EIN: 381790200
UEI: ZEP1F7J2CGC7
Audited by: GABRIDGE & CO., PLC
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 January 22, 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 July 22, 2026 (43 days ago).
What is a management decision? →FAC accepted this audit on December 3, 2024 — management decision was due June 3, 2025.
FAC accepted this audit on November 27, 2023 — management decision was due May 27, 2024.
FAC accepted this audit on January 10, 2023 — management decision was due July 10, 2023.
The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Criteria: 2 CFR 200.430(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements identified in this section, these records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and (v) comply with the established accounting policies and practices of the District. Cause: The District?s oversight of payroll charges on the Title I, Part A grant was insufficient. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $2,234 Unallowed/Allowable Cost Principles ? Time and Effort Reporting Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Condition: The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Criteria: 2 CFR 200.430(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements identified in this section, these records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and (v) comply with the established accounting policies and practices of the District. Cause: The District?s oversight of payroll charges on the Title I, Part A grant was insufficient. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $2,234
Show full finding ▾Hide full finding ▴Unallowed/Allowable Cost Principles ? Time and Effort Reporting Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Condition: The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Criteria: 2 CFR 200.430(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements identified in this section, these records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and (v) comply with the established accounting policies and practices of the District. Cause: The District?s oversight of payroll charges on the Title I, Part A grant was insufficient. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $2,234 Unallowed/Allowable Cost Principles ? Time and Effort Reporting Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Condition: The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Criteria: 2 CFR 200.430(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements identified in this section, these records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and (v) comply with the established accounting policies and practices of the District. Cause: The District?s oversight of payroll charges on the Title I, Part A grant was insufficient. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $2,234
Department: Grants Condition: The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Corrective Action: At the start of the 2022-23 school year BHAS implemented a new process to monitor staff salaries funded using title funds. An online platform was created for staff to fill out and submit ?Time and Effort? logs to their building principals for signature All staff funded in this manner were required to attend a 30-minute PD about how to fill out their logs each week and how to submit online to their principals. Once principals reviewed logs, they upload them to a shared drive folder created by building, month, and weekending. Grant Coordinator and Grant Account then reviews folders on a monthly basis and if individual logs are missing a notice is sent to that building principal and individual to complete and submit missing ?Time and Effort? sheet. Person(s) Responsible for Executing Corrective Action: ? Grant Coordinator ? Grant Accountant ? Building Principals ? Funded Staff Member Anticipated Completion Date: 12/31/22
The District did not record expenditures to the 2020-21 or 2021-22 grants in a timely manner, and internal controls over expenditures charged were not in place throughout the period during which such charges were incurred. Expenditures reported for the Title II, Part A grant in their submission to the Michigan Department of Education?s Financial Information Database (FID) did not agree with expenditures reported in the schedule of expenditures of Federal awards (SEFA) for the same period, as the District did not provide accurate information to the auditors nor did they prepare an accurate SEFA. Criteria: 2 CFR 200.510(b) requires that an auditee prepare a SEFA for the period covered by the financial statements which must include the total Federal awards expended for each program. In addition, 2 CFR 200.303 requires that an auditee establish and maintain effective internal control over the Federal award that provides reasonable assurance of compliance with Federal statutes, regulations, and the terms and conditions of the award. Cause: The District incurred expenditures throughout the fiscal year, however, did not determine Title II, Part A charges until prior to submission of the Final Expenditure Report for the grant, and did not inform their auditors of differences between federal revenue recognized and expenditure recorded during the same period. Effect: The District?s SEFA was not accurate for the fiscal year ending June 30, 2021, and adjustments were needed in the current year to correct Title II, Part A expenditures previously recorded. In addition, the FID submission to MDE reflected revenue recorded to Title II, Part A that did not agree with expenditures recorded to the associated grant code. Questioned Costs: $0 Recommendation: We recommend that the District record expenditures to federal grants throughout the fiscal year, as such expenditures are incurred, and prepare an accurate SEFA for auditor review. View of Responsible Officials: The District agrees with the recommendation and will implement internal controls to address the stated condition.
