Baltimore City Public School System

Federal Agency: Federal Communications Commission Federal Program Name: Emergency Connectivity Fund Program (ECF) Assistance Listing Number: 32.009 Federal Award Identification Number and Year: ECF202205731 obligation 3 and 2022 Award Period: 7/1/2022 to 6/30/2024 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Internal Control: In accordance with 2 CFR §200.309 and 2 CFR §200.403, costs and related transactions must be incurred, and goods or services must be received, within the applicable period of performance and in accordance with the award terms and conditions. Additionally, 2 CFR §200.303 requires non-federal entities to establish and maintain effective internal control over federal awards to ensure compliance with applicable laws, regulations, and award requirements, including timely documentation of receipt to support compliance with program delivery deadlines. Condition: City Schools’ internal controls over documenting receipt of goods were not consistently performed. The grant requires the receipt of goods to be performed by June 30, 2024. City Schools’ accounting system requires electronic acknowledgement of goods and services. In one instance the receipt of goods was posted three to seventeen months after the packing slip date. The delivery packing slip was dated June 5, 2024. However, the electronic acknowledgement for receipt of goods was reported on September 12, 2024, and November 19, 2025. Due to the untimely posting of receipts, the receipt of the goods appeared to be outside of the period of performance. Questioned Costs: None Context: For one of four transactions tested, the receipt of goods was not posted in a timely manner for the period of performance date. Cause: Due to a system error the receipts were not posted when entered by the Office of Informational Technology and the error was not identified by management. City schools is currently monitoring the electronic posting of receipts; however, these procedures were not in place during the audit period. Effect: Inconsistent applications of internal control increases City Schools’ risk of being non-compliant with federal compliance requirements and reduces the reliability of financial information used to support federal reporting, reimbursement requests and grantor monitoring. In this instance, City Schools was able to support their compliance with the requirement due the shipment packing slip. Repeat Finding: No Recommendation: City Schools should enhance internal controls over the electronic reporting for receipt of goods and services by implementing procedures to monitor the posting of receipts. The procedures should ensure that receipt of goods and services are reported in a timely manner, and that the receipts, including dates, are accurately reported in the accounting system. Views of Responsible Officials: City Schools agrees with the finding and will enhance procedures to ensure that electronic receipts are timely recorded in the accounting system.

Emergency Connectivity Fund Program – Assistance Listing No. 32.009 Recommendation: City Schools should enhance internal controls over the electronic reporting for receipt of goods and services by implementing procedures to monitor the posting of receipts. The procedures should ensure that receipt of goods and services are reported in a timely manner, and that the receipts, including dates, are accurately reported in the accounting system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In October of 2025, City Schools Finance Department began an internal review related to the electronic posting of receipts. While the facts related to the finding are considered an anomaly, we are reviewing the timeliness and accuracy of receipts posted in the accounting system. The Office of Informational Technology and/or City Schools users will assist with resolving identified concerns. These efforts by the Finance Department are continuous with no specified end date. Name(s) of the contact person(s) responsible for corrective action: Aires Coleman, Director of Finance 410-396-2611 Planned completion date for corrective action plan: March 31, 2026

2023-002 Special Tests: Graduation Cohort Federal Agency: U.S. Department of Education Federal Program Name: Title I Assistance Listing Number: 84.010 Federal Award Identification Number and Year: A010A200020 and fiscal years 2019-2022 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): 200091, 211083, 221498, 231248, 201469, 211311, 221770, 231256, 201704, 211289, 221674, 231035 Award Period (s): Fiscal years 2019-2022 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Compliance: Per ESEA sections 1111(h)(1)(C)(iii)(II) and 8101(23), (25) (20 USC 6311(h)(1)(C)(iii)(II) and 7801(23), (25))), in order to remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. A student who is retained in grade, enrolls in a GED program, or leaves school for any other reason may not be counted as having transferred out for the purpose of calculating graduation rate and must remain in the adjusted cohort. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: City Schools did not obtain and/or maintain documentation to support students’ the withdrawal code reported to Maryland State Department of Education (MSDE). MSDE requires City Schools to provide data for students that no longer attend a school in the district. The data is used to determine if City Schools’s graduation rate is affected because of the student’s departure. We identified 3 students whose withdrawal code was not supported by documentation for more than a year after the student’s departure from the district. 2 of the 3 students, 2 students attended other schools and 1 student no longer lived in the United States. In all 3 errors, the student was identified as reported as attending a school within the district without adequate documentation Questioned costs: None Context: For 2 out of 40 students tested, City Schools did not obtain documentation to support the student’s transfer to another school prior to the auditor’s inquiry. The school reported that student as attending another school without documentation the transfer. For 1 out of 40 students tested, the student no longer lived in the United States and did not attend school for school years 2019-2020 and 2020-2021. The school reported the student as attending school for both school years before learning that the student was no longer in the country. Cause: City Schools did not consistently follow the established procedures related to student withdrawal codes. Effect: MSDE data was not correct and City Schools’ graduation rate may be incorrect. Repeat Finding: No Recommendation: We recommend that the schools develop internal controls and procedures to ensure the documentation is consistently maintained to support compliance with grantor’s requirements. Views of responsible officials: There is no disagreement with the audit finding.

