EIN: 371142690
UEI: JS2SAEFFMEN7
Audited by: BAKER TILLY US, LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 15, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 15, 2026 (41 days from today).
What is a management decision? →8. Criteria or specific requirement (including statutory, regulatory, or other citation) "Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). " 9. Condition The auditee did not obtain the required certified payroll reports from contractors in accordance with the Davis‑Bacon Act and related labor standards, nor did the contractors or subcontractors submit the certified payrolls to the U.S. Department of Labor as required. 10. Questioned Costs None noted 11. Context The auditee contracted with Daikin TMI for HVAC work utilizing ESSER Funding. Due to the nature of the contract, prevailing wage requirements were applicable. 12. Effect Without certified payrolls, the entity cannot demonstrate compliance with federal prevailing wage requirements. 13. Cause The vendor East St. Louis School District 189 contracted with had turnover in the accounting department. That position was responsible for uploading certified payrolls to the IDOL as well as sending them to the client with the invoices. The vendor also went through a formal name change in June of 2025 which caused an issuance of a new FEIN and IL Tax ID. During this time, they were not recognized and unable to upload during this time. 14. Recommendation We recommend the auditee establish and enforce procedures to: 1) Obtain certified payrolls from all contractors and subcontractors subject to prevailing wage requirements and 2) Review payrolls for compliance with wage rates and maintain documentation for audit purposes. 15. Management's response See Corrective Action Plan.
Show full finding ▾Hide full finding ▴8. Criteria or specific requirement (including statutory, regulatory, or other citation) "Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). " 9. Condition The auditee did not obtain the required certified payroll reports from contractors in accordance with the Davis‑Bacon Act and related labor standards, nor did the contractors or subcontractors submit the certified payrolls to the U.S. Department of Labor as required. 10. Questioned Costs None noted 11. Context The auditee contracted with Daikin TMI for HVAC work utilizing ESSER Funding. Due to the nature of the contract, prevailing wage requirements were applicable. 12. Effect Without certified payrolls, the entity cannot demonstrate compliance with federal prevailing wage requirements. 13. Cause The vendor East St. Louis School District 189 contracted with had turnover in the accounting department. That position was responsible for uploading certified payrolls to the IDOL as well as sending them to the client with the invoices. The vendor also went through a formal name change in June of 2025 which caused an issuance of a new FEIN and IL Tax ID. During this time, they were not recognized and unable to upload during this time. 14. Recommendation We recommend the auditee establish and enforce procedures to: 1) Obtain certified payrolls from all contractors and subcontractors subject to prevailing wage requirements and 2) Review payrolls for compliance with wage rates and maintain documentation for audit purposes. 15. Management's response See Corrective Action Plan.
Corrective Action Plan Finding No. 2025-003 Condition – The auditee did not obtain the required certified payroll reports from contractors in accordance with the Davis‑Bacon Act and related labor standards, nor did the contractors or subcontractors submit the certified payrolls to the U.S. Department of Labor as required. Plan – The District’s Director of Maintenance, Operations & Risk Management will ensure certified payrolls are submitted with invoices and a copy of the submissions to the US Department of Labor are attached to final pay invoice. Anticipated Date of Completion: 03.06.26 Name of Contact Person: Delfaye Jason, Chief School Business Official
8. Criteria or specific requirement (including statutory, regulatory, or other citation) Federal awards claimed on a reimbursement basis must be limited to allowable costs incurred during the period of performance. Recipients must maintain effective internal controls to ensure charges are accurate, supported, and compliant with federal requirements (2 CFR §200.303 – Internal controls; §200.302 – Financial management; §200.403 – Factors affecting allowability of costs; §200.405 – Allocable costs; §200.344 – Closeout). Under cash management principles, reimbursement must not exceed expenditures incurred. 9. Condition The District submitted an expenditure report for $19,165,569 for the quarter ending March 31, 2025, which included amounts that were properly obligated but not yet expended as of the report date. The District reported $14,638,097 in ESSER funds on the Schedule of Expenditures of Federal Awards (SEFA), resulting in an unsupported difference of $4,527,472. 10. Questioned Costs Questioned costs totaled $4,527,472. 11. Context The District claimed the remaining award amount in the March submission as the liquidation extension for the grant was no longer available. 12. Effect The submission of expenditure reports that include unexpended obligations may result in inaccurate financial reporting and misrepresentation of the District’s use of federal funds. This could impact cash management decisions and compliance monitoring by the pass-through entity. 13. Cause As the ESSER grant period approached expiration, management attempted to maximize remaining available funding by submitting reimbursement requests in advance of incurring related expenditures. The District did not have adequate controls in place to ensure that expenditures were incurred prior to requesting federal reimbursement, as required by program regulations. 14. Recommendation We recommend the District submit claims for reimbursement for expenditures that the District has incurred. 15. Management's response See Corrective Action Plan.
