is implementing a policy and related procedures in order to comply.