CENTRAL VALLEY CENTRAL SCHOOL DISTRICT

2019-01 Federal Uniform Guidance Policies and Procedures Condition: The School District currently has effective procedural controls in place over the management of Federal awards as concluded through the testing of grant expenditures. However, key changes under the Uniform Guidance expanded the rules regarding the documentation of internal controls over Federal Awards to require that they be documented in writing in the School District?s policies and that management should evaluate and document the results of ongoing monitoring to identify internal control issues. The written internal controls should specifically address each of the applicable twelve (12) compliance requirements of the Federal award programs. It was noted that the School District did update their procurement policy in accordance with the Uniform Guidance during 2019. Other policies over financial management are still required. Criteria: On December 26, 2014 the Office of Management and Budget?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, more commonly referred to as the ?Uniform Guidance,? became effective for all Federal awards, whether the funds are provided directly from a Federal agency or passed-through another state or local agency. On May 17, 2017, the Office of Management and Budget extended the implementation date for the procurement standards for nonfederal entities and is now effective for the grant year ended June 30, 2019. Cause: Unknown Effect: The School District is more at risk of noncompliance with federal grant regulations related to Uniform Administrative Requirements by not having a fully effective procedural controls in place. Known Questioned Costs: None were noted. Context: The School District manages multiple federal programs in a single year. Repeat Finding: No. Recommendation: The School District should document the additional required policies and procedures in accordance with the Uniform Guidance. This should include monitoring procedures to ensure that internal controls over compliance are working effectively. Management?s Response: The District will document policies and procedures in accordance with the Uniform Guidance, which will include monitoring procedures to ensure that internal controls over compliance are working effectively.

October 29, 2019 Oversight Agency: New York State Department of Education Central Valley Central School District at Ilion/Mohawk respectfully submits the following corrective action plan for the year ended June 30, 2019. Independent Public Accounting Firm: D?Arcangelo & Co., LLP PO Box 4300 Rome, NY 13440 Finding: 2019-001 Federal Uniform Guidance Policies and Procedures Planned Action: We will develop required written policies and procedures as required by the OMB?s Uniform Guidance. Contact Responsible: James P. Humphrey Anticipated date of Completion: November 20, 2019