Show full finding ▾Hide full finding ▴8. Criteria or specific requirement (including statutory, regulatory, or other citation) Federal awards claimed on a reimbursement basis must be limited to allowable costs incurred during the period of performance. Recipients must maintain effective internal controls to ensure charges are accurate, supported, and compliant with federal requirements (2 CFR §200.303 – Internal controls; §200.302 – Financial management; §200.403 – Factors affecting allowability of costs; §200.405 – Allocable costs; §200.344 – Closeout). Under cash management principles, reimbursement must not exceed expenditures incurred. 9. Condition The District submitted an expenditure report for $19,165,569 for the quarter ending March 31, 2025, which included amounts that were properly obligated but not yet expended as of the report date. The District reported $14,638,097 in ESSER funds on the Schedule of Expenditures of Federal Awards (SEFA), resulting in an unsupported difference of $4,527,472. 10. Questioned Costs Questioned costs totaled $4,527,472. 11. Context The District claimed the remaining award amount in the March submission as the liquidation extension for the grant was no longer available. 12. Effect The submission of expenditure reports that include unexpended obligations may result in inaccurate financial reporting and misrepresentation of the District’s use of federal funds. This could impact cash management decisions and compliance monitoring by the pass-through entity. 13. Cause As the ESSER grant period approached expiration, management attempted to maximize remaining available funding by submitting reimbursement requests in advance of incurring related expenditures. The District did not have adequate controls in place to ensure that expenditures were incurred prior to requesting federal reimbursement, as required by program regulations. 14. Recommendation We recommend the District submit claims for reimbursement for expenditures that the District has incurred. 15. Management's response See Corrective Action Plan.
Corrective Action Plan Finding No. 2025-004 Condition – The District submitted an expenditure report for $19,165,569 for the quarter ending March 31, 2025, which included amounts that were properly obligated but not yet expended as of the report date. The District reported $14,638,097 in ESSER funds on the Schedule of Expenditures of Federal Awards (SEFA), resulting in an unsupported difference of $4,527,472. Plan – The District will implement additional review processes to ensure material errors are detected and corrected. The District requested all ESSER obligated funds as of March 2025 as directed by the state. Anticipated Date of Completion: 03.06.26 Name of Contact Person: Delfaye Jason, Chief School Business Official
FAC accepted this audit on January 8, 2025 — management decision was due July 8, 2025.
FAC accepted this audit on March 17, 2024 — management decision was due September 17, 2024.
FAC accepted this audit on February 21, 2023 — management decision was due August 21, 2023.
East St. Louis School District 189 50-082-1890-22 SCHEDULE OF FINDINGS AND QUESTIONED COSTS Year Ending June 30, 2022 SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2022 - 001 2. THIS FINDING IS: x New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: COVID-19 - Emergency Connectivity Fund Program 4. Project No.: 2022 5. AL No.: 32.009 6. Passed Through: N/A - Direct Award 7. Federal Agency: Federal Communication Commission 8. Criteria or specific requirement (including statutory, regulatory, or other citation) "According to 47 CFR Section 54.1706(c), ""Emergency Connectivity Fund support for eligible equipment and services is limited to no more than one fixed broadband internet access connection per location, and one connected device and one Wi-Fi hotspot per student, school staff member, or library patron. In addition there is also an ""unmet need"" requirement. According to the ""2022 Compliance Supplement,"" dated April 2022 and released by the Executive Office of the President Office of Management and Budget, ""When schools file for requests for reimbursement, however, they should only request reimbursement for eligible equipment and services provided to students or school staff who would otherwise lack broadband services and/or devices sufficient to engage in remote learning.""" 9. Condition15 Per review of the District's inventory listing containing devices purchased with the Emergency Connectivity Fund Program funding, 876 devices of the 6,000 devices purchased were not distributed to students. This indicates that amounts purchased and requested for reimbursement exceeded the "one device per student or staff member" requirement. The District was unable to provide supporting documentation for the 876 devices to support compliance with the "Special Tests, Restricted Purposes" compliance requirement that states there must be an "unmet need" and that there are "per-user limitations." 10. Questioned Costs16 Questioned costs for assistance listing number 32.009 totaled $324,926. This amount was computed by multiplying the 876 undistributed devices by the cost of each device ($370.92). 11. Context17 Questioned costs were determined by reviewing the inventory listing for all devices funded with the Emergency Connectivity Fund Program. Out of the 6000 devices purchased, 876 were not assigned to a specific student or school staff member. 12. Effect The District purchased extra devices that exceeded the number of students or school staff who lacked current broadband services and/or devices sufficient to engage in remote learning. 13. Cause Lack of authoritative guidance and resources specific to the Emergency Connectivity Funding which was a new federal grant. The District interpreted the guidance provided that they could order additional devices needed to address historically high mobility rate and high rate of damaged, lost or stolen chromebooks unique to their District as a result of economic challenges including a very high proportion of low income students. 14. Recommendation We recommend that the District implement procedures such as additional trainings and correspondence with the federal agency to ensure the grants requirements are being met. 15. Management's response18 See corrective action plan 14 See footnote 11. 15 Include facts that support the deficiency identified on the audit finding (?200.516 (b)(3)). 16 Identify questioned costs as required by ?200.516 (a)(3 - 4). 17 See footnote 12. 18 To the extent practical, indicate when management does not agree with the finding, questioned cost, or both.
