School District of the City of YorkLocal Government

Criteria: Federal Regulation 2 CFR section 215.34 requires equipment records shall be maintained accurately. Further a physical inventory of equipment purchased with federal grant funds shall be taken and the results reconciled with the equipment records at least once every two years. The recipient shall verify the existence, current utilization, and continued need for the equipment. Condition: As a result of our testing, we noted that the District maintained equipment records, but the District did not specify funding with which the equipment was purchased, the cost of the equipment, the percentage of Federal participation in the costs, as well as the actual acquisition date of the equipment items. ZA was unable to ensure the accuracy and completeness of the records and also noted that the District does not have policies in place to ensure the security of these items. During the testing performed, ZA noted that there is not consistent record keeping process among the schools within the District. Cause: The District did not maintain proper records documenting equipment purchased with Federal Funds. The District does not have adequate procedures in place to ensure compliance with Federal equipment and real property compliance requirements of the Title I, Part A and IDEA, Part B programs. Effect: Adequate internal controls are not in place and the District is not in compliance with Federal Equipment and Real Property compliance requirements of the Title I, Part A and IDEA, Part B programs. The finding was a repeat of Finding 2020-001 in the prior year. Questioned Costs: Questioned costs, if any, are undeterminable. Recommendation: Procedures should be developed to ensure that the District is following the state and federal requirements on physical inventory control and management of equipment. The District should indicate how to properly track equipment in their policy manual. The District?s property policy needs to be expanded in order for equipment to be tracked the same way for all schools located within the District. District?s Response: The District?s Technology Department has updated its inventory of equipment to improve the tracking of equipment purchased with federal as well as other fund sources. The District is continuing its effort to implement a new comprehensive fixed asset system that coordinates with the District?s accounting system.

Criteria: The District is required to perform procedures to ensure that a provider is neither suspended nor debarred prior to entering into a covered transaction. This may be accomplished by checking the System for Award Management Exclusions, collecting a certification from the entity, or adding a clause or condition to the covered transaction with the entity. Condition: As a result of our testing, we noted the District entered into covered transactions with two providers without performing procedures to ensure that the providers were not suspended or debarred. Cause: The District does not have adequate procedures in place to ensure compliance with Federal Procurement and Suspension and Debarment compliance requirements. Effect: Adequate internal controls are not in place and the District is not in compliance with Federal Procurement and suspension and Debarment compliance requirements. The finding was a repeat of Finding 2020-003 in the prior year. Questioned Costs: Questioned costs, if any, are undeterminable. Recommendation: Procedures should be implemented to ensure that a provider is neither suspended nor debarred prior to entering into a covered transaction. District?s Response: The District has updated its procurement procedures to ensure that a provider is neither suspended nor debarred prior to entering into a covered transaction. The District will ensure that all required components are in the contract. The Special Education Director or designated Executive Secretary will verify that the provider is in good standing by checking the System for Award Management Exclusions.

Criteria: The District is required to file Reconciliation of Cash on Hand Quarterly Reports (Pennsylvania Department of Education) and Quarterly Subgrantee Cumulative Fiscal Reports (Pennsylvania Commission on Crime and Delinquency) based on the pass-through entity that funds are received from. Reports should be appropriately reviewed prior to submission. Condition: As a result of our testing, we noted that the District?s Cash on Hand Quarterly Reports and Quarterly Subgrantee Cumulative Fiscal Reports did not include proper approval by a person not completing the reports. Cause: The District did not have proper control procedures in place to ensure that Cash on Hand Quarterly Reports and Quarterly Subgrantee Cumulative Fiscal Reports are reviewed prior to submission. Effect: Adequate internal controls are not in place over the Cash Management requirements of the CARES Act, Education Stabilization Fund program. Questioned Costs: Questioned costs, if any, are undeterminable. Recommendation: Procedures should be implemented to ensure the quarterly reports are appropriately reviewed prior to submission. District?s Response: The District will implement an approval process to ensure that quarterly reports are reviewed prior to submission in the future.

