Jamesville-Dewitt Central School District

Condition: The District did not comply with the required standards of Support and Salaries and Wages because employees whose time was charged to Education Stabilization Fund grants during the fiscal year did not complete monthly or semi-annual time certification forms or personnel activity reports (PAR) for their time distribution. Criteria: The distribution of 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 lease 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).) 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 or semi-annual certifications and that the time allocation on the grant is reported accurately. 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. Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management require that copies of these payroll certifications be forwarded to the District Treasurer on a timely basis and that they are reviewed for accuracy. Views of Responsible Official and Planned Corrective Actions: The District agrees with this recommendation. Brian Bartlett, School Business Administrator has reviewed the requirement with the District’s Payroll Coordinator, District Treasurer and Deputy Treasurer to ensure that all staff paid out of Federal grants are accompanied with the appropriate certification form or PAR. The District will review staff currently being funded through any Federal grant during 2023-24 is completing a certification form, which will be filed with the applicable grant going forward. This will be the responsibility of the District Treasurer and this change will be completed by June 30, 2024.

Condition: The District was not in compliance with the level of effort requirements as annual maintenance of effort calculations were not prepared and provided to NYSED timely to ensure that the level of expenditures for the education of children with disabilities made by the Local Educational Agency (LEA) from local funds, or a combination of State and local funds, was not less than 90% of the combined fiscal effort for the preceding fiscal year. Criteria: To meet the eligibility standards for an award for a fiscal year, the LEA must budget for the education of children with disabilities at least the same amount, from at least one of the following sources, as the LEA spent for that purpose from the same source for the most recent fiscal year for which information is available: (a) local funds only; (b) the combination of State and local funds; (c) local funds only on a per capita basis; or (d) the combination of State and local funds on a per capita basis. If an LEA fails to maintain its level of expenditures for the education of children of children with disabilities in accordance with 34 CFR section 300.203(b), the SEA is liable in a recovery action under Section 452 of the General Education Provisions Act (20 USC 1234a) to return to the Department of Education, using non-Federal funds, an amount equal to the amount by which the LEA failed to maintain its level of expenditures in accordance with the compliance standard in that fiscal year, or the amount of the LEA's Part B sub grant in that fiscal year, whichever is lower ((34 CFR Section 300.203(d)). Cause: Due to turnover in staffing, the applicable Maintenance of Effort calculations were prepared for the 2022-2023 year subsequent to year-end. Effect: The District did not provide the required calculation to NYSED with the annual grant application, and therefore did not evaluate whether the District met the requirements upon application submission, which would result in the District having to return any funds expended. Recommendation: It is recommended that the District implement processes and procedures to ensure the annual maintenance of effort calculation is properly completed within the required timeline provided by NYSED and level of effort compliance requirements have been maintained. Views of Responsible Official and Planned Corrective Actions: The District agrees with this recommendation. Brian Bartlett, School Business Administrator, will be responsible for ensuring the maintenance of effort (MOE) calculation is completed within the required timeline provided by NYSED. The MOE calculation for 2022-23 was submitted to NYSED and evidenced that the District was in compliance with the grant regulations. This will be corrected by June 30, 2024.

2022-001 Oversight of Cash Disbursement ProcessCriteria: Standards for Internal Control in New York State Government (March 2016) issued by the New York State Comptroller are expected to be adhered to by all governmental agencies in New York State, including school districts. The standards are based on the framework developed by COSO, the Internal Control-integrated framework (the Framework). Principle 3 of the framework states that management establishes, with board oversight, structures, reporting lines, and appropriate authorities and responsibilities in the pursuit of objectives.Condition: Throughout 2021-2022 the District inadvertently remitted 29 duplicate checks to vendors approximating $30,800.Cause: Invoices were entered into the District?s financial software using extra characters such as dashes, periods or zeros allowing the invoices to be processed twice. The District?s claims audit process and standard review procedures did not include steps to identify the duplication.Effect: The District duplicated payments to vendors of approximately $30,800 throughout the 2021-2022 school year.Recommendation: We recommend the District review and enhance its current policies and procedures surrounding the cash disbursement process, including training for personnel and claims auditor to strengthen internal controls over disbursements.Views of Responsible Official and Planned Corrective Actions: The District will provide accounts payable training to the accounts payable clerk, claims auditor, and any other individuals involved in the process. In addition the district will review the purchasing policies to ensure they are providing the internal controls necessary to protect the district's funds, and that they are being followed. The District will also enhance the use of purchase orders, and become less dependent on claims forms when possible.

Condition: The District has been awarded several federal grants which allow personnel to be directly charged as a grant expense. Personnel charged to the grant are determined by the District and are outlined in the grant budget submitted to New York State. A spelling error on the budget resulted in the incorrect employee being charged to the grant at the correct rate. Criteria: Individuals charged to federal programs within the financial software must match approved budgets for awarded grants. Cause: This error was isolated to one employee that shared the same last name as another employee. The correct employee worked under the grant and the approved salary was charged appropriately to the grant. Effect: Financial records relating to the grant indicate that the incorrect employee was charged to the program within the financial software system only. Recommendation: We recommend the District implement policies and procedures to enhance its oversight and review of grant expenses charged periodically throughout the year to ensure the correct employees and vendors are charged in accordance with approved budgets. Views of Responsible Official and Planned Corrective Actions: The District will reinforce the review and oversight of personnel charged to grants periodically throughout the year to ensure the financial software agrees to the approved budget expenditures.