Show full finding ▾Hide full finding ▴Inaccurate SEFA and Internal Control over Compliance Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.367 Title II, Part A Condition: The District did not record expenditures to the 2020-21 or 2021-22 grants in a timely manner, and internal controls over expenditures charged were not in place throughout the period during which such charges were incurred. Expenditures reported for the Title II, Part A grant in their submission to the Michigan Department of Education?s Financial Information Database (FID) did not agree with expenditures reported in the schedule of expenditures of Federal awards (SEFA) for the same period, as the District did not provide accurate information to the auditors nor did they prepare an accurate SEFA. Criteria: 2 CFR 200.510(b) requires that an auditee prepare a SEFA for the period covered by the financial statements which must include the total Federal awards expended for each program. In addition, 2 CFR 200.303 requires that an auditee establish and maintain effective internal control over the Federal award that provides reasonable assurance of compliance with Federal statutes, regulations, and the terms and conditions of the award. Cause: The District incurred expenditures throughout the fiscal year, however, did not determine Title II, Part A charges until prior to submission of the Final Expenditure Report for the grant, and did not inform their auditors of differences between federal revenue recognized and expenditure recorded during the same period. Effect: The District?s SEFA was not accurate for the fiscal year ending June 30, 2021, and adjustments were needed in the current year to correct Title II, Part A expenditures previously recorded. In addition, the FID submission to MDE reflected revenue recorded to Title II, Part A that did not agree with expenditures recorded to the associated grant code. Questioned Costs: $0 Recommendation: We recommend that the District record expenditures to federal grants throughout the fiscal year, as such expenditures are incurred, and prepare an accurate SEFA for auditor review. View of Responsible Officials: The District agrees with the recommendation and will implement internal controls to address the stated condition.
Department: Grants & Finance Condition: The District did not record expenditures to the 2020-21 or 2021-22 grants in a timely manner, and internal controls over expenditures charged were not in place throughout the period during which such charges were incurred. Expenditures reported for the Title II, Part A grant in their submission to the Michigan Department of Education?s Financial Information Database (FID) did not agree with expenditures reported in the schedule of expenditures of Federal awards (SEFA) for the same period, as the District did not provide accurate information to the auditors nor did they prepare an accurate SEFA. Corrective Action: Internal controls have been implemented over the purchasing process, all grant expenditures are approved by the Grant Coordinator and Teaching and Learning Department. Grant Coordinator meets on a regular basis with the finance department to ensure that all grant related expenditures are being processed with the correct code and in the correct manner. Any discrepancies that arise are addressed immediately. Person(s) Responsible for Executing Corrective Action: ? Grant Coordinator ? Grant Accountant ? Chief of Teaching and Learning ? Finance Office Designee Anticipated Completion Date: 12/31/22
FAC accepted this audit on December 19, 2021 — management decision was due June 19, 2022.
The District did not maintain effective internal controls over the Nutrition program to ensure the accuracy of meals served, as reported on monthly Claims for Reimbursement. Cause: The District?s oversight of monthly Claims for Reimbursement was not effective in ensuring that meals reported as served were accurate. Effect: Monthly Claims for Reimbursement were in some cases inaccurate, and full meal reimbursements to the extent allowed under the program were not received by the District. Effect: Monthly Claims for Reimbursement were in some cases inaccurate, and full meal reimbursements to the extent allowed under the program were not received by the District. Context: We evaluated meals served per the monthly Claims for Reimbursement report for three months during the audit period, for all schools in the District, and noted the following: ? For 1 of 3 months reviewed, meals served per the Claim for Reimbursement report did not agree with meals served per supporting records. ? Total meals recorded on physical meal count checklists did not consistently agree to the summary spreadsheet used for entry in the Claim for Reimbursement report. Corrective action associated with prior audit finding 2020-003 was implemented in December 2020, upon completion and submission of the fiscal year 2019-20 audit report. The differences noted that led to a repeat finding were for a month prior to December 2020, and no differences were noted for the months tested subsequent to that time during 2021. Recommendation: The District should establish and maintain effective procedures and internal controls that would identify and correct errors prior to requests for reimbursement. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure the accuracy of meal count records.
Show full finding ▾Hide full finding ▴Cash Management ? Inaccurate Meal Counts Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 10.553/10.555/10.559 Child Nutrition Cluster Criteria: 7 CFR 210.8(a) requires that school food authorities establish internal controls which ensure the accuracy of lunch counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include on-site reviews of the meal counting and claiming system employed by each school in the District, comparisons of daily meal counts against data which will assist in the identification of meal counts in excess of the number of meals served each day to children eligible for such meals; and a system for following upon those meal counts which suggest the likelihood of meal counting problems. Condition: The District did not maintain effective internal controls over the Nutrition program to ensure the accuracy of meals served, as reported on monthly Claims for Reimbursement. Cause: The District?s oversight of monthly Claims for Reimbursement was not effective in ensuring that meals reported as served were accurate. Effect: Monthly Claims for Reimbursement were in some cases inaccurate, and full meal reimbursements to the extent allowed under the program were not received by the District. Effect: Monthly Claims for Reimbursement were in some cases inaccurate, and full meal reimbursements to the extent allowed under the program were not received by the District. Context: We evaluated meals served per the monthly Claims for Reimbursement report for three months during the audit period, for all schools in the District, and noted the following: ? For 1 of 3 months reviewed, meals served per the Claim for Reimbursement report did not agree with meals served per supporting records. ? Total meals recorded on physical meal count checklists did not consistently agree to the summary spreadsheet used for entry in the Claim for Reimbursement report. Corrective action associated with prior audit finding 2020-003 was implemented in December 2020, upon completion and submission of the fiscal year 2019-20 audit report. The differences noted that led to a repeat finding were for a month prior to December 2020, and no differences were noted for the months tested subsequent to that time during 2021. Recommendation: The District should establish and maintain effective procedures and internal controls that would identify and correct errors prior to requests for reimbursement. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure the accuracy of meal count records.
