STO-ROX School District

CONDITION: During my review of the District’s compliance with the laws and regulations related to filing its federal grant program Final Expenditure Reports (FER), I noted that the School District did not file the Final Expenditure Report for the ARP ESSER, ARP ESSER Learning Loss, ARP ESSER Summer Enrichment, and ARP ESSER Afterschool grant programs until November of 2024. The report was required to be filed with the Pennsylvania Department of Education (PDE) no later than 90 days after the end date of the grant period, or within 30 days of expending all grant funding. This is a repeat Finding (2023-001) from the prior fiscal year. CRITERIA: The Department of Education requires the completion and submission of a ‘Final Expenditure Report’ (FER) within 30 days of expending all grant funding. In addition, Section 2 CFR 200.344 of the Uniform Guidance requires the submission of financial reports no later than 90 calendar days after the end date of the grant period for performance. EFFECT: The District is not in compliance with the financial reporting requirements for timely submission of a ‘final expenditure report’ (FER) for its ARP ESSER, ARP ESSER Learning Loss, ARP ESSER Summer Enrichment, and ARP ESSER Afterschool grant programs in accordance with PDE policy and Section 2 CFR 200.344 of the Uniform Guidance. QUESTIONED COST: None CAUSE: As a result of staff turnover, the School District inadvertently did not complete and file the Final Expenditure Reports with PDE in a timely manner. RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions or withholding of grant monies from PDE as a result of not filing these reports in a timely manner. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.

CONDITION: The Sto-Rox School District Did not submit a budget revision to the Pennsylvania Department of Education (PDE) for ARP ESSER in instances where 1) variances to the approved budget exceeded 20 percent by function code (9 instances), 2) function code categories remained unspent (5 instances), and 3) there were expenditures coded to unbudgeted function codes (9 instances). CRITERIA: In accordance with Pennsylvania Department of Education regulations, when the expenditure for a function code (line item) exceeds the last approved budgeted amount by 20% or more, the Schol District must submit a budget revision prior to submitting the Final Expenditure Report. In addition, the School District should not begin new programs/services or spend federal grant funds on expenses other than what is in the approved budget until written approval is obtained from the PDE Division of Federal Programs. EFFECT: The Sto-Rox School District did not comply with PDE regulatory guidance with regard to submitting a budget revision to PDE when the expenditure for a function code (line item) exceeded the last approved budgeted amount by 20% or more, prior to submitting the Final Expenditure Report. In addition, the School District did not comply with PDE regulatory guidance regarding not beginning new programs/services or spending federal grant funds on expenses other than what is in the approved budget until written approval is obtained from the PDE Division of Federal Programs. QUESTIONED COST: None CAUSE: As a result of staff turnover, the School District inadvertently did not comply with PDE regulatory guidance for the submission of budget revisions and spending in non-approved budgetary categories. RECOMMENDATION: I am recommending that the management of the School District implement procedures, as a matter of policy, for the timely submission of budget revisions to PDE when the expenditure for a function code (line item) exceeds the last approved budgeted amount by 20% or more, prior to submitting the Final Expenditure Report. In addition, the implemented procedures should ensure that the School District has measures in place for not beginning new programs/services or spending federal grant funds on expenses other than what is in the approved budget until written approval is obtained from the PDE Division of Federal Programs. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.

CONDITION: During my review of a random sample of eleven (11) invoices related to the District’s expenditure of federal funds, I noted that there was not an approved purchase order issued in eight (8) of those instances. This is a repeat Finding (2023-003) from the prior fiscal year. CRITERIA: In accordance with the District’s Procurement Policy for Federal Programs (#626.5), the District shall use properly prepared and approved purchase orders for federal purchases. In addition, Section 2 CFR 200.403(g) of the Uniform Guidance requires that all expenditures (costs) must be adequately documented. EFFECT: The District did not comply with the District’s Procurement Policy for Federal Programs (#626.5), or Section 2 CFR 200.403(g) of the Uniform Guidance, regarding the use of purchase orders and the adequate documentation of federal expenditures. QUESTIONED COST: None CAUSE: Management of the District did not properly interpret the provisions of its Procurement Policy for Federal Programs to include the use of purchase orders for federal expenditures in all instances. RECOMMENDATION: I recommend that the District utilize properly prepared and approved purchase orders for all future federal program purchases in compliance with its Procurement Policy for Federal Programs (#626.5) and Section 2 CFR 200.403(g) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.

CONDITION: During the PDE monitoring review of the ARP ESSER grant program, it was noted that the School District did not document in writing its rationale for the noncompetitive procurement of services provided by J. Martin & Associates. CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: $131,851 CAUSE: It was not readily determinable as to why the District did not adhere to its Procurement Policy for Federal Programs (#626.5) which addresses the issue of noncompetitive procurement as outline in Section 2 CFR 200.320(c’). RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, the School District adhere to Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement, as well as the District’s Procurement Policy for Federal Programs (#626.5). VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.

CONDITION: During my review of the District’s compliance with the requirements of the Public-School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, were obtained for the following vendors: Pittsburgh Area Community Schools Deborah Coppula Allegheny Intermediate Unit CRITERIA: In accordance with 24 PA Statute 8.807.1, the District must obtain/document at least three (3) written or well documented price or rate quotations from a reasonable number of qualified sources for purchases of goods between $10,000 and $22,500 (threshold established annually). In addition, Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance requires price or rate quotations to be received from an adequate number of qualified sources for purchases above the micro purchase threshold of $10,000 and the simplified acquisition threshold of $250,000. EFFECT: The District did not comply with 1) the District’s Procurement Policy for Federal Programs (#626.5), 2) the 24 PA Statute 8.807.1, and 3) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000 using federal funding. QUESTIONED COST: Pittsburgh Area Community Schools - $42,000, Deborah Coppula - $30,950, and Allegheny Intermediate Unit - $37,513 CAUSE: District officials responsible for federal procurement did not adhere to District, state and federal policies and regulations regarding the expenditure of federal funds. RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626.5), 2) the 24 PA Statute 8.807.1, and 3) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.

CONDITION: The School District contracted with MHY Family Services for professional services. The contract exceeded the threshold for competitive procurement. The District was unable to provide documentation to verify that the third-party procurement contract was competitively procured, such as a bid evaluation and public solicitation. In addition, the District did not conduct a cost or price analysis for this procurement, which was in excess of the Simplified Acquisition Threshold of $250,000. CRITERIA: Section 2 CFR 200. 318(i) of the Uniform Guidance specifies that the School District must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In addition, Section 2 CFR 200.324(a) of the Uniform Guidance requires the performance of a cost or price analysis in connection with every procurement in excess of the Simplified Acquisition Threshold. CAUSE: It was not readily determinable as to why the District did not adhere to its Procurement Policy for Federal Programs (#626.5) which addresses the issue of competitive procurement as outlined in Section 2 CFR 200. 318(i) and Section 2 CFR 200.324(a). EFFECT: The School District did not comply with the requirements of Sections 2 CFR 200.318(i) and 2 CFR 200.324(a) of the Uniform Guidance with regard to maintaining sufficient records to detail the history of procurement and conducting a cost or price analysis for procurement in excess of the Simplified Acquisition Threshold. QUESTIONED COST: $242,703 RECOMMENDATION: I am recommending that the management of the School District review and update as necessary its procurement policies to ensure retention of the appropriate procurement documentation, in all instances, so as to comply with all applicable sections of the Uniform Guidance, specifically, Section 2 CFR 200.318(i) of the Uniform Guidance. In addition, I recommend that the School District conduct a cost or price analysis for all procurement in excess of the Simplified Acquisition Threshold of $250,000 before receiving bids or proposals in accordance with Section 2 CFR 200.324(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.

CONDITION: During my review of the District’s compliance with the laws and regulations related to filing its federal grant program Final Expenditure Reports (FER), I noted that the School District did not file the Final Expenditure Report for the ESSER II grant program until February 9, 2024. The report was required to be filed with the Pennsylvania Department of Education (PDE) no later than 90 days after the end date of the grant period (September 30, 2023), or within 30 days of expending all grant funding. CRITERIA: The Department of Education requires the completion and submission of a ‘Final Expenditure Report’ (FER) within 30 days of expending all grant funding. In addition, Section 2 CFR 200.344 of the Uniform Guidance requires the submission of financial reports no later than 90 calendar days after the end date of the grant period for performance. EFFECT: The District is not in compliance with the financial reporting requirements for timely submission of a ‘final expenditure report’ (FER) for its ESSER II grant program in accordance with PDE policy and Section 2 CFR 200.344 of the Uniform Guidance. QUESTIONED COST: None CAUSE: It was not readily determinable as to why the School District had not completed and filed the ‘Final Expenditure Report’ with PDE in a timely manner. RECOMMENDATION: I recommend that the District develop fiscal procedures to ensure that ‘Final Expenditure Reports’ for future fiscal years are completed and filed in a timely manner based on supporting financial information obtained from the District’s business office, in order to 1) comply with PDE reporting requirements for the District’s applicable federal programs, and 2) to avoid any future sanctions or withholding of grant monies from PDE as a result of not filing these reports in a timely manner. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.

CONDITION: The Sto-Rox School District does not take affirmative action steps to ensure that minority businesses, women’s business enterprises, and labor surplus area firms are used, when possible, in the procurement process. CRITERIA: In accordance with Section 2 CFR 200.321(a) of the Uniform Guidance, the District must take all necessary affirmative action steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible. Section 2 CFR 200.321(a) of the Uniform Guidance outlines the six (6) affirmative steps to follow. EFFECT: The Sto-Rox School District did not comply with the requirements of Section 2 CFR 200.321(a) of the Uniform Guidance regarding required affirmative action steps to be employed in the procurement process. QUESTIONED COST: None CAUSE: School District personnel stated that these businesses are considered but recognized that no affirmative action steps are currently employed to solicit these businesses. RECOMMENDATION: I am recommending that the management of the School District implement, as a matter of policy, the six (6) affirmative action steps as stated Section 2 CFR 200.321(a) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: Management of the School District has reviewed the above noted finding and recommendation and have developed a corresponding ‘Corrective Action Plan’ to address this matter (See Corrective Action Plan).

CONDITION: During my review of a random sample of thirty-three (33) invoices related to the District’s expenditures of federal funds, I noted that there was not an approved purchase order issued in twenty-six (26) of those instances. CRITERIA: In accordance with the District’s Procurement Policy for Federal Programs (#626.5), the District shall use properly prepared and approved purchase orders for federal purchases. In addition, Section 2 CFR 200.403(g) of the Uniform Guidance requires that all expenditures (costs) must be adequately documented. EFFECT: The District did not comply with the District’s Procurement Policy for Federal Programs (#626.5), or Section 2 CFR 200.403(g) of the Uniform Guidance, regarding the use of purchase orders and the adequate documentation of federal expenditures. QUESTIONED COST: None CAUSE: Management of the District did not properly interpret the provisions of its Procurement Policy for Federal Programs to include the use of purchase orders for federal expenditures in all instances. RECOMMENDATION: I recommend that the District utilize properly prepared and approved purchase orders for all future federal program purchases in compliance with its Procurement Policy for Federal Programs (#626.5) and Section 2 CFR 200.403(g) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.

CONDITION: During my review of the District's compliance with the requirements of the Public School Code and the Uniform Guidance for procurement of goods and services, the District was unable to provide documentation or other evidence that three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000, were obtained for the following vendors: IXL Learning $15,300 Allegheny Intermediate Unit $36,000, AIM Institute $18,750, J. Martin & Associates $137,961, Communities in Schools $26,000,The Commission, LLC $246,281 CRITERIA: In accordance with 24 PA Statute 8.807.1, the District must obtain/document at least three (3) written or well documented price or rate quotations from a reasonable number of qualified sources for purchases of goods between $10,000 and $$22,500 (threshold established annually). In addition, Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance requires price or rate quotations to be received from an adequate number of qualified sources for purchases above the micro purchase threshold of $10,000 and the simplified acquisition threshold of $250,000. EFFECT: The District did not comply with 1) the District’s Procurement Policy for Federal Programs (#626.5), 2) the 24 PA Statute 8.807.1, and 3) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000 using federal funding. QUESTIONED COST: $480,292 CAUSE: District officials responsible for federal procurement did not adhere to District, state and federal policies and regulations regarding the expenditure of federal funds. RECOMMENDATION: I recommend that for all future purchases of goods and/or services utilizing federal funds, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626.5), 2) the 24 PA Statute 8.807.1, and 3) Section 2 CFR 200.300(a)(2)(i) of the Uniform Guidance regarding obtaining three price or rate quotations for the purchase of goods between $10,000 and $22,500, and services between $10,000 and $250,000. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.

CONDITION: During my review of the District’s compliance with the requirements for noncompetitive procurement, I noted the District did not document its rationale for purchases made from ‘Communities in Schools’ totaling $26,000.CRITERIA: In accordance with Section 2 CFR 200.318(i) of the Uniform Guidance, the District must maintain records sufficient to detail the history of procurement. These records include but are not limited to the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore, Section 2 CFR 200.320(c’) of the Uniform Guidance details five (5) circumstances in which noncompetitive procurement can be used. EFFECT: The District did not comply with Section 2 CFR 200.318(i) and Section 2CFR 200.320(c’) of the Uniform Guidance regarding the proper documentation required for noncompetitive procurement. QUESTIONED COST: $26,000 CAUSE: It was not readily determinable as to why the District did not adhere to its Procurement Policy for Federal Programs (#626.5) which addresses the issue of noncompetitive procurement as outline in Section 2 CFR 200.320(c’). RECOMMENDATION: I recommend that for all future purchases involving noncompetitive procurement, that the District adhere to the requirements of 1) the District’s Procurement Policy for Federal Programs (#626.5), and 2) Section 2 CFR 200.320(c) of the Uniform Guidance. VIEWS OF RESPONSIBLE OFFICIALS: The School District concurs with the above noted finding and addresses this issue in the ‘Corrective Action Plan’ included within this report.

During my review of District?s compliance with the laws and regulations related to its participation in the Title I grant program, I noted that the School District did not complete and submit the required Title I `final expenditure report? (FER) for the 2018-2019 grant program year.

: During my review of the District?s `Reconciliation of Cash on Hand Quarterly Reports? for the 2018-2019 fiscal year, I noted that although the reports were supported by a spreadsheet detailing the expenditures, no underlying documentation from the general ledger was available and in one case no expenditures were listed on the report although the general ledger reflected expenditures.