Criteria: The District is required to file Reconciliation of Cash on Hand Quarterly Reports (Pennsylvania Department of Education) and Quarterly Subgrantee Cumulative Fiscal Reports (Pennsylvania Commission on Crime and Delinquency) based on the pass-through entity that funds are received from. Reports should be appropriately reviewed prior to submission. Condition: As a result of our testing, we noted that the District did not submit Cash on Hand Quarterly Reports for the portion of this grant passed through the Pennsylvania Department of Education during the year under audit. We also noted that the Quarterly Subgrantee Cumulative Fiscal Report submitted to the Pennsylvania Commission on Crime and Delinquency did not include proper approval by a person not completing the report. Cause: The District did not have proper control procedures in place to ensure that Cash on Hand Quarterly Reports and Quarterly Subgrantee Cumulative Fiscal Reports are reviewed and submitted as required. Effect: Adequate internal controls are not in place and the District is not in compliance with Federal Reporting requirements of the Coronavirus Relief Fund (CARES Act) program. Questioned Costs: Questioned costs, if any, are undeterminable. Recommendation: Procedures should be implemented to ensure the quarterly reports are appropriately reviewed and filed in a timely manner. District?s Response: The District will implement a process to ensure that quarterly reports are reviewed and submitted timely in the future.

Criteria: The District is required to maintain the level of expenditures for the education of children with disabilities made by the District with State and Local Funds at the same level or higher in the current year as the previous year. For a fiscal year in which the federal allocation received by the District exceeds the amount received for the previous fiscal year, the District may reduce the level of State and Local expenditures by not more than 50 percent of the excess. Condition: As a result of our testing, we noted that the District?s expenditures for the education of children with disabilities in the current fiscal year were reduced by more than 50 percent of the increase in federal allocation during the current year to the prior year. Cause: The District did not maintain the required level of State and Local expenditures for the education of children with disabilities. The District does not have adequate procedures in place to ensure compliance with Federal Level of Effort compliance requirements. Effect: Adequate internal controls are not in place and the District is not in compliance with Federal Level of Effort compliance requirements. Questioned Costs: Questioned costs, if any, are undeterminable. Recommendation: Procedures should be implemented to ensure the District meets the required level of State and Local expenditures for the education of children with disabilities made by the District. District?s Response: The District will implement procedures to ensure that the required level of State and Local expenditures is maintained in the future.

Criteria: Federal Regulation 2 CFR section 215.34 requires equipment records shall be maintained accurately. Further a physical inventory of equipment purchased with federal grant funds shall be taken and the results reconciled with the equipment records at least once every two years. The recipient shall verify the existence, current utilization, and continued need for the equipment. Condition: As a result of our testing, we noted that the District maintained equipment records, but the District did not specify funding with which the equipment was purchased, the cost of the equipment, the percentage of Federal participation in the costs, as well as the actual acquisition date of the equipment items. ZA was unable to ensure the accuracy and completeness of the records and also noted that the District does not have policies in place to ensure the security of these items. During the testing performed, ZA noted that there is not consistent record keeping process among the schools within the District. Cause: The District did not maintain proper records documenting equipment purchased with Federal Funds. The District does not have adequate procedures in place to ensure compliance with Federal equipment and real property compliance requirements of the Title I, Part A and IDEA, Part B programs. Effect: Adequate internal controls are not in place and the District is not in compliance with Federal Equipment and Real Property compliance requirements of the Title I, Part A and IDEA, Part B programs. The finding was a repeat of Finding 2019-001 in the prior year. Questioned Costs: Questioned costs, if any, are undeterminable. Recommendation: Procedures should be developed to ensure that the District is following the state and federal requirements on physical inventory control and management of equipment. The District should indicate how to properly track equipment in their policy manual. The District?s property policy needs to be expanded in order for equipment to be tracked the same way for all schools located within the District. District?s Response: The District?s Technology Department has updated its inventory of equipment to improve the tracking of equipment purchased with federal as well as other fund sources. The District is continuing its effort to implement a new comprehensive fixed asset system that coordinates with the District?s accounting system.

