Catskill Central School DistrictLocal Government

U.S. Department of Education Passed-Through Entity: New York State Department of Education Finding 2024-002 (Significant Deficiency) COVID-19 – Education Stabilization Fund: ARP Homeless II (Assistance Listing # 84.425U) ARP Learning Loss (Assistance Listing # 84.425U) ESSER II (Assistance Listing # 84.425D) ARP Summer Enrichment (Assistance Listing # 84.425U) ARP Comprehensive After School (Assistance Listing # 84.425U) ARP ESSER III (Assistance Listing # 84.425U) Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria – Expenditures must be used to prevent, prepare for, and respond to COVID-19. These programs are authorized, as applicable, by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, 2021, Pub. L. No. 116-260 (December 27, 2020), and the American Rescue Plan (ARP) Act of 2021, Pub. L. No. 117-2 (March 11, 2021). The regulations in 34 CRF Part 76 (State Administration), 2 CFR Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Award and 31 CFR Part 205 (Cash Management Improvement Act) apply to these programs. The School District must: (a) Establish and maintain effective 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statues, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, State, local and tribal laws regarding privacy and responsibility over confidentiality. Condition/Context – We haphazardly sampled five COVID-19 – Education Stabilization Fund (ESF) expenditures. Our audit procedures found one disbursement where management overrode documented internal control procedures. We viewed invoices, purchase orders, and payment support and noted the disbursement was processed and paid without proper documentation to support the payment made and the payment was processed without the internal claims auditor’s review prior to payment. Cause – Management override of established controls. Effect – Revenues and expenditures for one of the ESF grants were overstated prior to adjustment. Adjustment resulted in recording a receivable from the vendor and an offsetting liability to the passthrough agency providing the grant funding. Questioned Costs – None. The improper payment was subsequently adjusted out of expenditures. Recommendation – We recommend that the School District ensures that only disbursements that have been processed and approved by the internal claims auditor to be paid. Management Response – School District management concurs with the finding and will take corrective action.

Federal Program: Assistance Listing Nos.: 84.027 Special Education, Part B, 611 & 81.173 Special Education, Preschool 619, and 84.425C, 84.425D, 84.425U Education Stabilization Grant Condition: The District did not comply with the required standards of Support of Salaries and Wages because employees whose time was charged to federal grants during fiscal year ending 6/30/2017 did not complete monthly time certification forms or personnel activity reports (PAR) for their time distribution. This was not addressed completely during the preceding years. In the current year the time allocated to the grant on the PAR was inaccurate for actual time spent on the grant. Criteria: The distribution of the salaries and wages of employees are to be supported by either time certifications or personnel activity reports or equivalent documentation which meets the standards in Subsection 8.h. (5) of the OMB Circular A-87 Part 225 Appendix B. The certification for employees who work on one cost objective must be prepared at least semi-annually. Personnel activity reports (PAR) for employees who work on multiple activities or cost objectives must be prepared at least monthly and meet certain prescribed standards, such as accounting for the employee?s total compensation, and reflecting an after-the-fact distribution of the actual activity of each employee. The costs of such compensation are allowable to the extent that they satisfy the specific requirements of this and other appendices under 2 CFR Part 225, and that the total compensation for individual employees: (3) Is determined and supported as provided in Subsection h. (8. Compensation for Personal Services. A. (3).) Questioned Costs: There are no questioned costs. Effect: It is more likely that the extent of effort charged to the various cost objectives may not be representative of the related time devoted to the respective cost objectives. Cause: District did not have a system in place to ensure the District complied with the required standards of Support of Salaries and Wages for an employee who needed to complete monthly certifications and that the time allocation on the grant is reported accurately. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management require that copies of these payroll certifications be forward to the District Treasurer on a timely basis and that they are reviewed for accuracy. Perspective: This is a systematic issue in that controls over the requirement have not been developed to ensure no issues arise. Repeat: This is a repeat finding. The staff that handles this has changed over past couple of years.