Finding Number Federal Programs Audit: 2021-001 Departments: Food Service and Business Office Condition: The District did not maintain effective internal controls over the nutrition program to ensure accuracy of meals served, as reported on monthly claims for reimbursement. General Corrective Action: The District will further improve and monitor internal controls in this area during the 2021-22 fiscal year. Detailed Corrective Action: The junior accountant will work with the District?s auditor to identify 2020-21 inaccuracies, and will work with Sodexo Magic?s Ricardo Carter to improve meal claim accuracy. Person(s) Responsible for Executing Corrective Action: Ricardo Carter and Bryan Lentz Anticipated Completion Date: 6/30/2022
2020-003
The District did not maintain effective internal controls to ensure that amounts budgeted for private school participation in the 2019-20 Consolidated Application were expended as planned. Cause: The District?s oversight of budgeted expenditures was not effective in ensuring that minimum expenditure requirements were met. Effect: Eligible students at participating private schools may not have received equitable Title I, Part A services. Context: The District budgeted for Title I, Part A services to be provided to participating private schools within the District?s boundary as part of their 2019-20 Consolidated Application for Title funds, submitted to MDE. Our review disclosed that there were no related expenditures incurred during the 2020-21 school year. Recommendation: The District should establish and maintain effective internal control procedures that ensure equitable Title I, Part A services are budgeted and expended on behalf of all participating private schools in the District. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure private school participation requirements are met.
Show full finding ▾Hide full finding ▴Special Tests & Provisions - Private School Participation Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Criteria: 34 CFR 200.64 requires that a Local Education Authority (LEA) determine the proportional share of funds available for services for eligible private school children based on the total amount of funds received by the LEA, and that funds expended for such purpose are equitable in comparison to the services and other benefits that the LEA provides to public school children participating in Title I, Part A. Condition: The District did not maintain effective internal controls to ensure that amounts budgeted for private school participation in the 2019-20 Consolidated Application were expended as planned. Cause: The District?s oversight of budgeted expenditures was not effective in ensuring that minimum expenditure requirements were met. Effect: Eligible students at participating private schools may not have received equitable Title I, Part A services. Context: The District budgeted for Title I, Part A services to be provided to participating private schools within the District?s boundary as part of their 2019-20 Consolidated Application for Title funds, submitted to MDE. Our review disclosed that there were no related expenditures incurred during the 2020-21 school year. Recommendation: The District should establish and maintain effective internal control procedures that ensure equitable Title I, Part A services are budgeted and expended on behalf of all participating private schools in the District. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure private school participation requirements are met.
Finding Number Federal Programs Audit: 2021-002 Departments: Grant Office Condition: The District did not maintain effective internal controls to ensure that amounts budgeted for private school participation the 2019-20 Consolidated Application were expended as planned. General Corrective Action: The District will develop and maintain controls to ensure that all eligible students at participating private schools within the District?s boundaries receive equitable Title I, Part A. Detailed Corrective Action: The state and federal (grant) program director, or her successor, will use MDE approved criteria to allocate Title I resources, and will maintain documentation for the ensuing annual, external financial audit. Person(s) Responsible for Executing Corrective Action: The to-be-hired successor to the recently resigned state and federal program director and Jill Latham. Anticipated Completion Date: 6/30/2022
2020-004
FAC accepted this audit on February 2, 2021 — management decision was due August 2, 2021.
