EIN: 383797280
UEI: L2LKFXJB2UW4
Audited by: Runyon Kersteen Ouellette
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 February 5, 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 August 5, 2026 (29 days ago).
What is a management decision? →The School Unit contracted with schools to provide out-of-district tuition and did not document that the schools were not suspended or debarred as service providers. Cause: Although the School Unit verified the schools were not suspended or debarred through the site Sam.gov, no documentation was maintained to show such verification was performed. Effect: The School Unit is not in compliance with documentation requirements under the Uniform Guidance. Questioned Costs: None Recommendation: Management should ensure that documentation of suspension and debarment checks are maintained annually for all vendors for which suspension and debarment requirements apply. Documentation should be in accordance with the School Unit’s procurement policy and procedures.
Show full finding ▾Hide full finding ▴2025-001 – U.S. Department of Education, For the Period July 1, 2024, through June 30, 2025, Assistance Listing #84.027-84.173 – Internal Controls and Compliance over Special Education Cluster Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended, debarred, or otherwise excluded from participating in the transaction. In addition, under the requirements of fiscal management, grant recipients are required to design and implement internal controls to ensure compliance with grant requirements and their own policies and procedures. Condition: The School Unit contracted with schools to provide out-of-district tuition and did not document that the schools were not suspended or debarred as service providers. Cause: Although the School Unit verified the schools were not suspended or debarred through the site Sam.gov, no documentation was maintained to show such verification was performed. Effect: The School Unit is not in compliance with documentation requirements under the Uniform Guidance. Questioned Costs: None Recommendation: Management should ensure that documentation of suspension and debarment checks are maintained annually for all vendors for which suspension and debarment requirements apply. Documentation should be in accordance with the School Unit’s procurement policy and procedures.
Management’s response/corrective action plan: Management agrees with the finding. The School Unit acknowledges that while suspension and debarment verifications for out-of-district tuition providers were performed through SAM.gov, documentation evidencing those verifications was not formally retained. This occurred because the verification process was conducted as part of normal procurement due diligence; however, procedures did not explicitly require the retention of proof of those checks. RSU 18 will ensure that procedures will require documentation of suspension and debarment checks for all vendors and service providers subject to Uniform Guidance requirements. The school unit will utilize screenshots of vendors search on SAM.gov or signed vendor certifications/attestations as evidence for compliance. The records will be maintained with the Business office and reviewed prior to entering a new contract, renewal, or when required by federal program guidance. Management believes these corrective actions will strengthen internal controls, ensure compliance with Uniform Guidance documentation requirements, and prevent recurrence of this issue in future audit periods.
The School Unit paid for a 5-year software agreement in 2024 and included the software costs in grant reimbursements in 2025. Cause: The payment for the software agreement was recognized as a prepaid expenditure in 2024. However, the entire amount was recognized as an expenditure in 2025 and was included in the calculation of grant reimbursements. Effect: The School Unit was reimbursed for expenditures that had not yet been incurred as the costs were for future services. Known Questioned Costs: $44,800. Recommendation: When reversing prior year prepaid expenditures, management should review the period for which the payment was to ensure the correct amount is recognized in current year expenditures.
Show full finding ▾Hide full finding ▴2025-002 – U.S. Department of Education, For the Period July 1, 2024, through June 30, 2025, Assistance Listing #84.027-84.173 – Internal Controls and Compliance over Special Education Cluster Criteria: Grants through the Department of Education are on a reimbursement basis. In order for a grant expenditure to be eligible for reimbursement, it must be for an allowable expenditure that has been incurred. Condition: The School Unit paid for a 5-year software agreement in 2024 and included the software costs in grant reimbursements in 2025. Cause: The payment for the software agreement was recognized as a prepaid expenditure in 2024. However, the entire amount was recognized as an expenditure in 2025 and was included in the calculation of grant reimbursements. Effect: The School Unit was reimbursed for expenditures that had not yet been incurred as the costs were for future services. Known Questioned Costs: $44,800. Recommendation: When reversing prior year prepaid expenditures, management should review the period for which the payment was to ensure the correct amount is recognized in current year expenditures.
Management’s response/corrective action plan: Management concurs with the audit finding. During fiscal year 2024, the School Unit appropriately recorded the cost of a five-year software agreement as a prepaid expenditure. However, in fiscal year 2025, the entire amount was incorrectly recognized as a current-year expenditure and included in the calculation of grant reimbursements. To remedy this issue, management will enhance internal controls over prepaid expenditures charged to federal grants. Specifically, finance staff and the business manager, will review all prepaid items at year-end and during grant reimbursement preparation to ensure that expenditures are recognized in the proper fiscal period and in accordance with the underlying contract terms. A reconciliation between prepaid balances, contract terms, and reimbursement requests will be performed prior to federal grant submission. In addition, written procedures will be updated to clearly require verification that only allowable and incurred costs are included in reimbursement claims, and relevant staff will receive additional training on grant compliance requirements related to prepaid expenditures. Management believes these actions will prevent similar issues in the future.