Federal Program: CFDA Nos.: 84.027 Special Education, Part B, 611 & 81.173 Special Education, Preschool 619 Condition: The District does not comply with the required standards of Support of Salaries and Wages because employees whose time was charged to federal grants during fiscal year ending 6/30/2017 did not complete monthly time certification forms or personnel activity reports (PAR) for their time distribution. Criteria: The distribution of the salaries and wages of employees are to be supported by either time certifications or personnel activity reports or equivalent documentation which meets the standards in Subsection 8.h. (5) of the OMB Circular A-87 Part 225 Appendix B. The certification for employees who work on one cost objective must be prepared at least semi-annually. Personnel activity reports (PAR) for employees who work on multiple activities or cost objectives must be prepared at least monthly and meet certain prescribed standards, such as accounting for the employee?s total compensation, and reflecting an after-the-fact distribution of the actual activity of each employee. The costs of such compensation are allowable to the extent that they satisfy the specific requirements of this and other appendices under 2 CFR Part 225, and that the total compensation for individual employees: (3) Is determined and supported as provided in Subsection h. (8. Compensation for Personal Services. A. (3).) Questioned Costs: There are no questioned costs. Effect: It is more likely that the extent of effort charged to the various cost objectives may not be representative of the related time devoted to the respective cost objectives. Cause: District did not have a system in place to ensure the District complied with the required standards of Support of Salaries and Wages for an employee who needed to complete monthly certifications.

Federal Program: CFDA Nos.: 84.027 Special Education, Part B, 611 & 81.173 Special Education, Preschool 619 Condition: The District does not comply with the required standards of Support of Salaries and Wages because employees whose time was charged to federal grants during fiscal year ending 6/30/2017 did not complete monthly time certification forms or personnel activity reports (PAR) for their time distribution. Criteria: The distribution of the salaries and wages of employees are to be supported by either time certifications or personnel activity reports or equivalent documentation which meets the standards in Subsection 8.h. (5) of the OMB Circular A-87 Part 225 Appendix B. The certification for employees who work on one cost objective must be prepared at least semi-annually. Personnel activity reports (PAR) for employees who work on multiple activities or cost objectives must be prepared at least monthly and meet certain prescribed standards, such as accounting for the employee?s total compensation, and reflecting an after-the-fact distribution of the actual activity of each employee. The costs of such compensation are allowable to the extent that they satisfy the specific requirements of this and other appendices under 2 CFR Part 225, and that the total compensation for individual employees: (3) Is determined and supported as provided in Subsection h. (8. Compensation for Personal Services. A. (3).) Questioned Costs: There are no questioned costs. Effect: It is more likely that the extent of effort charged to the various cost objectives may not be representative of the related time devoted to the respective cost objectives. Cause: District did not have a system in place to ensure the District complied with the required standards of Support of Salaries and Wages for an employee who needed to complete monthly certifications.

Federal Program: CFDA Nos.: 84.027 Special Education, Part B, 611 & 81.173 Special Education, Preschool 619 Condition: The District does not comply with the required standards of Support of Salaries and Wages because employees whose time was charged to federal grants during fiscal year ending 6/30/2017 did not complete monthly time certification forms or personnel activity reports (PAR) for their time distribution. Criteria: The distribution of the salaries and wages of employees are to be supported by either time certifications or personnel activity reports or equivalent documentation which meets the standards in Subsection 8.h. (5) of the OMB Circular A-87 Part 225 Appendix B. The certification for employees who work on one cost objective must be prepared at least semi-annually. Personnel activity reports (PAR) for employees who work on multiple activities or cost objectives must be prepared at least monthly and meet certain prescribed standards, such as accounting for the employee?s total compensation, and reflecting an after-the-fact distribution of the actual activity of each employee. The costs of such compensation are allowable to the extent that they satisfy the specific requirements of this and other appendices under 2 CFR Part 225, and that the total compensation for individual employees: (3) Is determined and supported as provided in Subsection h. (8. Compensation for Personal Services. A. (3).) Questioned Costs: There are no questioned costs. Effect: It is more likely that the extent of effort charged to the various cost objectives may not be representative of the related time devoted to the respective cost objectives. Cause: District did not have a system in place to ensure the District complied with the required standards of Support of Salaries and Wages for an employee who needed to complete monthly certifications. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management require that copies of these payroll certifications be forward to the District Treasurer on a timely basis. Status as of June 30, 2019: The District still does not comply with the required standards of Support of Salaries and Wages because two employees whose time was charged to federal grants during fiscal year ending 6/30/2019 did not complete monthly time certification forms or personnel activity reports (PAR) for their time distribution. We will continue to monitor going forward.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION