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SCHOOL BOARD CITY OF RICHMONDLocal Government

EIN: 541689909

UEI: QQNBNYU8ADM4

Audited by: CHERRY BEKAERT LLP

Cognizant agency: 84 [Department of Education]

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Data as of September 2, 2026

SCHOOL BOARD CITY OF RICHMOND10 audit years7 findings2 repeat
10
Audit Years
7
Total Findings
2
Repeat Findings
$79.2M
Federal Awards Expended (FY 2025)

FY 2025-06-30

$79,222,319 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on June 9, 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 December 9, 2026 (97 days from today).

What is a management decision? →
2025-003
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2023-002OTHER MATTERS

During testing of seven students removed from the adjusted cohort, management was unable to provide timely supporting documentation for one student demonstrating that the student had transferred to another qualifying school or educational program. As a result, the student’s removal from the adjusted cohort was not adequately supported. Cause: Management and supervisory personnel did not maintain required supporting documentation in a timely and consistent manner. Effect: Failure to maintain adequate documentation supporting student removals from the adjusted cohort increases the risk that high school graduation rate data reported on the Annual Report Card may be inaccurate. This condition resulted in noncompliance with applicable requirements and represents a significant deficiency in internal control over compliance. Questioned Costs: None Recommendation: We recommend that the grant administrator strengthen procedures to ensure that official written documentation supporting all student removals from the adjusted cohort is obtained, retained, and readily available for review on a timely basis. Supervisory review controls should also be implemented to verify that required documentation is complete and properly maintained. Views of Responsible Officials and Planned Corrective Action: Responsible officials acknowledge the finding and agree that documentation supporting student removals from the adjusted cohort was not maintained timely in all instances. Management stated that it will implement enhanced procedures and supervisory review processes to ensure required documentation is obtained and retained timely for all applicable students going forward.

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2025-003 – Significant Deficiency and Nonmaterial Noncompliance – Annual Report Card, High School Graduation Rate Program: Title I Grants to Local Educational Agencies (ALN 84.010) – United States Department of Education – Virginia Department of Education; Federal Award Year: 2025. Criteria: For purposes of the Annual Report Card high school graduation rate, state educational agencies and local educational agencies are required to implement appropriate policies and procedures for documenting the removal of a student from the adjusted cohort. To support a student’s transfer out of the cohort, the school or local educational agency must maintain 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. Condition: During testing of seven students removed from the adjusted cohort, management was unable to provide timely supporting documentation for one student demonstrating that the student had transferred to another qualifying school or educational program. As a result, the student’s removal from the adjusted cohort was not adequately supported. Cause: Management and supervisory personnel did not maintain required supporting documentation in a timely and consistent manner. Effect: Failure to maintain adequate documentation supporting student removals from the adjusted cohort increases the risk that high school graduation rate data reported on the Annual Report Card may be inaccurate. This condition resulted in noncompliance with applicable requirements and represents a significant deficiency in internal control over compliance. Questioned Costs: None Recommendation: We recommend that the grant administrator strengthen procedures to ensure that official written documentation supporting all student removals from the adjusted cohort is obtained, retained, and readily available for review on a timely basis. Supervisory review controls should also be implemented to verify that required documentation is complete and properly maintained. Views of Responsible Officials and Planned Corrective Action: Responsible officials acknowledge the finding and agree that documentation supporting student removals from the adjusted cohort was not maintained timely in all instances. Management stated that it will implement enhanced procedures and supervisory review processes to ensure required documentation is obtained and retained timely for all applicable students going forward.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Action: Responsible officials acknowledge the finding and agree that documentation supporting student removals from the adjusted cohort was not maintained timely in all instances. Management stated that it will implement enhanced procedures and supervisory review processes to ensure required documentation is obtained and retained timely for all applicable students going forward.

Prior Finding References

2023-002

About Special Tests and Provisions →

FY 2024-06-30

$104,959,142 federal awards expended

FAC accepted this audit on November 14, 2025 — management decision was due May 14, 2026.

2024-003
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2023-003OTHER MATTERS