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
FAC accepted this audit on August 29, 2025 — management decision was due March 1, 2026.
The required language pertaining to wage rate requirements was omitted from a construction contract. In addition, management did not obtain the required certified payrolls from the contractor during the contract period. Cause: Management did not ensure that wage rate language was included in the construction contract and that certified payrolls were obtained and reviewed. Effect: Contractors could fail to follow wage rate requirements and pay less than prevailing wages. Questioned Costs: None Recommendation: Management should review all construction contracts paid with federal funds to ensure they contain the required wage rate requirements. In addition, someone familiar with the wage rate requirements should ensure certified payrolls are obtained and reviewed during the contract period.
Show full finding ▾Hide full finding ▴2023-001 – U.S. Department of Education, For the Period July 1, 2022 through June 30, 2023, Assistance Listing #84.425 – Internal Controls and Compliance over Elementary and Secondary School Emergency Relief Fund Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor. Management must ensure that all contractors and subcontractors are submitting weekly certified payrolls and verify that they are being paid at least the prevailing wage rates. In addition, language regarding wage rate requirements must be included in the contract. Condition: The required language pertaining to wage rate requirements was omitted from a construction contract. In addition, management did not obtain the required certified payrolls from the contractor during the contract period. Cause: Management did not ensure that wage rate language was included in the construction contract and that certified payrolls were obtained and reviewed. Effect: Contractors could fail to follow wage rate requirements and pay less than prevailing wages. Questioned Costs: None Recommendation: Management should review all construction contracts paid with federal funds to ensure they contain the required wage rate requirements. In addition, someone familiar with the wage rate requirements should ensure certified payrolls are obtained and reviewed during the contract period.
Management’s response/corrective action plan: Management takes compliance matters seriously and is committed to ensuring that all applicable regulations, including Davis-Bacon Act requirements, are adhered to. We have conducted a review of our processes and procedures related to prevailing wage rate compliance. This review has helped us identify areas where improvements can be made to ensure full compliance with these requirements. We have taken the following actions to address the identified compliance issue: 1. Management will proactively include prevailing wage language in any qualifying district construction project bids and contracts. 2. To strengthen our compliance efforts, we have improved monitoring to regularly assess our adherence to prevailing wage rate requirements for projects with federal assistance. This includes periodic reviews of construction projects, and proposed projects, to identify any potential non-compliance issues. Additionally, we will conduct prevailing wage compliance reviews of all certified payrolls as they are received. Management will oversee this monitoring to ensure ongoing compliance.
FAC accepted this audit on January 23, 2023 — management decision was due July 23, 2023.
FAC accepted this audit on January 16, 2022 — management decision was due July 16, 2022.
During the month of November 2020, the School Unit under reported meal counts for one of its schools, and during the month of September 2020 the School Unit over reported meal counts for one of its schools. Cause: A formula error on the meal count sheets caused the meals to be under reported, and a clerical error caused the meals to be over reported. Effect: The total meal counts for the month of November 2020 were under reported to the State of Maine, and the total meal counts for the month of September 2020 were over reported to the State of Maine. As a result, the School Unit may have received less federal subsidy due to the reduced meal counts. Recommendation: Management should review and recalculate supporting documentation from the individual schools before including the counts in the monthly claim forms. Questioned Costs: None
Show full finding ▾Hide full finding ▴2021-001 ? U.S. Department of Agriculture, For the Period July 1, 2020 through June 30, 2021, Assistance Listing #10.553 ? 10.559 Child Nutrition Cluster Criteria: Accurate meal counts and reporting are required for the proper calculation of federal subsidy. Statement of Condition: During the month of November 2020, the School Unit under reported meal counts for one of its schools, and during the month of September 2020 the School Unit over reported meal counts for one of its schools. Cause: A formula error on the meal count sheets caused the meals to be under reported, and a clerical error caused the meals to be over reported. Effect: The total meal counts for the month of November 2020 were under reported to the State of Maine, and the total meal counts for the month of September 2020 were over reported to the State of Maine. As a result, the School Unit may have received less federal subsidy due to the reduced meal counts. Recommendation: Management should review and recalculate supporting documentation from the individual schools before including the counts in the monthly claim forms. Questioned Costs: None
Management response/corrective action plan: Management understands the importance of correctly recording and requesting reimbursement for meals provided. The District has added a third monthly check before reimbursement of meals is requested and approved.
2020-002
FAC accepted this audit on March 8, 2021 — management decision was due September 8, 2021.
The total meal counts for the month of April 2020 were under reported to the State of Maine. In addition, the School Unit may have received less federal subsidy due to the reduced meal counts.
Show full finding ▾Hide full finding ▴The total meal counts for the month of April 2020 were under reported to the State of Maine. In addition, the School Unit may have received less federal subsidy due to the reduced meal counts.