Show full finding ▾Hide full finding ▴East St. Louis School District 189 50-082-1890-22 SCHEDULE OF FINDINGS AND QUESTIONED COSTS Year Ending June 30, 2022 SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2022 - 001 2. THIS FINDING IS: x New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: COVID-19 - Emergency Connectivity Fund Program 4. Project No.: 2022 5. AL No.: 32.009 6. Passed Through: N/A - Direct Award 7. Federal Agency: Federal Communication Commission 8. Criteria or specific requirement (including statutory, regulatory, or other citation) "According to 47 CFR Section 54.1706(c), ""Emergency Connectivity Fund support for eligible equipment and services is limited to no more than one fixed broadband internet access connection per location, and one connected device and one Wi-Fi hotspot per student, school staff member, or library patron. In addition there is also an ""unmet need"" requirement. According to the ""2022 Compliance Supplement,"" dated April 2022 and released by the Executive Office of the President Office of Management and Budget, ""When schools file for requests for reimbursement, however, they should only request reimbursement for eligible equipment and services provided to students or school staff who would otherwise lack broadband services and/or devices sufficient to engage in remote learning.""" 9. Condition15 Per review of the District's inventory listing containing devices purchased with the Emergency Connectivity Fund Program funding, 876 devices of the 6,000 devices purchased were not distributed to students. This indicates that amounts purchased and requested for reimbursement exceeded the "one device per student or staff member" requirement. The District was unable to provide supporting documentation for the 876 devices to support compliance with the "Special Tests, Restricted Purposes" compliance requirement that states there must be an "unmet need" and that there are "per-user limitations." 10. Questioned Costs16 Questioned costs for assistance listing number 32.009 totaled $324,926. This amount was computed by multiplying the 876 undistributed devices by the cost of each device ($370.92). 11. Context17 Questioned costs were determined by reviewing the inventory listing for all devices funded with the Emergency Connectivity Fund Program. Out of the 6000 devices purchased, 876 were not assigned to a specific student or school staff member. 12. Effect The District purchased extra devices that exceeded the number of students or school staff who lacked current broadband services and/or devices sufficient to engage in remote learning. 13. Cause Lack of authoritative guidance and resources specific to the Emergency Connectivity Funding which was a new federal grant. The District interpreted the guidance provided that they could order additional devices needed to address historically high mobility rate and high rate of damaged, lost or stolen chromebooks unique to their District as a result of economic challenges including a very high proportion of low income students. 14. Recommendation We recommend that the District implement procedures such as additional trainings and correspondence with the federal agency to ensure the grants requirements are being met. 15. Management's response18 See corrective action plan 14 See footnote 11. 15 Include facts that support the deficiency identified on the audit finding (?200.516 (b)(3)). 16 Identify questioned costs as required by ?200.516 (a)(3 - 4). 17 See footnote 12. 18 To the extent practical, indicate when management does not agree with the finding, questioned cost, or both.
Corrective Action Plan Finding No.: 2022- 001 Condition: Per review of the District's inventory listing containing devices purchased with the Emergency Connectivity Fund Program funding, 876 devices of the 6,000 devices purchased were not distributed to students. This indicates that amounts purchased and requested for reimbursement exceeded the "one device per student or staff member" requirement. The District was unable to provide supporting documentation for the 876 devices to support compliance with the "Special Tests, Restricted Purposes" compliance requirement that states there must be an "unmet need" and that there are "per-user limitations." Plan: When the Emergency Connectivity Fund Program (?ECF?) became available, the district estimated that we needed 6,000 devices in order to meet the needs of students and school staff who would otherwise lack access to connected devices and broadband connections sufficient to engage in remote learning. This estimate was based on the population of students and staff at the time. The estimate also included a provision to address the district?s mobility rate of 13.6% (many students who transferred out of the district did so without returning the resources they had been provided). Additionally, approximately 20%+ of the devices in the past would be returned with damage or would not be returned at all and families were unable to pay for them. It was never the intention of the district to over-order devices. Instead, we had a reasonable expectation (based on the factors listed above), that additional units would be necessary to ensure that no student is left without access to a device so that the district can continue to meet the educational and social-emotional needs of ALL students. As of the date of this response, of the original 876 devices that were not assigned, the district now has only 719 of those devices remaining and fully anticipates the remaining devices to be assigned by the beginning of the 2023-2024 school year (September 2023). Anticipated Date of Completion: September 1, 2023 Name of Contact Person: Jennifer Brumback, Chief Academic Officer Management Response See Above
FAC accepted this audit on June 13, 2022 — management decision was due December 13, 2022.
