NORTH COLONIE CENTRAL SCHOOL DISTRICT

Child Nutrition - Procurement - Information on Federal Program: U.S. Department of Agriculture Child Nutrition Cluster (National School Breakfast Program, School Lunch Program, Supply Chain, Snack, non-cash commodities, Summer Food Service Program, Assistance Listing numbers 10.553, 10.555 and 10.559) 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 for the school lunch fund vendors. 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. 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. Questioned Costs: None Perspective Information: As a result of inquiry, the District performed a review of vendors charged to the school lunch fund, none were suspended or debarred from participation in Federal assistance programs or activities. 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. Views of the Responsible Officials and Planned Corrective Actions: Effective September 15, 2025 the District Treasurer will check the status of all vendors associated to the Child Nutrition program. In cooperation with the Food Service Director, the District Treasurer will review eligibility of any vendors that are requested to be used. Any vendor that is found not to be eligibility list will be reported to the Food Service Director and Purchasing Agent. This list will be updated and checked annually.

Special Education Cluster – Procurement Information on Federal Program: U.S. Department of Education Special Education Cluster (Special Education – Grants to State (IDEA, Part B) and Special Education – Preschool Grants (IDEA Preschool) Assistance Listing numbers 84.027 and 84.173) passed through the New York State Education Department. Criteria: CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additionally, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Statement of Condition: During our discussions with management and testing of various vendors, we noted that the District is not following its procurement procedures for the Special Education program purchases and is not verifying the eligibility of vendors to participate in Federal assistance programs on an annual basis. Statement of Cause: The District did not review compliance requirements related to procurement outlined in 2 CFR Section 200.318 and Section 200.213. Statement of Effect: The District is not in compliance with 2 CFR Section 200.213. The District is not performed required procedures, as a result, vendors that are not eligible for participation in Federal assistance programs or activities could be selected or the District could be overpaying for goods and services. Questioned Costs: None Perspective Information: As part of required procurement testing, a review of vendors charged to the special education cluster and therefore represents purchases with federal dollars was performed. Of the District’s vendors charged to the fund, none were suspended or debarred from participation in Federal assistance programs or activities. Repeat Finding: No Recommendation: We recommend that the District review the requirements of 2 CFR Section 200.213 and ensure that their procurement procedures are being followed and 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. Views of the Responsible Officials and Planned Corrective Actions: As of November 1, 2024, the District will have implemented a process to determine the eligibility of potential vendors to participate in Federal assistance programs or activities prior to disbursing funds.

Title I Information on Federal Program: Title I Grants to Local Agencies, CFDA No. 84.010 Criteria: Compliance under Title I: Grants and Agreements Part 200.430 Compensation-personal services under compliance requirement Allowable Costs/Cost Principles 2. Documentation of Employee Time and Effort. Condition: During our testing of payroll expenditures charged to this program it was noted that two part-time tutors were being charged to this grant. The time and effort reports (payroll certifications) being signed by these individuals acknowledging and noting that their salaries are being allocated to the Federal Program were not maintained by the District. Questioned Cost: None. Context: A selection of eleven employees charged to the Federal Program were tested for verification of wages charged, educational certifications and payroll certifications. Effect: We were unable to review payroll certifications of time and effort reports acknowledged by the employee that their services were being allocated to this Federal Program as the District had not requested them from employees who were operating in a tutor capacity. The amounts paid to the tutors were supported, allowable under the grant, included on the approved grant budget and properly coded to the grant. Cause: While the District has policies and procedures in place requiring completion of payroll certifications there was an oversight causing the District to not obtain the certifications for this type of employee. Perspective Information: Certifications were not required for tutors. Repeat Finding: No Recommendation: We recommend that compensating controls be implemented to monitor compliance with existing policies and procedures to ensure all employees whose time and effort of providing special education services is acknowledged by the payroll certifications. Views of the Responsible Officials and Planned Corrective Actions: The Director of Special Education will ensure that payroll certifications are obtained for all employees with Federal Program allocations.