The Nutrition Director had made corrections in how meal counts are recorded for the COVID and summer feeding plans. Now, a workbook is shared with the kitchens to record meals served for breakfast and lunch each day. All schools calculate to a district total sheet. The concern identified in April was from an incorrect formula in a spreadsheet and has since been corrected. The Director now verifies this work to ensure accuracy and that no meals go unclaimed.
FAC accepted this audit on January 12, 2020 — management decision was due July 12, 2020.
The Office of Management and Budget (OMB) revised regulations applicable to federally funded programs. The new regulations are contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance replaced OMB Circulars A-133, A-87, and A-110 and incorporates new requirements for grant recipients. The Uniform Guidance includes not only protocols for program management and administration, but also updates compliance regulations for federal awards. Currently, the School Unit does not have a formal written procurement policy that incorporates all provisions of the Uniform Guidance procurement standards. Cause: The School Unit has not yet adopted a procurement policy that covers all aspects required by the Uniform Guidance. However, during our testing of procurement over federal expenditures, we did not notate any violations of the Uniform Guidance procurement standards. Effect: Examples of items required by the Uniform Guidance procurement standards that may not currently be addressed in the School Unit?s procurement policy are as follows: ? Conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts ? Contracting with small and minority businesses, women?s business enterprises, and labor surplus area firms ? Bonding requirements ? Contract provisions ? Subrecipient and contractor determinations ? Retention requirements for records Recommendation: We recommend that management review the applicable provisions of the Uniform Guidance procurement standards and update the School Unit?s procurement policy appropriately. This would include adding any missing components to the School Unit?s current procurement policy and updating definitions of types of procurement, i.e., micro-purchases, small purchases, and small acquisition threshold, to match the language used in the Uniform Guidance procurement standards.
Show full finding ▾Hide full finding ▴2019-002 ? Uniform Guidance Procurement Standards Criteria: One of the more significant provisions of the Uniform Guidance that affects the School Unit is the procurement standards under 2 CFR sections 200.318 through 200.326. Under the new procurement standards, the School Unit is required to have a documented purchasing policy, which at a minimum, incorporates the provisions of the Uniform Guidance. Statement of Condition: The Office of Management and Budget (OMB) revised regulations applicable to federally funded programs. The new regulations are contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance replaced OMB Circulars A-133, A-87, and A-110 and incorporates new requirements for grant recipients. The Uniform Guidance includes not only protocols for program management and administration, but also updates compliance regulations for federal awards. Currently, the School Unit does not have a formal written procurement policy that incorporates all provisions of the Uniform Guidance procurement standards. Cause: The School Unit has not yet adopted a procurement policy that covers all aspects required by the Uniform Guidance. However, during our testing of procurement over federal expenditures, we did not notate any violations of the Uniform Guidance procurement standards. Effect: Examples of items required by the Uniform Guidance procurement standards that may not currently be addressed in the School Unit?s procurement policy are as follows: ? Conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts ? Contracting with small and minority businesses, women?s business enterprises, and labor surplus area firms ? Bonding requirements ? Contract provisions ? Subrecipient and contractor determinations ? Retention requirements for records Recommendation: We recommend that management review the applicable provisions of the Uniform Guidance procurement standards and update the School Unit?s procurement policy appropriately. This would include adding any missing components to the School Unit?s current procurement policy and updating definitions of types of procurement, i.e., micro-purchases, small purchases, and small acquisition threshold, to match the language used in the Uniform Guidance procurement standards.
Management response/corrective action plan: This his issue was discovered as part of our pre-audit work in June 2019. In discussion with RKO on this it was clear that we were following federal procurement and purchasing guidelines, but the issue was that we had not yet implemented policies and procedures addressing these required guidelines. Since then, the following steps have been taken. We obtained legal and financial input using their guidance what policies and procedures were needed. The following changes are in the process of being implemented and will be implemented prior to December 2019. 1. Updates are being made the School Unit?s Policy (DJ) for Bidding/Purchasing to include procurement methods for Federally Funded Project with the appropriate legal and RSU 18 Internal Financial Control references were added to this policy. 2. Updates are being made the School Unit?s Policy (DJH) for Purchasing and Contracting - Procurement Staff Code of Conduct. This policy already contains language meeting federal procurement guidelines. This policy also contains required language for dispute resolution (versus adding dispute resolution language to the new internal financial control for Federal procurement and purchasing). Appropriate legal and RSU 18 Internal Financial Control references were added to this policy. 3. We developed and implemented an RSU 18 Internal Financial Control for Federal Procurement Procedures. This internal financial control governs the procurement and purchase of property, goods and services for using any federal award, in whole or in part that is subject to the Uniform Grant Guidance codified at 2 CFR Part 200. Appropriate legal and RSU 18 Internal Financial Control references were added to this policy.
FAC accepted this audit on January 9, 2019 — management decision was due July 9, 2019.
FAC accepted this audit on December 19, 2017 — management decision was due June 19, 2018.
FAC accepted this audit on November 13, 2016 — management decision was due May 13, 2017.
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