2023-002 Special Rest; Graduation Cohort Recommendation: We recommend that the schools develop internal controls and procedures to ensure the documentation is consistently maintained to support compliance with grantor’s requirements. Action planned/taken in response to finding: 1. City Schools will draft guidance to schools reminding them of their obligation to maintain documentation for all student transfers as per the MSDE Student Records Manual, P.32. The initial guidance will remind schools that all documentation needs to be saved as part of a student’s transfer packet. For SY24-25, the guidance will be updated to instruct schools to save all transfer requests in Person Documents in Infinite Campus (IC). This will be a collaboration between the Office of Achievement and Accountability (OAA) and the Schools Office. 2. City Schools will create a new data cleansing report (DCR) to ensure that all transfer codes entered in Infinite Campus have transfer documentation uploaded to IC to support the transfer request. The above guidance will be shared with schools as part of the launch of the new DCR report in SY24-25. This will be a collaboration between OAA and the Office of Information Technology (OIT). 3. City Schools’ School Managers will monitor the new DCR to ensure schools are uploading documentation for every transfer into IC. Name(s) of the contact person(s) responsible for corrective action: Holly Bedwell (OAA) and Sabree Barnes (Schools Office) Planned completion date for corrective action plan: September 9, 2024.

2023-003 Allowable Costs: Payroll Costs Federal Agency: U.S. Department of Education Federal Program Name: Coronavirus State and Local Fiscal Relief Fund (CSLFRF), Education Stabilization Fund (ESF) and Student Support and Academic Enrichment Program (Title IV) Assistance Listing Number: 21.027, 84.425 C, D, U,W and 84.424 Federal Award Identification Number and Year (s): CSLFRF: none and 3/2021-12/31/2024, ESF: S425D20005, S425C200002, S425U200002, S425W200002 and 3/13/2020-9/30/2023, Title IV: S424A200021 and Fiscal years 2021-2025 Pass-Through Agency: Maryland State Department of Education Pass-Through Number(s): CSLFRF: 211770, 211821, 211903, 211889, 211904, 21188 ESF: 201766, 201878, 202134, 202126, 211958, 221569, 221864, 222038, 221360, Title IV: 211382, 221548, 23253 Award Period (s): CSLFRF: 3/2021-12/31/2024, ESF: 3/13/2020-9/30/2023, Title IV: Fiscal years 2021-2025 Type of Finding: Material Non-Compliance, Material Weakness in Internal Control Criteria or specific requirement: Compliance: For an employee who works in part on the consolidated administrative cost objective and in part on a Federal program whose administrative funds have not been consolidated or on activities funded from other revenue sources, an SEA or LEA must maintain time and effort distribution records in accordance with 2 CFR section 200.430(i)(1)(vii) that support the portion of time and effort dedicated to: • The consolidated cost objective, and • Each program or other cost objective supported by non-consolidated Federal funds or other revenue sources. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Time and effort documentation did not support the employee’s payroll costs charged to the grant. In addition, payroll testing for the Education Stabilization Funds grant, we identified the following: 1. Employee’s time and effort documentation was not provided. 2. Documentation to support the employees’ gross pay or hourly rate was not provided. As a result, the auditor was unable to support the accuracy of the employee's pay charged to the grant. 3. Employees were included in the grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant. Replacement samples were not selected and deemed ineffective as the population did not clearly identify which employee’s payroll costs were removed from the grant. Questioned costs: Time and effort documentation did not support the employee’s payroll costs charged to the grant. CSLFRF: $6,087.16, ESF: $3,807.00, Title IV: $6,097.07 ESF: a. $18,256.60- employees time and effort and/or support for salary or hourly rate was not provided b. $ 6,150.10 - employees were included in grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant Context: Time and effort did not support payroll costs charged to the grant: c. CSLFRF 8 out of 60 transactions tested d. ESF: 3 out of 60 transactions tested e. Title IV: 12 out of 40 transactions tested ESF: f. 6 out of 60 employees time and effort and/or support for salary or hourly rate was not provided. g. 4 out of 60 employees were included in grant expenditure population, after inquiry from the auditor, City Schools stated that the employee’s salary was no longer charged to the grant. Cause: City Schools did not have documentation to support payroll costs charged to the grant readily available for the audit. Effect: City Schools is unable to support payroll costs charged to the grant. Repeat Finding: No Recommendation: We recommend that the schools develop internal controls and procedures to ensure the documentation is consistently maintained and readily available to support compliance with grantor’s requirements. Views of responsible officials: There is no disagreement with the audit finding.

2023-003 Allowable Cost- Payroll Recommendation We recommend that the schools develop internal controls and procedures to ensure the documentation is consistently maintained and readily available to support compliance with grantor’s requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: 1. Requirements to support documentation of payroll expenditures will be reviewed with school staff annually as part of grant support visits, resource materials provided and other technical assistance sessions. 2. As part of Spring 2024 site visits to be completed prior to June 30, 2024, Title I specialists will review with school staff requirements for documentation to support payroll expenditures using Title I funds. Documentation of stipend and temporary staff payroll will be collected and saved in the school’s grant monitoring folder. This activity will also occur in September 2024 for summer stipend/temp staff payments. 3. Charter schools utilizing Title II and/or Title IV funds will continue to participate in twice annual monitoring by the Office of Data Monitoring and Compliance to review support documentation for any stipend/temporary staff payments. 4. Schools leveraging ESSER funds in SY23/24 for stipend/temporary staff payments will be requested to upload support documentation to a district established SharePoint site prior to June 30, 2024. 5. By April 30, 2024 requirements for payroll expenditure documentation will be reviewed with district offices implementing grant funded district initiatives. These meetings include Title I, Title II, Title III, Title IV, Perkins and COVID relief grant funds. All district offices will be required to save support documentation for stipend and temporary staff payments for district level and/or district coordinated activities to a SharePoint folder to ensure accessibility for future monitoring activities. The district staff person from the Office of Data Monitoring and Compliance assigned to support the federal grant will review uploaded materials to ensure the documentation supports payroll expenditures. Name(s) of the contact person(s) responsible for corrective action: Kimberly Hoffmann Planned completion date for corrective action plan: June 2024.

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