Criteria: The District is required to file with the Pennsylvania Department of Education a Final Expenditure Report within 30 days of the close of the grant or as soon as funds are liquidated, whichever comes first. In addition, reports that are filed (i.e. Final Expenditure Report, Cash on Hand Report, etc.) should be adequately supported by accounting or other appropriate records of the District and appropriately reviewed prior to submission. The District is required to file with the Pennsylvania Department of Education the Reconciliation of Cash on Hand Quarterly Reports no later than the 10th working day of the month of submission. Condition: As a result of our testing, we noted that the District did not file the first quarter Title I Cash on Hand Quarterly Report during the year under audit. Cause: The District?s procedures were not properly followed to ensure compliance with Federal Reporting compliance requirements. Effect: Internal controls are not operating effectively and the District is not in compliance with Federal Reporting compliance requirements. Questioned Costs: Questioned costs, if any, are undeterminable. Recommendation: Procedures should be implemented to ensure the quarterly reports are filed in a timely manner. District?s Response: The District has a process in place. The District will make every effort to file the reports in a timely manner in the future.

Criteria: The District is required to perform procedures to ensure that a provider is neither suspended nor debarred prior to entering into a covered transaction. This may be accomplished by checking the System for Award Management Exclusions, collecting a certification from the entity, or adding a clause or condition to the covered transaction with the entity. Condition: As a result of our testing, we noted that the District entered into a covered transaction with one provider without performing procedures to ensure that the provider was not suspended or debarred. Cause: The District does not have adequate procedures in place to ensure compliance with Federal Procurement and Suspension and Debarment compliance requirements. Effect: Adequate internal controls are not in place and the District is not in compliance with Federal Procurement and Suspension and Debarment compliance requirements. Questioned Costs: Questioned costs, if any, are undeterminable. Recommendation: Procedures should be implemented to ensure that a provider is neither suspended nor debarred prior to entering into a covered transaction. District?s Response: The District has updated its procurement procedures to ensure that a provider is neither suspended nor debarred prior to entering into a covered transaction. The District will ensure that all required components are in the contract. The Federal Programs Coordinator will verify that the provider is in good standing by checking the System for Award Management Exclusions.

CFDA # 84.010 Grants to Local Educational Agencies (Title I, Part A) CFDA # 84.027 Special Education Cluster (IDEA, Part B) Criteria: Federal Regulation 2 CFR section 215.34 requires equipment records shall be maintained accurately. Further a physical inventory of equipment purchased with federal grant funds shall be taken and the results reconciled with the equipment records at least once every two years. The recipient shall verify the existence, current utilization, and continued need for the equipment. Condition: As a result of our testing, we noted that the District maintained equipment records, but the District did not specify funding with which the equipment was purchased, the cost of the equipment, the percentage of Federal participation in the costs, as well as the actual acquisition date of the equipment items. ZA was unable to ensure the accuracy and completeness of the records and also noted that the District does not have policies in place to ensure the security of these items. During the testing performed, ZA noted that there is not consistent record keeping process among the schools within the District. Cause: The District did not maintain proper records documenting equipment purchased with Federal Funds. The District does not have adequate procedures in place to ensure compliance with Federal equipment and real property compliance requirements of the Title I, Part A and IDEA, Part B programs. Effect: Adequate internal controls are not in place and the District is not in compliance with Federal Equipment and Real Property compliance requirements of the Title I, Part A and IDEA, Part B programs. The finding was a repeat of Finding 2018-002 in the prior year. Questioned Costs: Questioned costs, if any, are undeterminable. Recommendation: Procedures should be developed to ensure that the District is following the state and federal requirements on physical inventory control and management of equipment. The District should indicate how to properly track equipment in their policy manual. The District?s property policy needs to be expanded in order for equipment to be tracked the same way for all schools located within the District. District?s Response: The District?s Technology Department has updated its inventory of equipment to improve the tracking of equipment purchased with federal as well as other fund sources. The District is continuing its effort to implement a new comprehensive fixed asset system that coordinates with the District?s accounting system.

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