FAC accepted this audit on December 9, 2020 — management decision was due June 9, 2021.
FAC accepted this audit on January 22, 2020 — management decision was due July 22, 2020.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2019- 002 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Gaining Early Awareness and Readiness for Undergraduate Programs 4. Project No.: P334A140204 5. CFDA No.: 84.334A 6. Passed Through: N/A 7. Federal Agency: Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) Per the Federal Register, Section 404C(b)(1) of the HEA requires partnership grantees under this program to provide from State, local, institutional, or private funds not less than 50 percent of the cost of the program (or $1 of non-Federal funds for $1 of Federal funds awarded), which may be provided in cash or in-kind. In-kind contributions may include equipment and supplies, cash contributions from non-Federal sources, discounted program services and facility usage. The provision also provides that the match may be accrued over the full duration of the grant award period, except that the grantee must make substantial progress towards meeting the matching requirement in each year of the grant award period. 9. Condition The District did not have a formal documented process in place to ensure that the matching requirements for the Gaining Early Awareness and Readiness for Undergraduate Program were being met in accordance with the provisions of the federal award. Based upon our audit procedures we noted that the District did not materially comply with the matching requirements of the award. 10. Questioned Costs During our audit procedures we noted that the District claimed $788,031 during the period under audit for the program. The District was able to substantiate $105,069 of non-federal match expenditures to us during our audit procedures, a shortfall of matching expenditures of $682,962. 11. Context Issue does not appear to be an isolated incident and appears to be the result of improperly designed controls around matching requirements. 12. Effect The District is out of compliance with grant matching requirements. 13. Cause The District did not spend enough non federal monies to meet matching requirements as required by the Federal Register. 14. Recommendation The District should implement a review and tracking of all federal and non federal monies spent in relation to the grant. 15. Management's response See Corrective Action Plan
Show full finding ▾Hide full finding ▴SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2019- 002 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Gaining Early Awareness and Readiness for Undergraduate Programs 4. Project No.: P334A140204 5. CFDA No.: 84.334A 6. Passed Through: N/A 7. Federal Agency: Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) Per the Federal Register, Section 404C(b)(1) of the HEA requires partnership grantees under this program to provide from State, local, institutional, or private funds not less than 50 percent of the cost of the program (or $1 of non-Federal funds for $1 of Federal funds awarded), which may be provided in cash or in-kind. In-kind contributions may include equipment and supplies, cash contributions from non-Federal sources, discounted program services and facility usage. The provision also provides that the match may be accrued over the full duration of the grant award period, except that the grantee must make substantial progress towards meeting the matching requirement in each year of the grant award period. 9. Condition The District did not have a formal documented process in place to ensure that the matching requirements for the Gaining Early Awareness and Readiness for Undergraduate Program were being met in accordance with the provisions of the federal award. Based upon our audit procedures we noted that the District did not materially comply with the matching requirements of the award. 10. Questioned Costs During our audit procedures we noted that the District claimed $788,031 during the period under audit for the program. The District was able to substantiate $105,069 of non-federal match expenditures to us during our audit procedures, a shortfall of matching expenditures of $682,962. 11. Context Issue does not appear to be an isolated incident and appears to be the result of improperly designed controls around matching requirements. 12. Effect The District is out of compliance with grant matching requirements. 13. Cause The District did not spend enough non federal monies to meet matching requirements as required by the Federal Register. 14. Recommendation The District should implement a review and tracking of all federal and non federal monies spent in relation to the grant. 15. Management's response See Corrective Action Plan
Corrective Action Plan Finding No.: 2019- 002 Condition: The District did not have a formal documented process in place to ensure that the matching requirements for the Gaining Early Awareness and Readiness for Undergraduate Program were being met in accordance with the provisions of the federal award. Based upon our audit procedures we noted that the District did not materially comply with the matching requirements of the award. Plan: The District will implement procedures to ensure that matching requirements can be tracked and reviewed/approved by the District administration to ensure compliance with the programs matching requirements. Anticipated Date of Completion: 6/30/2020 Name of Contact Person: Dr. Sherry Whitaker Management Response: N/A
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2019- 003 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Gaining Early Awareness and Readiness for Undergraduate Programs 4. Project No.: P334A140204 5. CFDA No.: 84.334A 6. Passed Through: N/A 7. Federal Agency: Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) According to 2 CFR 200.53(b) an "improper payment includes any payment to an ineligible party, any payment for an ineligible good or service, any duplicate payment, any payment for good or service not received (except for such payments authorized by law), any payment that does not account for credit applicable discounts and any payments where insufficient or lack of documentation prevents reviewer from discerning whether a payment was proper." 9. Condition During the course of performing audit procedures for allowable costs charged to the District?s Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) federal program we noted that certain expenditures charged to the program could not be supported through appropriate documentation. From our inquiry we learned that the District was aware of certain unsupported advancements to the previous GEAR UP director and that these matters were referred to the St. Clair County court system for further evaluation through the judicial process 10. Questioned Costs During testing, known questioned costs for CFDA 84.334A of $14,310.63 were identified. It was noted that a further $32,059.01 was determined to be unsupported from the same employee related to the advancement of past Gear Up funds. This resulted in total questioned costs of $46,369.64. 11. Context Issue does not appear to be an isolated incident and appears to be the result of improperly designed controls around cash disbursements. 12. Effect Effects expose District employees to risk by having to utilize large amounts of cash or other personnel means and substantiate the use of these funds at a later date which can lead to questioned costs. It also exposes the District to potential misappropriation of assets and non-compliance as to the use of state and federal awards. 13. Cause Proper documentation was not provided to support the advancement 14. Recommendation The District institute a policy that no longer allows for the advancement of payment to District employees that requires a reconciliation to be performed at a later date and recommend that the District explore the use of procurement cards as a way for lawful expenditures to be procured by District employees that are consistent with well-defined policy. Establishing a policy around the use of procurement cards and implementing internal controls can improve accountability and reduce the risk of misappropriation of District assets. 15. Management's response See Corrective Action Plan
Show full finding ▾Hide full finding ▴SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2019- 003 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Gaining Early Awareness and Readiness for Undergraduate Programs 4. Project No.: P334A140204 5. CFDA No.: 84.334A 6. Passed Through: N/A 7. Federal Agency: Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) According to 2 CFR 200.53(b) an "improper payment includes any payment to an ineligible party, any payment for an ineligible good or service, any duplicate payment, any payment for good or service not received (except for such payments authorized by law), any payment that does not account for credit applicable discounts and any payments where insufficient or lack of documentation prevents reviewer from discerning whether a payment was proper." 9. Condition During the course of performing audit procedures for allowable costs charged to the District?s Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) federal program we noted that certain expenditures charged to the program could not be supported through appropriate documentation. From our inquiry we learned that the District was aware of certain unsupported advancements to the previous GEAR UP director and that these matters were referred to the St. Clair County court system for further evaluation through the judicial process 10. Questioned Costs During testing, known questioned costs for CFDA 84.334A of $14,310.63 were identified. It was noted that a further $32,059.01 was determined to be unsupported from the same employee related to the advancement of past Gear Up funds. This resulted in total questioned costs of $46,369.64. 11. Context Issue does not appear to be an isolated incident and appears to be the result of improperly designed controls around cash disbursements. 12. Effect Effects expose District employees to risk by having to utilize large amounts of cash or other personnel means and substantiate the use of these funds at a later date which can lead to questioned costs. It also exposes the District to potential misappropriation of assets and non-compliance as to the use of state and federal awards. 13. Cause Proper documentation was not provided to support the advancement 14. Recommendation The District institute a policy that no longer allows for the advancement of payment to District employees that requires a reconciliation to be performed at a later date and recommend that the District explore the use of procurement cards as a way for lawful expenditures to be procured by District employees that are consistent with well-defined policy. Establishing a policy around the use of procurement cards and implementing internal controls can improve accountability and reduce the risk of misappropriation of District assets. 15. Management's response See Corrective Action Plan
Corrective Action Plan Finding No.: 2019- 003 Condition: During the course of performing audit procedures for allowable costs charged to the District?s Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) federal program we noted that certain expenditures charged to the program could not be supported through appropriate documentation. From our inquiry we learned that the District was aware of certain unsupported advancements to the previous GEAR UP director and that these matters were referred to the St. Clair County court system for further evaluation through the judicial process. Plan: The District will explore the use of procurement cards as a way for expenditures to be procured by District employees that are consistent with District policy. Anticipated Date of Completion: 6/30/2020 Name of Contact Person: Dr. Sherry Whitaker Management Response: N/A
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2019- 004 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Teacher and School Leader Incentive Programs 4. Project No.: U374A170042 5. CFDA No.: 84.374 6. Passed Through: N/A 7. Federal Agency: Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) Per the Federal Register, under section 2212(f) of the ESEA, each grant recipient must provide, from non-Federal sources an amount equal to 50 percent of the amount of the grant (which may be provided in cash or in kind) to carry out the activities supported by the grant. 9. Condition The District did not have a formal documented process in place to review non federal monies spent to match the federal portion of the Teacher and School Leader Incentive Program. 10. Questioned Costs None noted - The District was able to provide documentation to support a match of non-federal monies spent on the program. 11. Context Issue does not appear to be an isolated incident and appears to be the result of improperly designed controls around matching requirements. 12. Effect The District could become out of compliance with grant requirements without a properly designed internal control structure that requires formal documented reviews of matching provisions. 13. Cause The District does not have formal documented controls in place to actively monitor and ensure compliance with the matching requirement. 14. Recommendation The District should implement a review and tracking of all federal and non federal monies spent in relation to the grant. 15. Management's response See Corrective Action Plan
Show full finding ▾Hide full finding ▴SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2019- 004 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Teacher and School Leader Incentive Programs 4. Project No.: U374A170042 5. CFDA No.: 84.374 6. Passed Through: N/A 7. Federal Agency: Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) Per the Federal Register, under section 2212(f) of the ESEA, each grant recipient must provide, from non-Federal sources an amount equal to 50 percent of the amount of the grant (which may be provided in cash or in kind) to carry out the activities supported by the grant. 9. Condition The District did not have a formal documented process in place to review non federal monies spent to match the federal portion of the Teacher and School Leader Incentive Program. 10. Questioned Costs None noted - The District was able to provide documentation to support a match of non-federal monies spent on the program. 11. Context Issue does not appear to be an isolated incident and appears to be the result of improperly designed controls around matching requirements. 12. Effect The District could become out of compliance with grant requirements without a properly designed internal control structure that requires formal documented reviews of matching provisions. 13. Cause The District does not have formal documented controls in place to actively monitor and ensure compliance with the matching requirement. 14. Recommendation The District should implement a review and tracking of all federal and non federal monies spent in relation to the grant. 15. Management's response See Corrective Action Plan
Corrective Action Plan Finding No.: 2019- 004 Condition: The District did not have a formal documented process in place to review non-federal monies spent to match the federal portion of the Teacher and School Leader Incentive Program. Plan: The District will formal documented procedures to ensure compliance with matching requirements associated with the program. Anticipated Date of Completion: 6/30/2020 Name of Contact Person: Dr. Sherry Whitaker Management Response: N/A
FAC accepted this audit on January 22, 2020 — management decision was due July 22, 2020.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2019- 002 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Gaining Early Awareness and Readiness for Undergraduate Programs 4. Project No.: P334A140204 5. CFDA No.: 84.334A 6. Passed Through: N/A 7. Federal Agency: Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) Per the Federal Register, Section 404C(b)(1) of the HEA requires partnership grantees under this program to provide from State, local, institutional, or private funds not less than 50 percent of the cost of the program (or $1 of non-Federal funds for $1 of Federal funds awarded), which may be provided in cash or in-kind. In-kind contributions may include equipment and supplies, cash contributions from non-Federal sources, discounted program services and facility usage. The provision also provides that the match may be accrued over the full duration of the grant award period, except that the grantee must make substantial progress towards meeting the matching requirement in each year of the grant award period. 9. Condition The District did not have a formal documented process in place to ensure that the matching requirements for the Gaining Early Awareness and Readiness for Undergraduate Program were being met in accordance with the provisions of the federal award. Based upon our audit procedures we noted that the District did not materially comply with the matching requirements of the award. 10. Questioned Costs During our audit procedures we noted that the District claimed $788,031 during the period under audit for the program. The District was able to substantiate $105,069 of non-federal match expenditures to us during our audit procedures, a shortfall of matching expenditures of $682,962. 11. Context Issue does not appear to be an isolated incident and appears to be the result of improperly designed controls around matching requirements. 12. Effect The District is out of compliance with grant matching requirements. 13. Cause The District did not spend enough non federal monies to meet matching requirements as required by the Federal Register. 14. Recommendation The District should implement a review and tracking of all federal and non federal monies spent in relation to the grant. 15. Management's response See Corrective Action Plan
Show full finding ▾Hide full finding ▴SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2019- 002 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Gaining Early Awareness and Readiness for Undergraduate Programs 4. Project No.: P334A140204 5. CFDA No.: 84.334A 6. Passed Through: N/A 7. Federal Agency: Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) Per the Federal Register, Section 404C(b)(1) of the HEA requires partnership grantees under this program to provide from State, local, institutional, or private funds not less than 50 percent of the cost of the program (or $1 of non-Federal funds for $1 of Federal funds awarded), which may be provided in cash or in-kind. In-kind contributions may include equipment and supplies, cash contributions from non-Federal sources, discounted program services and facility usage. The provision also provides that the match may be accrued over the full duration of the grant award period, except that the grantee must make substantial progress towards meeting the matching requirement in each year of the grant award period. 9. Condition The District did not have a formal documented process in place to ensure that the matching requirements for the Gaining Early Awareness and Readiness for Undergraduate Program were being met in accordance with the provisions of the federal award. Based upon our audit procedures we noted that the District did not materially comply with the matching requirements of the award. 10. Questioned Costs During our audit procedures we noted that the District claimed $788,031 during the period under audit for the program. The District was able to substantiate $105,069 of non-federal match expenditures to us during our audit procedures, a shortfall of matching expenditures of $682,962. 11. Context Issue does not appear to be an isolated incident and appears to be the result of improperly designed controls around matching requirements. 12. Effect The District is out of compliance with grant matching requirements. 13. Cause The District did not spend enough non federal monies to meet matching requirements as required by the Federal Register. 14. Recommendation The District should implement a review and tracking of all federal and non federal monies spent in relation to the grant. 15. Management's response See Corrective Action Plan
Corrective Action Plan Finding No.: 2019- 002 Condition: The District did not have a formal documented process in place to ensure that the matching requirements for the Gaining Early Awareness and Readiness for Undergraduate Program were being met in accordance with the provisions of the federal award. Based upon our audit procedures we noted that the District did not materially comply with the matching requirements of the award. Plan: The District will implement procedures to ensure that matching requirements can be tracked and reviewed/approved by the District administration to ensure compliance with the programs matching requirements. Anticipated Date of Completion: 6/30/2020 Name of Contact Person: Dr. Sherry Whitaker Management Response: N/A
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2019- 003 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Gaining Early Awareness and Readiness for Undergraduate Programs 4. Project No.: P334A140204 5. CFDA No.: 84.334A 6. Passed Through: N/A 7. Federal Agency: Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) According to 2 CFR 200.53(b) an "improper payment includes any payment to an ineligible party, any payment for an ineligible good or service, any duplicate payment, any payment for good or service not received (except for such payments authorized by law), any payment that does not account for credit applicable discounts and any payments where insufficient or lack of documentation prevents reviewer from discerning whether a payment was proper." 9. Condition During the course of performing audit procedures for allowable costs charged to the District?s Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) federal program we noted that certain expenditures charged to the program could not be supported through appropriate documentation. From our inquiry we learned that the District was aware of certain unsupported advancements to the previous GEAR UP director and that these matters were referred to the St. Clair County court system for further evaluation through the judicial process 10. Questioned Costs During testing, known questioned costs for CFDA 84.334A of $14,310.63 were identified. It was noted that a further $32,059.01 was determined to be unsupported from the same employee related to the advancement of past Gear Up funds. This resulted in total questioned costs of $46,369.64. 11. Context Issue does not appear to be an isolated incident and appears to be the result of improperly designed controls around cash disbursements. 12. Effect Effects expose District employees to risk by having to utilize large amounts of cash or other personnel means and substantiate the use of these funds at a later date which can lead to questioned costs. It also exposes the District to potential misappropriation of assets and non-compliance as to the use of state and federal awards. 13. Cause Proper documentation was not provided to support the advancement 14. Recommendation The District institute a policy that no longer allows for the advancement of payment to District employees that requires a reconciliation to be performed at a later date and recommend that the District explore the use of procurement cards as a way for lawful expenditures to be procured by District employees that are consistent with well-defined policy. Establishing a policy around the use of procurement cards and implementing internal controls can improve accountability and reduce the risk of misappropriation of District assets. 15. Management's response See Corrective Action Plan
Show full finding ▾Hide full finding ▴SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2019- 003 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Gaining Early Awareness and Readiness for Undergraduate Programs 4. Project No.: P334A140204 5. CFDA No.: 84.334A 6. Passed Through: N/A 7. Federal Agency: Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) According to 2 CFR 200.53(b) an "improper payment includes any payment to an ineligible party, any payment for an ineligible good or service, any duplicate payment, any payment for good or service not received (except for such payments authorized by law), any payment that does not account for credit applicable discounts and any payments where insufficient or lack of documentation prevents reviewer from discerning whether a payment was proper." 9. Condition During the course of performing audit procedures for allowable costs charged to the District?s Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) federal program we noted that certain expenditures charged to the program could not be supported through appropriate documentation. From our inquiry we learned that the District was aware of certain unsupported advancements to the previous GEAR UP director and that these matters were referred to the St. Clair County court system for further evaluation through the judicial process 10. Questioned Costs During testing, known questioned costs for CFDA 84.334A of $14,310.63 were identified. It was noted that a further $32,059.01 was determined to be unsupported from the same employee related to the advancement of past Gear Up funds. This resulted in total questioned costs of $46,369.64. 