The grant administrator was unable to provide quarterly and annual reporting requirements for fiscal year 2024. Cause: Documentation was not maintained for audit purposes. Effect: Accountability for use of the funds can not be demonstrated. Questioned Costs: None Recommendation: Grant administrator should maintain adequate documentation. Views of Responsible Officials and Planned Corrective Action: According to Appendix: American Rescue Plan CSLFRF HVAC Replacement and Improvement Grant Assurances of the 2021 CSLFRF HVAC Application it is stated the LEA/grantee assures: IX. It will submit such reports to the state educational agency as the state educational agency and Secretary may require to enable the state educational agency and the Secretary to perform their duties under the program; The LEA has also submitted an official correspondence to the Auditors from the Commonwealth of Virginia Department of Education’s Director of the Office of Federal Pandemic Relief Programs stating the following: On April 25, 2023, the Virginia Department of Education conducted monitoring to ensure that certain federally funded programs and activities supported with Elementary and Secondary School Emergency Relief (ESSER) formula grants; ESSER and Governor’s Emergency Education Relief (GEER) state setaside grants; and Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) HVAC grants were implemented as stipulated by law. These federally funded programs were reviewed as operated by Richmond City Public Schools. Furthermore, RPS is a subrecipient. As such it is our stance that RPS was not required to create or submit quarterly financial activity reports to US Treasury. We were also not required to submit quarterly financial reports to the recipient (i.e. the Commonwealth of Virginia). Instead, RPS regularly submitted expenditures for reimbursement to VDOE on a nearly monthly basis via OMEGA. We also maintained financial records (invoices, GL transactions) via AS400 and LINQ and conducted annual single audits as required by the Single Audit Act & 2 CFR part 200, subpart F. We also complied with all monitoring activities conducted by VDOE. In turn, VDOE (the award recipient) used these artifacts to create and submit its quarterly financial reports to US Treasury, as required by statute. For more evidence of this "passthrough" structure of reporting, see the attached SLFRF Compliance and Reporting Guidance published by US Treasury and Updated October 2025 Part 2 Section B (p. 21-22) for a detail of which entities are required to submit quarterly reports. The following recipients are required to submit quarterly Project and Expenditure Reports: • States and U.S. territories • Tribal governments that are allocated more than $30 million in SLFRF funding • Metropolitan cities and counties with a population that exceeds 250,000 residents Coronavirus State and Local Fiscal Recovery Funds C • Metropolitan cities and counties with a population below 250,000 residents that are allocated more than $10 million in SLFRF funding • NEUs [Non-Entitlement Units of Government] that are allocated more than $10 million in SLFRF funding RPS does not fall into any of the aforementioned categories. We humble ask that you reconsider this finding.

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2024-003 – Significant Deficiency and Nonmaterial Noncompliance – Reporting Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) – United States Department of Education – Virginia Department of Education; Federal Award Year: 2024. Prior Year Audit Finding Number: 2023-003 Criteria: Project and Expenditure reports should be submitted to the VDOE quarterly and annually. Condition: The grant administrator was unable to provide quarterly and annual reporting requirements for fiscal year 2024. Cause: Documentation was not maintained for audit purposes. Effect: Accountability for use of the funds can not be demonstrated. Questioned Costs: None Recommendation: Grant administrator should maintain adequate documentation. Views of Responsible Officials and Planned Corrective Action: According to Appendix: American Rescue Plan CSLFRF HVAC Replacement and Improvement Grant Assurances of the 2021 CSLFRF HVAC Application it is stated the LEA/grantee assures: IX. It will submit such reports to the state educational agency as the state educational agency and Secretary may require to enable the state educational agency and the Secretary to perform their duties under the program; The LEA has also submitted an official correspondence to the Auditors from the Commonwealth of Virginia Department of Education’s Director of the Office of Federal Pandemic Relief Programs stating the following: On April 25, 2023, the Virginia Department of Education conducted monitoring to ensure that certain federally funded programs and activities supported with Elementary and Secondary School Emergency Relief (ESSER) formula grants; ESSER and Governor’s Emergency Education Relief (GEER) state setaside grants; and Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) HVAC grants were implemented as stipulated by law. These federally funded programs were reviewed as operated by Richmond City Public Schools. Furthermore, RPS is a subrecipient. As such it is our stance that RPS was not required to create or submit quarterly financial activity reports to US Treasury. We were also not required to submit quarterly financial reports to the recipient (i.e. the Commonwealth of Virginia). Instead, RPS regularly submitted expenditures for reimbursement to VDOE on a nearly monthly basis via OMEGA. We also maintained financial records (invoices, GL transactions) via AS400 and LINQ and conducted annual single audits as required by the Single Audit Act & 2 CFR part 200, subpart F. We also complied with all monitoring activities conducted by VDOE. In turn, VDOE (the award recipient) used these artifacts to create and submit its quarterly financial reports to US Treasury, as required by statute. For more evidence of this "passthrough" structure of reporting, see the attached SLFRF Compliance and Reporting Guidance published by US Treasury and Updated October 2025 Part 2 Section B (p. 21-22) for a detail of which entities are required to submit quarterly reports. The following recipients are required to submit quarterly Project and Expenditure Reports: • States and U.S. territories • Tribal governments that are allocated more than $30 million in SLFRF funding • Metropolitan cities and counties with a population that exceeds 250,000 residents Coronavirus State and Local Fiscal Recovery Funds C • Metropolitan cities and counties with a population below 250,000 residents that are allocated more than $10 million in SLFRF funding • NEUs [Non-Entitlement Units of Government] that are allocated more than $10 million in SLFRF funding RPS does not fall into any of the aforementioned categories. We humble ask that you reconsider this finding.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Action: According to Appendix: American Rescue Plan CSLFRF HVAC Replacement and Improvement Grant Assurances of the 2021 CSLFRF HVAC Application it is stated the LEA/grantee assures: IX. It will submit such reports to the state educational agency as the state educational agency and Secretary may require to enable the state educational agency and the Secretary to perform their duties under the program; The LEA has also submitted an official correspondence to the Auditors from the Commonwealth of Virginia Department of Education’s Director of the Office of Federal Pandemic Relief Programs stating the following: On April 25, 2023, the Virginia Department of Education conducted monitoring to ensure that certain federally funded programs and activities supported with Elementary and Secondary School Emergency Relief (ESSER) formula grants; ESSER and Governor’s Emergency Education Relief (GEER) state setaside grants; and Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) HVAC grants were implemented as stipulated by law. These federally funded programs were reviewed as operated by Richmond City Public Schools. Furthermore, RPS is a subrecipient. As such it is our stance that RPS was not required to create or submit quarterly financial activity reports to US Treasury. We were also not required to submit quarterly financial reports to the recipient (i.e. the Commonwealth of Virginia). Instead, RPS regularly submitted expenditures for reimbursement to VDOE on a nearly monthly basis via OMEGA. We also maintained financial records (invoices, GL transactions) via AS400 and LINQ and conducted annual single audits as required by the Single Audit Act & 2 CFR part 200, subpart F. We also complied with all monitoring activities conducted by VDOE. In turn, VDOE (the award recipient) used these artifacts to create and submit its quarterly financial reports to US Treasury, as required by statute. For more evidence of this "passthrough" structure of reporting, see the attached SLFRF Compliance and Reporting Guidance published by US Treasury and Updated October 2025 Part 2 Section B (p. 21-22) for a detail of which entities are required to submit quarterly reports. The following recipients are required to submit quarterly Project and Expenditure Reports: • States and U.S. territories • Tribal governments that are allocated more than $30 million in SLFRF funding • Metropolitan cities and counties with a population that exceeds 250,000 residents Coronavirus State and Local Fiscal Recovery Funds C • Metropolitan cities and counties with a population below 250,000 residents that are allocated more than $10 million in SLFRF funding • NEUs [Non-Entitlement Units of Government] that are allocated more than $10 million in SLFRF funding RPS does not fall into any of the aforementioned categories. We humble ask that you reconsider this finding.

