Goshen Central School District

A. Finding on Internal Control over Compliance Finding Reference: 2025-001 Federal Agency: U.S. Department of Education Federal Program: IDEA – Part B, Section 611 (84.027) IDEA – Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a) Significant Deficiencies in Internal Control Over Compliance b) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(1) of the Office of Management and Budget’s Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, among other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity; d) Encompass both federally assisted and all other activities compensated by the non-Federal entity; e) Support the distribution of the employee’s salary or wages amount specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: District employees whose time was being charged to the grants, who were working both 100% and less than 100% of the time in the federal award program, were required to complete semi-annual or monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely and not completed by all employees whose time was charged to the grants. In one instance, an employee’s percent of time charged to the grant was greater than the percentage certified. Cause: The School District did not have adequate internal controls in place to ensure that the semi-annual or monthly certifications were being completed by each employee working in the federal award programs timely and accurately. Effect: Without adequate internal controls over the employee’s time being charged to the grant and the certification requirement, the School District cannot ensure that federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Identification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027), Section 619 (84.173) from the immediate previous audit, 2024-001. Questioned Costs: The employees’ certifications in questions were reviewed and after reviewing the allocation of each employees’ time it was determined that the time being charged to the grant was appropriate. Additionally, for the one employee whose time charged to the grant was greater than percent of time certified, we determined that the actual time and effort was greater than that charged to the grant and determined that there were no questioned costs. Recommendation: We recommend that the District have proper internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program and completed timely. Monthly certifications should be completed if less than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Internal controls should also be in place to ensure that only those employees who are working in the grant are being charged to the grant. Management Response: The District agrees with the finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan on the following page.

Corrective Action Plan: The District will implement a system of internal controls to ensure that all certifications are completed by employees working in the federal award programs and in a timely manner. Additionally, the District will ensure that time being charged to the grant agrees to actual time spent working in the grant for each employee by sharing this information with building Principals to ensure that the information is accurate and they obtain the employee signature as soon as possible. Anticipated Completion Date:This was completed by October 31, 2025 by the District Treasurer, Assistant Superintendent for Business & PPS Director

2024-001

A. Finding on Internal Control over Compliance Finding Reference: 2024-001 Federal Agency: U.S. Dept of Education Federal program: IDEA - Part B, Section 611 (84.027) IDEA- Part B, Section 619 (84.173), Title I, Part A (84.010) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a.) Significant Deficiencies in Internal Control Over Compliance b.) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(l) of the Office of Management and Budget's Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, amoung other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity; d) Encompass both federally assisted and all other actvities compensated by the non-Federal entity; e) Support for the distribution of the employee's salary or wages amount specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: District employees whose time was being charged to the grants, who were working both 100% and less than 100% of the time in the federal award program, were required to complete semi-annual or monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely and not completed by all employees whose time was charged to the gratns. In one instance, an employee's time was charged to the grant that did not work in the gratn. Cause: The School District did not have adequate internal controls in place to ensure that the semi annual or monthly certifications were being completed by each employee working in the federal award programs timely. Effect: Without adequate internal contyrols over the employee's time being charged to the grant and the certification requirement, the School District cannot ensure that the federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Indentification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2023-001. Questioned Costs: The employee's certifications in questions were reviewed and after reviewing the allocation of each employee's time it was determined that the time being charged to the gratn was appropriate. Additionally, for the one employee charged to the grant in error, we reviewed documentation for an employee who workied in the grant but shose time was not charged to the grant and determined that there were no questioned costs. Recommendation: We recommend that the District have propert internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program and completed timely. . Monthly certifications should be completed if less than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Internal controls should also be in place to ensure that only those employees who are working in the grant are being charged to the grant. Management Response: The District agrees with the audit finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan.

The District will implement a system of internal controls to ensure that all certifications are completed by employees working in the federal award programs and in a timely manner. Additionally, the District will ensure that the time being charged to the grant agrees to actual time spent working in the grant for each employee. Anticipated completion Date: Currently in process with final expected date of October 31, 2024.

2023-001

A. Finding on Internal Control over Compliance Finding Reference: 2023-001 Federal Agency: U.S. Dept of Education Federal program: IDEA - Part B, Section 611 (84.027) IDEA- Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a.) Significant Deficiencies in Internal Control Over Compliance b.) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(l) of the Office of Management and Budget's Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, amoung other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) reasonably reflect the total activity for which the employee is compensated by the non-Federal entity; d) Encompass both federally assisted and all other actvities compensated by the non-Federal entity; e) Support for the distribution of the employee's salary or wages amount specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Several of the District employees whose time was being charged to the grants but who were working less than 100% of the time in the federal award program, where required to complete monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely. Cause: The School District did not have adequate review procedures in place to ensure that the monthly certifications were being completed by each employee working in the federal award programs timely. Effect: Without adequate internal contyrols over the employee's time being charged to the grant and the certification requirement, the School District cannot ensure that the federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Indentification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2022-001. Questioned Costs: The employee's certifications in questions were reviewed and after reviewing the allocation of each employee's time it was determined that the time being charged to the gratn was appropriate, therefore, there were no questioned costs. Recommendation: We recommend that the District have propert internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if thless than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Management Response: The District agrees with the audit finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan.

The District will implement a system of internal controls to ensure that all certifications are completed timley. Additionally, the District will ensure that time being charged to the grant agrees to actual time spent working in the grant for each employee.

2022-001

A. Finding on Internal Control over Compliance Finding Reference: 2022-001 Federal Agency: U.S. Department of Education Federal Program: IDEA ? Part B, Section 611 (84.027) IDEA ? Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a) Significant Deficiencies in Internal Control Over Compliance b) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(1) of the Office of Management and Budget?s Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, among other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity; d) Encompass both federally assisted and all other activities compensated by the non-Federal entity; e) Support the distribution of the employee?s salary or wages amount specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Several of the District employees whose time was being charged to the grants but who were working less than 100% of the time in the federal award program, were required to complete monthly certifications of the percentage of time they worked in each federal award program however, they were not completed timely. Cause: The School District did not have adequate review procedures in place to ensure that the monthly certifications were being completed by each employee working in the federal award programs timely. Effect: Without adequate internal controls over the employee?s time being charged to the grant and the certification requirement, the School District cannot ensure that federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Identification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2021-001. Questioned Costs: The employees? certifications in questions were reviewed and after reviewing the allocation of each employees? time it was determined that the time being charged to the grant was appropriate, therefore, there were no questioned costs. Recommendation: We recommend that the District have proper internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if less than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Management Response: The District agrees with the finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan on the following page.

FINDINGS - FEDERAL AWARD PROGRAM AUDITS U.S. DEPARTMENT OF EDUCATION Finding: 2022-001: IDEA - Part B, Section 611 (84.027) & IDEA - Part B, Section 619 (84.173) Recommendation; We recommend that the District have proper internal controls in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if less than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Corrective Action Plan: The District will implement a system of internal controls to ensure that all certifications are completed in accordance with the percentage of time worked (ie. Monthly or semiannually) and that they are completed timely. Additionally, the District will ensure that time being charged to the grant agrees to actual time spent working in the grant for each employee. Anticipate,/ Completion Date: Currently in process with a final expected date of October 31,2022.

2021-001

A. Finding on Internal Control over Compliance Finding Reference: 2021-001 Federal Agency: U.S. Department of Education Federal Program: IDEA ? Part B, Section 611 (84.027) IDEA ? Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a) Significant Deficiencies in Internal Control Over Compliance b) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(1) of the Office of Management and Budget?s Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, among other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity; d) Encompass both federally assisted and all other activities compensated by the non-Federal entity; e) Support the distribution of the employee?s salary or wages amount specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: One of the employees whose time was charged to the grant did not perform services directly related to the grant and was charged to the grant in error. Two of the District employees whose time was being charged to the grants were required to complete certifications of the percentage of time they worked in each federal award program however, they were not completed. Cause: The School District did not have adequate review procedures in place to ensure that salaries being charged to the grant were for employees who actually performed services related to the grant. Further, adequate internal controls were not in place to ensure that the certifications were being completed by employees working in the federal award programs. Effect: Without adequate internal controls over the employee?s time being charged to the grant and the certification requirement, the School District cannot ensure that federal funds are paid in accordance with allowable costs and the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Identification of a Repeat Finding: This is a repeat finding for IDEA, Section 611 (84.027) and Section 619 (84.173), from the immediate previous audit, 2020-001 Finding Reference: 2021-001 (Continued) Federal Agency: U.S. Department of Education Federal Program: IDEA ? Part B, Section 611 (84.027) IDEA ? Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a) Significant Deficiencies in Internal Control Over Compliance b) Compliance Finding Questioned Costs: The employees? certifications in questions were reviewed and after reviewing the allocation of each employees? time it was determined that the time being charged to the grant was appropriate. The one employee whose time was charged to the grant in error was $17,000. The District had other salary expenses that could have been charged but were not, therefore, there were no questioned costs. Recommendation: We recommend that the District have proper internal controls in place to ensure that salaries being charged to the grant are for only those employees who perform services directly related to the grant. Additionally, internal controls should be in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if less than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Management Response: The District agrees with the finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan on the following page.