The District did not maintain effective internal controls over the Nutrition program to ensure the accuracy of meals served, as reported on monthly Claims for Reimbursement. Cause: The District?s oversight of monthly Claims for Reimbursement was not effective in ensuring that meals reported as served were accurate. Effect: Monthly Claims for Reimbursement were in some cases inaccurate, and full meal reimbursements to the extent allowed under the program were not received by the District. Questioned Costs: $0; net number of meals served were under-requested. Context: We evaluated meals served per the monthly Claims for Reimbursement report for three months during the audit period, for all schools in the District, and noted the following: ? For 3 of 3 months reviewed, meals served per the Claim for Reimbursement report did not agree with meals served per supporting records. ? Total meals recorded on physical meal count checklists did not consistently agree to the summary spreadsheet used for entry in the Claim for Reimbursement report. Recommendation: The District should establish and maintain effective procedures and internal controls that would identify and correct errors prior to requests for reimbursement. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure the accuracy of meal count records
Show full finding ▾Hide full finding ▴Cash Management ? Inaccurate Meal Counts Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 10.553/10.555/10.559 Child Nutrition Cluster Criteria: 7 CFR 210.8(a) requires that school food authorities establish internal controls which ensure the accuracy of lunch counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include on-site reviews of the meal counting and claiming system employed by each school in the District, comparisons of daily meal counts against data which will assist in the identification of meal counts in excess of the number of meals served each day to children eligible for such meals; and a system for following upon those meal counts which suggest the likelihood of meal counting problems. Condition: The District did not maintain effective internal controls over the Nutrition program to ensure the accuracy of meals served, as reported on monthly Claims for Reimbursement. Cause: The District?s oversight of monthly Claims for Reimbursement was not effective in ensuring that meals reported as served were accurate. Effect: Monthly Claims for Reimbursement were in some cases inaccurate, and full meal reimbursements to the extent allowed under the program were not received by the District. Questioned Costs: $0; net number of meals served were under-requested. Context: We evaluated meals served per the monthly Claims for Reimbursement report for three months during the audit period, for all schools in the District, and noted the following: ? For 3 of 3 months reviewed, meals served per the Claim for Reimbursement report did not agree with meals served per supporting records. ? Total meals recorded on physical meal count checklists did not consistently agree to the summary spreadsheet used for entry in the Claim for Reimbursement report. Recommendation: The District should establish and maintain effective procedures and internal controls that would identify and correct errors prior to requests for reimbursement. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure the accuracy of meal count records
Finding Number Federal Programs Audit Department Condition General Corrective Action Detailed Corrective Action Person Responsible for Executing Correction Action Anticipated Completion Date 2020-003 Operations The District did not maintain effective internal controls over the Nutrition program to ensure the accuracy of meals served, as reported on monthly Claims for Reimbursement. The district will improve and monitor internal controls in this area during the 2020-21 fiscal year. Beginning in the 2020-21 fiscal year, the Junior Accountant will review monthly meal claim reports from the food service management company before submitting claims to the State. Bryan Lentz 6/30/2021
2019-003
The District did not maintain effective internal controls to ensure that amounts budgeted for private school participation in the 2018-19 Consolidated Application were expended as planned. Cause: The District?s oversight of budgeted expenditures was not effective in ensuring that minimum expenditure requirements were met. Effect: Eligible students at participating private schools may not have received equitable Title I, Part A services. Questioned costs: $0 Context: The District budgeted for Title I, Part A services to be provided to participating private schools within the District?s boundary as part of their 2018-19 Consolidated Application for Title funds, submitted to MDE. Our review disclosed that actual expenditures for planned private school participation services amounted to less than 5% of the total amount budgeted for such services. Recommendation: The District should establish and maintain effective internal control procedures that ensure equitable Title I, Part A services are budgeted and expended on behalf of all participating private schools in the District. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure private school participation requirements are met.
Show full finding ▾Hide full finding ▴Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Criteria: 34 CFR 200.64 requires that a Local Education Authority (LEA) determine the proportional share of funds available for services for eligible private school children based on the total amount of funds received by the LEA, and that funds expended for such purpose are equitable in comparison to the services and other benefits that the LEA provides to public school children participating in Title I, Part A. Condition: The District did not maintain effective internal controls to ensure that amounts budgeted for private school participation in the 2018-19 Consolidated Application were expended as planned. Cause: The District?s oversight of budgeted expenditures was not effective in ensuring that minimum expenditure requirements were met. Effect: Eligible students at participating private schools may not have received equitable Title I, Part A services. Questioned costs: $0 Context: The District budgeted for Title I, Part A services to be provided to participating private schools within the District?s boundary as part of their 2018-19 Consolidated Application for Title funds, submitted to MDE. Our review disclosed that actual expenditures for planned private school participation services amounted to less than 5% of the total amount budgeted for such services. Recommendation: The District should establish and maintain effective internal control procedures that ensure equitable Title I, Part A services are budgeted and expended on behalf of all participating private schools in the District. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure private school participation requirements are met.
