ROSLYN UNION FREE SCHOOL DISTRICT

2021-001. Allowable Costs/Cost Principles Special Education Cluster Special Education Grants to States Assistance Listing (CFDA) No. 84.027 Special Education Preschool Grants Assistance Listing (CFDA) No. 84.173 Criteria: Salaries and wages charged to federal awards must be supported by documentation prescribed by the Uniform Guidance at Subpart E, 2 CFR 200.430. Condition: Subpart E, 2 CFR 200.430 of the Uniform Guidance requires that charges to ?Federal awards for salaries and wages must be based on records that accurately reflect the work performed?. The documentation should support the distribution of the employee?s compensation among specific activities if the employee works on more than one Federal award, or a Federal award and non-Federal award. The preparation of personnel activity reports (PARs) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District did not prepare the periodic certification equivalent correctly, to comply with Subpart E, 2 CFR 200.430, for the one salaried employee whose wages were charged to this federal award. Cause: The staff that were responsible for maintaining records that accurately reflect the work performed, as described in Subpart E, 2 CFR 200.430, to support salaries charged to Federal awards did not support the distribution of the employee?s compensation among specific activities if the employee works on more than one Federal award, or a Federal award and non-Federal award. Potential Effect: Noncompliance could result in the incorrect amount for services rendered being charged to the Federal award. Questioned Costs: None reported. Repeat Finding: This is not a repeat finding from a previous year audit. Recommendation: The District should prepare the appropriate documentation to support salaries and wages determined by services performed that are charged to Federal awards in accordance with the requirements of the Uniform Guidance at Subpart E, 2 CFR 200.430. Views of Responsible Officials of Auditee: The District will adopt procedures to ensure appropriate documentation will be prepared to comply with Subpart E, 2 CFR 200.430.

Significant Deficiency 2020-001. Cash Management Department of Agriculture, Passed-through New York State, Department of Education Child Nutrition Cluster School Breakfast Program CFDA No. 10.553 National School Lunch Program CFDA No. 10.555 Condition: During the COVID-19 pandemic, the District provided meals free of charge to eligible families within the District. The District was responsible for tracking the free meals distributed to support the federal and state claims reimbursement made for these meals during the pandemic (March 16, 2020 through June 30, 2020). We noted that the District complied with meal distribution requirements, and the tracking of total meals distributed, however, the number of meals claimed for reimbursement from the State for breakfast and lunch was not accurate. Criteria: Under the Child Nutrition Program, claims for meals served should be reconciled to supporting information, prior to the submission of the claim for payment to the State. Cause: Due to staffing limitations and timing constraints during the COVID-19 pandemic, from March 16, 2020 through June 30, 2020, there was no verification of the manual compilation of the meals distributed by building to the underlying daily meal count sheets maintained for each building. Potential Effect: Without a reconciliation of the meals distributed count data to the summary information used to claim the reimbursement, the District is at risk for either receiving overpayments from the State or not receiving adequate reimbursements. Questioned Costs: None reported, as the amounts are not material and well below the $25,000 reporting level for known question costs. Identification of a repeat finding: This is a not repeat finding from a previous year audit. Recommendation: We recommend that the District review the existing process in place for the compiling of and review of the monthly meals distributed summary information to the underlying daily meals counts maintained for each building, to ensure all information reported on the monthly claims submissions is accurate. The District should also complete its reconciliation of the meals served differences for the March 16, 2020 through June 30, 2020 period and determine whether they are due additional monies for federal and state claim reimbursements or if monies are due to the State. Views of Responsible Officials: The District agrees with these recommendations and will make every effort to address these by June 30, 2021.

2020-002. Special Tests/Income Verification Department of Agriculture, Passed-through New York State, Department of Education Child Nutrition Cluster School Breakfast Program CFDA No. 10.553 National School Lunch Program CFDA No. 10.555 Condition: The District determined that the sample size for verification and approved applications for the school year 2019-20 was two. Based on our review of the income documentation submitted for these two households, we noted that one of the verifications revealed eligibility for reduced price meals was not changed as a result of the household not responding to the request for income information. Criteria: Under the Child Nutrition Program, the District must request verification of income from households of students participating in the food service program each year by November 15th. Cause: Based on our inquiries and a review of a sample of the applications for free and reduced-price school meals used in the District?s verification process, it was determined that there was one required change in meal status for the 2019-20 school year. The meal status for that student had not been changed in the District?s point of sale software. Potential Effect: Not changing the student?s status for free and reduced price meals results in an incorrect reporting of meals claimed, and an incorrect reimbursement amount from the state of federal and state funds. The District has not resolved the potential small amount of repayment to the state for this amount. Questioned Costs: None reported, as the amounts are not material and well below the $25,000 reporting level for known question costs. Identification of a Repeat Finding: This is a not repeat finding from a previous year audit. Recommendation: Due to the COVID-19 pandemic and the State?s decision to establish the provision of free meals to all students during the pandemic, the District was informed by the State that they are not required to perform income verifications for fiscal 2020-21. Therefore, no secondary review for income verifications will be required for fiscal 20-21. However, we recommend the District evaluate the one change in classification in 2019-20 to determine the necessary reporting and monetary adjustments. We also recommend that the District implement the additional controls necessary for prospective changes to the point of sale system which may result from the annual verification process. Views of Responsible Officials: The District agrees with these recommendations and will make every effort to address these by June 30, 2021.

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 the finding and has adopted the required purchasing policy in November 2019 and is in the process of creating and adopting a manual of procedures to implement that policy.