FINDINGS - FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION 2021-001 IDEA - Part D, Section 611 (84.027) & IDEA - Part D, Section 619 (84.173) Recommendation: We recommend that the District have proper internal controls in place to ensure that salaries being charged to the grant are for only those employees who perform services directly related to the grant. Additionally, internal controls should be in place to ensure that the employees working in the grants are certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if less than 100% of time is being worked in the federal program or semiannually If 100% of time is spent. Corrective Action Plan: The Assistant Superintendent for Business will review each employee being charged to a grant to ensure their eligibility. Anticipated Completion Date: November 30, 2021

2020-001

Finding Reference: 2020-001 Federal Agency: U.S. Department of Education Federal Program: IDEA ? Part B, Section 611 (84.027) IDEA ? Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a) Significant Deficiencies in Internal Control Over Compliance b) Compliance Finding Criteria: According to 2 CFR, Part 200.430(i)(1) of the Office of Management and Budget?s Uniform Grant Guidance, charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, which must, among other things: a) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; b) Be incorporated into the official records of the non-Federal entity; c) Reasonably reflect the total activity for which the employee is compensated by the non- Federal entity; d) Encompass both federally assisted and all other activities compensated by the non-Federal entity; e) Support the distribution of the employee?s salary or wages amount specifid activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: Several of the District employees whose time was being charged to the grants but who were working less than 100% of the time in the federal award program, were required to complete monthly certifications of the percentage of time they worked in each federal award program however, they were being completed semi-annually and were not being completed timely. Cause: The School District did not have adequate internal controls in place to ensure that the monthly certifications were being completed by each employee working in the federal award programs and are not ensuring that they are being completed timely. Effect: Without adequate internal controls over the employee certification requirement, the School District cannot ensure that federal funds are paid in accordance with the time worked in the grant. Additionally, they cannot easily monitor the amount of funds that can be charged to the grant for salaries and benefits. Payments that do not agree with the time worked are unallowable and subject to recovery by the grantor. Questioned Costs: The employees? certifications in questions were reviewed and after reviewing the allocation of each employees? time it was determined that the time being charged to the grant was appropriate, therefore, there were no questioned costs. Recommendation: We recommend that the District ensure that the employees working in the grants are timely certifying their actual percent of time and effort that is being spent working in the federal award program. Monthly certifications should be completed if less than 100% of time is being worked in the federal award program or semiannually if 100% of time is being spent. Management Response: The District agrees with the finding and will implement adequate checks and balances to ensure that this problem does not recur. Please refer to the corrective action plan on the following page.

Finding Reference: 2020-001 Federal Agency: U.S. Department of Education Federal Program: IDEA ? Part B, Section 611 (84.027) IDEA ? Part B, Section 619 (84.173) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: a) Significant Deficiencies in Internal Control Over Compliance b) Compliance Finding Finding: 2020-001 Name of Contact Person: Ms. Louise M. Lynch, Assistant Superintendent for Business Corrective Action: The District will implement a system of internal controls to ensure that all certifications are completed in accordance with the percentage of time worked (ie. monthly or semiannually) and that they are completed timely. Additionally, the District will ensure that this information is verified to the costs being charged to the grant. Anticipated Completion Date: Currently in process.