Finding Number Federal Programs Audit Department Condition General Corrective Action Detailed Corrective Action Person Responsible for Executing Correction Action Anticipated Completion Date 2020-004 Grants The District did not maintain effective internal controls to ensure that all amounts budgeted for private school participation in the 2018-19 Consolidated Application were expended as planned. The District will develop and maintain effective internal controls to ensure that all eligible students at participating private schools within the District's boundaries receive equitable Title 1, Part A services. The state and federal grant coordinator will use MDE approved criteria to allocate Title 1 resources, and will maintain documentation for the ensuing annual, external financial audit. Tracy Davis 6/30/2021
2019-004
The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Cause: The District?s oversight of payroll charges on the Title I, Part A grant was insufficient. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $19,855 Context: The District utilized semi-annual time certifications as the control over payroll charges to the Title I, Part A grant. Such certifications identify the employees working on Title I, Part A, and the rate at which they are to be charged to the grant during the specified period. We noted the following during our review of eighteen employees charged to the grant during the audit period: ? 11 of 18 employees were charged to Title I, Part A at a percentage rate that did not agree with semi-annual time certifications. ? 5 of 18 employees were charged to Title I, Part A in the absence of a semi-annual time certification. Recommendation: We recommend that the District establish and adhere to documented time and effort reporting procedures, and maintain effective internal controls that ensure salaries and wages allocated to the Title I, Part A Federal award are based on records that accurately reflect the work performed. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure time and effort reporting is consistent with District policies, and that all charges to the grant are adequately supported.
Show full finding ▾Hide full finding ▴Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Criteria: 2 CFR 200.430(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements identified in this section, these records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and (v) comply with the established accounting policies and practices of the District. Condition: The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Cause: The District?s oversight of payroll charges on the Title I, Part A grant was insufficient. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $19,855 Context: The District utilized semi-annual time certifications as the control over payroll charges to the Title I, Part A grant. Such certifications identify the employees working on Title I, Part A, and the rate at which they are to be charged to the grant during the specified period. We noted the following during our review of eighteen employees charged to the grant during the audit period: ? 11 of 18 employees were charged to Title I, Part A at a percentage rate that did not agree with semi-annual time certifications. ? 5 of 18 employees were charged to Title I, Part A in the absence of a semi-annual time certification. Recommendation: We recommend that the District establish and adhere to documented time and effort reporting procedures, and maintain effective internal controls that ensure salaries and wages allocated to the Title I, Part A Federal award are based on records that accurately reflect the work performed. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure time and effort reporting is consistent with District policies, and that all charges to the grant are adequately supported.
Finding Number Federal Programs Audit Department Condition General Corrective Action Detailed Corrective Action Person Responsible for Executing Correction Action Anticipated Completion Date 2020-005 Grants The District did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. The District will monitor payroll charges to ensure that each employee charged to a Federal grant has the correct time keeping support to substantiate the charges. Tracy will review the time and effort reporting procedures, will update as needed to meet federal requirements, and will monitor compliance. Tracy Davis 6/30/2021
2019-005
The District budgeted 1% of their Title I, Part A allocation for the grant period ending September 30, 2019, however only distributed 57% of the budgeted total. Cause: The District experienced significant turnover during the year of review, resulting in periods of ineffective or absent controls and budget oversight. Effect: The District may not have provided sufficient opportunities for consultation with parents and teachers of eligible pupils. Questioned Costs: $0 Context: The District did not provide sufficient opportunities for consultation with parents and teachers of eligible pupils as it did not spend the resources allocated for this purpose. Recommendation: We recommend that the District establish and maintain effective internal controls over the Title I, Part A program to ensure parental involvement expenditures are consistent with budgeted totals. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure parental involvement requirements are met.
Show full finding ▾Hide full finding ▴Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: Title I, Part A Criteria: Section 1118 of Title I, Part A, and the Michigan Department of Education (MDE), requires that a District provide opportunities for consultation with parents and teachers of eligible pupils. A minimum of 1% of the Title I, Part A allocation must be reserved for this parental involvement, with no less than 95% of the budgeted total distributed during the grant period. Condition: The District budgeted 1% of their Title I, Part A allocation for the grant period ending September 30, 2019, however only distributed 57% of the budgeted total. Cause: The District experienced significant turnover during the year of review, resulting in periods of ineffective or absent controls and budget oversight. Effect: The District may not have provided sufficient opportunities for consultation with parents and teachers of eligible pupils. Questioned Costs: $0 Context: The District did not provide sufficient opportunities for consultation with parents and teachers of eligible pupils as it did not spend the resources allocated for this purpose. Recommendation: We recommend that the District establish and maintain effective internal controls over the Title I, Part A program to ensure parental involvement expenditures are consistent with budgeted totals. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure parental involvement requirements are met.
Finding Number Federal Programs Audit Department Condition General Corrective Action Detailed Corrective Action Person Responsible for Executing Correction Action Anticipated Completion Date 2020-006 Grants The District budgeted 1% of its Title I, Part A allocation for the grant period ending September 30, 2019; however, it only distributed 57% of the budgeted total. The District will ensure that it meets the federally required spend level for parent involvement. Tracy will "calendar" 1-3 reviews of the year-to-date budget to actual data for parent involvement, including one by August 31 of future years, to verify district conformance with federal spend requirements. Tracy Davis 6/30/2021
2019-006
FAC accepted this audit on November 11, 2019 — management decision was due May 11, 2020.