11. Context Issue does not appear to be an isolated incident and appears to be the result of improperly designed controls around cash disbursements. 12. Effect Effects expose District employees to risk by having to utilize large amounts of cash or other personnel means and substantiate the use of these funds at a later date which can lead to questioned costs. It also exposes the District to potential misappropriation of assets and non-compliance as to the use of state and federal awards. 13. Cause Proper documentation was not provided to support the advancement 14. Recommendation The District institute a policy that no longer allows for the advancement of payment to District employees that requires a reconciliation to be performed at a later date and recommend that the District explore the use of procurement cards as a way for lawful expenditures to be procured by District employees that are consistent with well-defined policy. Establishing a policy around the use of procurement cards and implementing internal controls can improve accountability and reduce the risk of misappropriation of District assets. 15. Management's response See Corrective Action Plan
Corrective Action Plan Finding No.: 2019- 003 Condition: During the course of performing audit procedures for allowable costs charged to the District?s Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) federal program we noted that certain expenditures charged to the program could not be supported through appropriate documentation. From our inquiry we learned that the District was aware of certain unsupported advancements to the previous GEAR UP director and that these matters were referred to the St. Clair County court system for further evaluation through the judicial process. Plan: The District will explore the use of procurement cards as a way for expenditures to be procured by District employees that are consistent with District policy. Anticipated Date of Completion: 6/30/2020 Name of Contact Person: Dr. Sherry Whitaker Management Response: N/A
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2019- 004 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Teacher and School Leader Incentive Programs 4. Project No.: U374A170042 5. CFDA No.: 84.374 6. Passed Through: N/A 7. Federal Agency: Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) Per the Federal Register, under section 2212(f) of the ESEA, each grant recipient must provide, from non-Federal sources an amount equal to 50 percent of the amount of the grant (which may be provided in cash or in kind) to carry out the activities supported by the grant. 9. Condition The District did not have a formal documented process in place to review non federal monies spent to match the federal portion of the Teacher and School Leader Incentive Program. 10. Questioned Costs None noted - The District was able to provide documentation to support a match of non-federal monies spent on the program. 11. Context Issue does not appear to be an isolated incident and appears to be the result of improperly designed controls around matching requirements. 12. Effect The District could become out of compliance with grant requirements without a properly designed internal control structure that requires formal documented reviews of matching provisions. 13. Cause The District does not have formal documented controls in place to actively monitor and ensure compliance with the matching requirement. 14. Recommendation The District should implement a review and tracking of all federal and non federal monies spent in relation to the grant. 15. Management's response See Corrective Action Plan
Show full finding ▾Hide full finding ▴SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2019- 004 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Teacher and School Leader Incentive Programs 4. Project No.: U374A170042 5. CFDA No.: 84.374 6. Passed Through: N/A 7. Federal Agency: Department of Education 8. Criteria or specific requirement (including statutory, regulatory, or other citation) Per the Federal Register, under section 2212(f) of the ESEA, each grant recipient must provide, from non-Federal sources an amount equal to 50 percent of the amount of the grant (which may be provided in cash or in kind) to carry out the activities supported by the grant. 9. Condition The District did not have a formal documented process in place to review non federal monies spent to match the federal portion of the Teacher and School Leader Incentive Program. 10. Questioned Costs None noted - The District was able to provide documentation to support a match of non-federal monies spent on the program. 11. Context Issue does not appear to be an isolated incident and appears to be the result of improperly designed controls around matching requirements. 12. Effect The District could become out of compliance with grant requirements without a properly designed internal control structure that requires formal documented reviews of matching provisions. 13. Cause The District does not have formal documented controls in place to actively monitor and ensure compliance with the matching requirement. 14. Recommendation The District should implement a review and tracking of all federal and non federal monies spent in relation to the grant. 15. Management's response See Corrective Action Plan
Corrective Action Plan Finding No.: 2019- 004 Condition: The District did not have a formal documented process in place to review non-federal monies spent to match the federal portion of the Teacher and School Leader Incentive Program. Plan: The District will formal documented procedures to ensure compliance with matching requirements associated with the program. Anticipated Date of Completion: 6/30/2020 Name of Contact Person: Dr. Sherry Whitaker Management Response: N/A
FAC accepted this audit on April 28, 2019 — management decision was due October 28, 2019.
FAC accepted this audit on July 29, 2019 — management decision was due January 29, 2020.
FAC accepted this audit on December 12, 2017 — management decision was due June 12, 2018.
FAC accepted this audit on December 12, 2017 — management decision was due June 12, 2018.
FAC accepted this audit on January 25, 2017 — management decision was due July 25, 2017.
FAC accepted this audit on February 28, 2017 — management decision was due August 28, 2017.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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