DICKINSON PUBLIC SCHOOL DISTRICT NO. 1Local Government

2025-002: AL 84.027 / 84.173 Activities Allowed or Unallowed & Allowable Costs / Cost Principles Criteria According to the Uniform Guidance, “An LEA may only use federal funds under IDEA, Part B for the excess costs of providing special education and related services to children with disabilities." Condition Employees sign time and effort certification documents that detail the percentage of their wages that are allocated to specific grants. Cause While the employee’s wages were allocated to the grant correctly, the time and effort certification signed by the employee was not updated to reflect the new allocation percentage. Effect An unallowable payroll cost could be charged to the grant. Questioned Costs None Recommendation Ensure that changes in payroll allocations are communicated properly and certified by the employees working on the federal program. Views of Responsible Officials and Planned Corrective Actions The current process of completing the annual IDEA, Part B budget along with the corresponding time and effort certifications were reviewed by Naomi Obrigewitch and the grant director, Sheri Twist, Director of Student Services. It was realized that an additional step of communication between the director and the grant specialist who processes the time and effort certifications needs to happen at the beginning of the fiscal year when the budget is created. The director will ensure the IDEA, Part B salary breakdown is forwarded to both the grant specialist and the payroll manager. This will ensure the federal grant guidelines are met. Indication of Repeat Finding This is a new finding.

2023-002: AL 84.010, AL 84.027 / 84.173, AL 84.425 & AL 84.371 – Activities Allowed or Unallowed & Allowable Costs / Cost Principles Criteria The District should keep adequate documentation to support charges to grants. This would include supporting invoices, time cards, approved pay rates and cost allocation worksheets. Condition In our total sample of 160 transactions, four payroll transactions had timesheets that were missing supervisor approval, along with two nonpayroll transactions. Thirteen payroll transactions did not have documentation of the hours worked by the employee or documentation of the employee’s time spent towards that particular grant. Cause Internal control processes were not properly followed and proper documentation was not kept. Effect Unallowable costs could be charged to the grant. Questioned Costs AL 84.027 / 84.173: $8,891 AL 84.371: $8,247 Recommendation We recommend internal control processes are followed and include documentation of employees time towards the grant. Views of Responsible Officials and Planned Corrective Actions During the 2022-2023 fiscal year, Dickinson Public Schools was in the transition of the administration assistant position for the Director of Curriculum and Instruction. In addition, the business office created and hired a new position of a grant specialist. With the changes in these two departments, Dickinson Public Schools will create a more streamlined process to ensure that grant documentation is completed as outlined in all federal grant guidelines. Indication of Repeat Finding This is a new finding in the current year.

Criteria: The District's procurement policy should be updated to conform with Uniform Guidance. Condition: The District follows North Dakota Century Code and federal regulations, but has not updated their policy to comply with Uniform Guidance requirements. Cause: The District has not updated their policy to conform to Uniform Guidance. Effect: The District may not be in compliance with Uniform Guidance procurement policies. Recommendation: The District should draft and the Board approve a procurement policy that complies with Uniform Guidance. Indication of a Repeat Finding: This is a new finding in the current year. Views of Responsible Officials and Planned Corrective Actions: In the past the District has followed internal procurement practices and procedures but has not adopted a formal procurement policy. In response to the financial statement audit finding of a significant deficiency, the District will draft and adopt a formal procurement policy that complies with Uniform Guidance. The District will implement these changes in procurement policy for the 2020 Fiscal year.