The District does not have a clearly defined, uniform set of written procedures to govern the administration of Federal awards. Whereas written procedures are in place that are specific to certain grants being administered, they do not meet the intent nor content requirements imposed by the Uniform Guidance. Cause: The District?s business office experienced significant turnover during the year, and procedures established by the prior administration were not carried forward. Effect: Control activities performed by the business office staff or other staff involved with the administration of Federal awards were inconsistent, ineffective and, in some cases, nonexistent, increasing the risk of noncompliance with requirements of Federal programs administered by the District. Context: The District had no established, written policies that it followed with regards to Federal grant compliance under the Uniform Guidance. Recommendation: We recommend that the District establish and adhere to a uniform set of Federal Written Procedures, and that such procedures support an effective control environment that provides reasonable assurance that the District is in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Views of Responsible Officials: The District agrees with the finding and will review and revise its written procedures to reflect current policies.
Show full finding ▾Hide full finding ▴2019-002 Internal Control/Federal Written Procedures Repeat of 2018-002 Finding type: Material weakness in internal control over compliance. Program(s) Impacted: 84.010 Title I, Part A 10.553/10.555/10.559 Child Nutrition Cluster Criteria: Uniform Guidance, 2 CFR 200.303, requires that the District establish and maintain effective internal controls over Federal awards that provide reasonable assurance that the non-Federal entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the federal award. Condition: The District does not have a clearly defined, uniform set of written procedures to govern the administration of Federal awards. Whereas written procedures are in place that are specific to certain grants being administered, they do not meet the intent nor content requirements imposed by the Uniform Guidance. Cause: The District?s business office experienced significant turnover during the year, and procedures established by the prior administration were not carried forward. Effect: Control activities performed by the business office staff or other staff involved with the administration of Federal awards were inconsistent, ineffective and, in some cases, nonexistent, increasing the risk of noncompliance with requirements of Federal programs administered by the District. Context: The District had no established, written policies that it followed with regards to Federal grant compliance under the Uniform Guidance. Recommendation: We recommend that the District establish and adhere to a uniform set of Federal Written Procedures, and that such procedures support an effective control environment that provides reasonable assurance that the District is in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Views of Responsible Officials: The District agrees with the finding and will review and revise its written procedures to reflect current policies.
Tracy will obtain an auditor approved template, and will customize it for Benton Harbor Area Schools in collaboration with the CFO.
2018-002
The District did not maintain effective internal controls over the Nutrition program to ensure the accuracy of meals served, as reported on monthly Claims for Reimbursement. Cause: The District?s process for recording, monitoring, and reporting meals served is inconsistent across the District. In addition, intermittent network issues throughout the year necessitated the use of physical meal count checklists in some cases, which are prone to human error. The same checklists are used exclusively at one building in the District, whereas all others utilize point-of-sale technology. Effect: Monthly Claims for Reimbursement were in some cases inaccurate, and full meal reimbursements to the extent allowed under the program were not received by the District. Questioned Costs: $0; number of meals served were under-requested for reimbursement. Context: We reviewed meal count information for three months during the audit period, for all seven schools in the District, and noted the following: ? For 3 of 3 months reviewed, we noted differences between meals claimed on the monthly Claim for Reimbursement and the supporting records: o For the month of October 2018, supporting documentation for meals served did not agree to meals claimed for 1 of 7 schools reviewed. o For the month of March 2019, supporting documentation for meals served did not agree to meals claimed for 5 of 7 schools reviewed. o For the month of May 2019, supporting documentation for meals served did not agree to meals claimed for 7 of 7 schools reviewed. ? Total meals recorded on physical meal count checklists did not always agree with the numbers checked off on the same form, resulting in incorrect meal claims. Recommendation: The District should establish and maintain effective procedures and internal controls that would identify and correct meal count errors prior to requests for reimbursement. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure the accuracy of meal count records.
Show full finding ▾Hide full finding ▴2019-003 Cash Management ? Inaccurate Meal Counts Repeat of 2018-003 Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 10.553/10.555/10.559 Child Nutrition Cluster Criteria: 7 CFR 210.8(a) requires that school food authorities establish internal controls which ensure the accuracy of lunch counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include on-site reviews of the meal counting and claiming system employed by each school in the District, comparisons of daily meal counts against data which will assist in the identification of meal counts in excess of the number of meals served each day to children eligible for such meals; and a system for following upon those meal counts which suggest the likelihood of meal counting problems. Condition: The District did not maintain effective internal controls over the Nutrition program to ensure the accuracy of meals served, as reported on monthly Claims for Reimbursement. Cause: The District?s process for recording, monitoring, and reporting meals served is inconsistent across the District. In addition, intermittent network issues throughout the year necessitated the use of physical meal count checklists in some cases, which are prone to human error. The same checklists are used exclusively at one building in the District, whereas all others utilize point-of-sale technology. Effect: Monthly Claims for Reimbursement were in some cases inaccurate, and full meal reimbursements to the extent allowed under the program were not received by the District. Questioned Costs: $0; number of meals served were under-requested for reimbursement. Context: We reviewed meal count information for three months during the audit period, for all seven schools in the District, and noted the following: ? For 3 of 3 months reviewed, we noted differences between meals claimed on the monthly Claim for Reimbursement and the supporting records: o For the month of October 2018, supporting documentation for meals served did not agree to meals claimed for 1 of 7 schools reviewed. o For the month of March 2019, supporting documentation for meals served did not agree to meals claimed for 5 of 7 schools reviewed. o For the month of May 2019, supporting documentation for meals served did not agree to meals claimed for 7 of 7 schools reviewed. ? Total meals recorded on physical meal count checklists did not always agree with the numbers checked off on the same form, resulting in incorrect meal claims. Recommendation: The District should establish and maintain effective procedures and internal controls that would identify and correct meal count errors prior to requests for reimbursement. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure the accuracy of meal count records.
The Chief Operations Officer will (1) work with Sodexo to ensure that meal counting procedures conform with federal requirements, (2) review monthly meal claim reports before submissions, and (3) work with IT staff to maximize "up time" for the food service point of sale system.
2018-003
The District did not maintain effective internal controls to ensure that all eligible students at participating private schools within the District?s boundaries received equitable Title I, Part A services. Cause: The District experienced significant turnover during the year, resulting in periods of ineffective or absent controls. Effect: Eligible students at participating private schools may not have received equitable Title I, Part A services. Questioned costs: $0 Context: The District budgeted for Title I, Part A services to be provide to participating private schools within the District?s boundary as part of their 2018-19 Consolidated Application for Title funds, submitted to MDE. Our review disclosed the following: ? Supporting documentation was not available to evaluate whether the budgeted total was equitable on a per pupil basis when compared to the average Title I, Part A allocation per public school pupil in the District. ? Supporting documentation was not available to gain assurance that all eligible students at participating private schools were considered and factored into the budgeted total for Title I, Part A services to private schools. Recommendation: The District should establish and maintain effective procedures and internal controls that ensure equitable Title I, Part A services are provided to all eligible students at participating private schools in the District. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure private school participation requirements are met.
Show full finding ▾Hide full finding ▴2019-004 Special Tests & Provisions - Private School Participation Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Criteria: 34 CFR 200.64 requires that a Local Education Authority (LEA) determine the proportional share of funds available for services for eligible private school children based on the total amount of funds received by the LEA, and that funds expended for such purpose are equitable in comparison to the services and other benefits that the LEA provides to public school children participating in Title I, Part A. Condition: The District did not maintain effective internal controls to ensure that all eligible students at participating private schools within the District?s boundaries received equitable Title I, Part A services. Cause: The District experienced significant turnover during the year, resulting in periods of ineffective or absent controls. Effect: Eligible students at participating private schools may not have received equitable Title I, Part A services. Questioned costs: $0 Context: The District budgeted for Title I, Part A services to be provide to participating private schools within the District?s boundary as part of their 2018-19 Consolidated Application for Title funds, submitted to MDE. Our review disclosed the following: ? Supporting documentation was not available to evaluate whether the budgeted total was equitable on a per pupil basis when compared to the average Title I, Part A allocation per public school pupil in the District. ? Supporting documentation was not available to gain assurance that all eligible students at participating private schools were considered and factored into the budgeted total for Title I, Part A services to private schools. Recommendation: The District should establish and maintain effective procedures and internal controls that ensure equitable Title I, Part A services are provided to all eligible students at participating private schools in the District. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure private school participation requirements are met.
The state and federal grant coordinator will use MDE approved criteria to allocate Title 1 resources, and will maintain documentation for the ensuing annual, external financial audit.
The District did not have an established policy for documenting time and effort reporting on Federal awards, and did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Cause: The District experienced significant turnover during the year, resulting in periods of ineffective or absent controls. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $8,057 Context: Whereas we noted in the prior audit that time and effort reporting policies were documented but not adhered to, no such policies were documented and available for our review for the current audit period. Methods utilized to document time and effort reporting and to support salaries and wages charged to the Title I, Part A grant varied at the different schools in the District. Furthermore, we noted the following during our review of sixteen employees charged to the Title I, Part A grant at seven schools in the District: ? At 2 of 7 schools, time and effort documentation was not available to support all employees charged to Title I, Part A during the first half of the school year. ? At 2 of 7 schools, support for time charged to the grant consisted of a weekly class schedule that did not provide necessary detail to support the amount charged to the grant. ? 3 of 16 employees were charged to Title I, Part A at a greater percentage than identified on their time and effort documentation. Recommendation: We recommend that the District establish and adhere to documented time and effort reporting procedures, and maintain effective internal controls that ensure salaries and wages allocated to the Title I, Part A Federal award are based on records that accurately reflect the work performed. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure time and effort reporting is consistent with District policies, and that all charges to the grant are adequately supported.
