Hudson Falls Central School DistrictLocal Government

Procurement Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, Supply Chain, noncash assistance, Summer Food Service Program Assistance Listing numbers 10.553, 10.555 and 10.559) passed through the New York State Education Department. U.S. Department of Education Special Education Cluster (Special Education – Grants to States and Special Education – Preschool Grants Assistance Listing Numbers 84.027 and 84.173) passed through the New York State Education Department. Criteria: 2 CFR Section 200.214 refers to executive orders 12549 and 12689 as well as 2 CFR Part 180, which stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal Assistance programs or activities. Statement of Condition: During our discussions with management, we noted that the District is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Additionally, we noted that there was no verification that procurements through state contracts were invoiced to the District at the contract rates. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.214 and 2 CFR part 180. Statement of Effect: The District is not in compliance with 2 CFR Section 200.214 and 2 CFR Part 180. The District is not performing required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected. The District could also be overpaying for goods. Questioned Costs: None Perspective Information: A review of vendors charged to the major programs determined no vendors were suspended or debarred. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This should be verified on an annual basis. Additionally, we recommend that a review of invoices as compared to bidding/contracting documentation be performed prior to payment. Views of responsible officials and planned corrective actions: Effective July 1, 2025 the Executive Director of Business & Human Resources, Kevin J. Polunci will review and and verify the eligibility of vendors that participate in federal assistance programs and on an annual basis. Additionally, the District will review the eligibility of potential vendors that participate in federal assistance programs and compare invoices to bidding/contracts prior to payments.

Equipment and Real Property Management Information on Federal Program: U.S. Department of Education, Education Stabilization Funds (Federal Assistance Listing numbers 84.425D, 84.425U, 84.425W), Passed through the New York State Education Department. Criteria: 2 CFR Section 200.313(d) requires property records to be maintained including a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in project costs, the location, use and condition of the property, and any ultimate disposition data. Additionally, it requires a physical inventory of the property be taken and results reconciled with the property records at least every two years. Statement of Condition: Record of equipment purchased under the federal program was not maintained in accordance with 2 CFR Section 200.313(d). Statement of Cause: The district was not aware of the requirements. Statement of Effect: The District is not in compliance with 2 CFR Section 200.313(d) and could fail to follow related disposition requirements. Questioned Cost: None. Recommendation: We recommend the District review the above referenced requirements and implement procedures to ensure the District complies with relevant compliance requirements. Views of the Responsible Officials and Planned Corrective Actions: The District will follow up with Questar III BOCES to make sure these federally funded pieces of equipment are clearly denoted in our fixed asset inventory.

Compliance with Reporting Requirements Information on Federal Program: U.S. Department of Education, Education Stabilization Funds (Federal Assistance Listing numbers 84.425D, 84.425U, 84.425W), Passed through the New York State Education Department. Criteria: 34 CFR 76.720 requires submission of an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. Statement of Condition: Our testing over financial reporting included the submission of the ESF annual report due during the year ended June 30, 2024. The annual report for the ESF grants due March 2024, was not filed as of September 19, 2024. Statement of Cause: There annual report for the ESF grants was not filed. Statement of Effect: Annual reports noted above were not filed within the required reporting deadline. Questioned Costs: None Perspective Information: As part of testing the compliance with the reporting requirements of the program, the submission of the annual ESF report, due within the period under audit, is reviewed for submission. Recommendation: Management should develop a tracking system for when their various grant reports are due based on the grant award notices to ensure timely filing of their annual reports. View of Responsible Officials and Corrective Action Plan: Annual reports will be filed by the appropriate deadline.

Equipment and Real Property Management Information on Federal Program: U.S. Department of Education, Education Stabilization Funds (Federal Assistance Listing numbers 84.425D, 84.425U, 84.425W), Passed through the New York State Education Department. Criteria: 2 CFR Section 200.313(d) requires property records to be maintained including a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in project costs, the location, use and condition of the property, and any ultimate disposition data. Additionally, it requires a physical inventory of the property be taken and results reconciled with the property records at least every two years. Statement of Condition: Record of equipment purchased under the federal program was not maintained in accordance with 2 CFR Section 200.313(d). Statement of Cause: The district was not aware of the requirements. Statement of Effect: The District is not in compliance with 2 CFR Section 200.313(d) and could fail to follow related disposition requirements. Questioned Cost: None. Repeat Finding: No Recommendation: We recommend the District review the above referenced requirements and implement procedures to ensure the District complies with relevant compliance requirements. Views of the Responsible Officials and Planned Corrective Actions: The District has contracted with Questar III BOCES for a complete fix asset inventory which will include the record management of the fixed assets.