Show full finding ▾Hide full finding ▴2019-005 Unallowed/Allowable Cost Principles ? Time and Effort Reporting Repeat of 2018-005 Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: 84.010 Title I, Part A Criteria: 2 CFR 200.430(i) requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Among other requirements identified in this section, these records must (i) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, and (v) comply with the established accounting policies and practices of the District. Condition: The District did not have an established policy for documenting time and effort reporting on Federal awards, and did not maintain adequate support documentation to substantiate salaries and wages charged to the Title I, Part A grant. Cause: The District experienced significant turnover during the year, resulting in periods of ineffective or absent controls. Effect: The District is unable to support the accuracy of all expenditures charged to the grant. Questioned Costs: $8,057 Context: Whereas we noted in the prior audit that time and effort reporting policies were documented but not adhered to, no such policies were documented and available for our review for the current audit period. Methods utilized to document time and effort reporting and to support salaries and wages charged to the Title I, Part A grant varied at the different schools in the District. Furthermore, we noted the following during our review of sixteen employees charged to the Title I, Part A grant at seven schools in the District: ? At 2 of 7 schools, time and effort documentation was not available to support all employees charged to Title I, Part A during the first half of the school year. ? At 2 of 7 schools, support for time charged to the grant consisted of a weekly class schedule that did not provide necessary detail to support the amount charged to the grant. ? 3 of 16 employees were charged to Title I, Part A at a greater percentage than identified on their time and effort documentation. Recommendation: We recommend that the District establish and adhere to documented time and effort reporting procedures, and maintain effective internal controls that ensure salaries and wages allocated to the Title I, Part A Federal award are based on records that accurately reflect the work performed. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure time and effort reporting is consistent with District policies, and that all charges to the grant are adequately supported.
Tracy will review the time and effort reporting procedures, will update as needed to meet federal requirements, and will monitor compliance.
2018-005
The District budgeted 1% of their Title I, Part A allocation for the grant period ending September 30, 2018, however only distributed 42% of the budgeted total. Cause: The District experienced significant turnover during the year, resulting in periods of ineffective or absent controls. Effect: The District may not have provided sufficient opportunities for consultation with parents and teachers of eligible pupils. Questioned Costs: $0 Context: The District did not provide sufficient opportunities for consultation with parents and teachers of eligible pupils as it did not spend the resources allocated for this purpose. Recommendation: We recommend that the District establish and maintain effective internal controls over the Title I, Part A program to ensure parental involvement expenditures are consistent with budgeted totals. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure parental involvement requirements are met.
Show full finding ▾Hide full finding ▴2019-006 Parental Involvement Finding Type: Material weakness in internal control over compliance and noncompliance with laws and regulations. Program(s) Impacted: Title I, Part A Criteria: Section 1118 of Title I, Part A, and the Michigan Department of Education (MDE), requires that a District provide opportunities for consultation with parents and teachers of eligible pupils. A minimum of 1% of the Title I, Part A allocation must be reserved for this parental involvement, with no less than 95% of the budgeted total distributed during the grant period. Condition: The District budgeted 1% of their Title I, Part A allocation for the grant period ending September 30, 2018, however only distributed 42% of the budgeted total. Cause: The District experienced significant turnover during the year, resulting in periods of ineffective or absent controls. Effect: The District may not have provided sufficient opportunities for consultation with parents and teachers of eligible pupils. Questioned Costs: $0 Context: The District did not provide sufficient opportunities for consultation with parents and teachers of eligible pupils as it did not spend the resources allocated for this purpose. Recommendation: We recommend that the District establish and maintain effective internal controls over the Title I, Part A program to ensure parental involvement expenditures are consistent with budgeted totals. View of Responsible Officials: The District agrees with the finding and will establish effective controls to ensure parental involvement requirements are met.
Tracy will "calendar" 1-3 reviews of the year-to-date budget to actual data for parent involvement to verify district conformance with federal spend requirements.
FAC accepted this audit on October 31, 2018 — management decision was due May 1, 2019.
GSA_MIGRATION
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2017-002
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2017-003
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FAC accepted this audit on November 8, 2017 — management decision was due May 8, 2018.
GSA_MIGRATION
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2016-008
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Show full finding ▾Hide full finding ▴FAC accepted this audit on October 31, 2016 — management decision was due May 1, 2017.
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2015-004
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2015-006
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