Prior Finding References

2023-003

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2024-004
Equipment & Real Property
SIGNIFICANT DEFICIENCYOTHER MATTERS

The School Board began purchasing equipment under this program in 2022. A physical inventory was not performed during 2024. Cause: Procedures over equipment and property management not properly designed and implemented. Effect: Equipment and property not examined for any potential loss, damage, theft, or disposal. Questioned Costs: None Recommendation: Grant administrator should perform a physical inventory of property at least every two years Views of Responsible Officials and Planned Corrective Action: The Designees of the Grants Monitoring and Compliance team will oversee the completion of a physical inventory of all equipment that exceed $5,000 by October 31, 2026. The Grants team will also house documentation.

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2024-004 – Significant Deficiency and Nonmaterial Noncompliance – Equipment and Real Property Management Program: Education Stabilization Fund (ALN 84.425) – United States Department of Education – Virginia Department of Education; Federal Award Year: 2024. Prior Year Audit Finding Number: N/A Criteria: 2 CFR section 200.313(d)(2) states: A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Condition: The School Board began purchasing equipment under this program in 2022. A physical inventory was not performed during 2024. Cause: Procedures over equipment and property management not properly designed and implemented. Effect: Equipment and property not examined for any potential loss, damage, theft, or disposal. Questioned Costs: None Recommendation: Grant administrator should perform a physical inventory of property at least every two years Views of Responsible Officials and Planned Corrective Action: The Designees of the Grants Monitoring and Compliance team will oversee the completion of a physical inventory of all equipment that exceed $5,000 by October 31, 2026. The Grants team will also house documentation.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Action: The Designees of the Grants Monitoring and Compliance team will oversee the completion of a physical inventory of all equipment that exceed $5,000 by October 31, 2026. The Grants team will also house documentation.

About Equipment and Real Property Management →

FY 2023-06-30

$108,323,879 federal awards expended

FAC accepted this audit on November 14, 2025 — management decision was due May 14, 2026.

2023-001
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

For a sample of forty (40) payroll and forty (40) non-payroll transactions, grant management could not provide certifications of time incurred and charged to the grant for two (2) employees. Cause: Employees and supervisors did not adhere to School Board time certification policies and procedures. Effect: Time incurred by personnel could be incorrectly allocated to federal programs. Questioned Costs: Two (2) grant charged employees approximating $6,400, from a sample population approximating $132,000. Recommendation: Employees charging time to a grant should have approved timesheets/records prior to payroll certification and processing. Views of Responsible Officials and Planned Corrective Action: Weekly staffing reports are sent to the locations for administrators to identify employees assigned to their location. Title 1 Grant Manager is sent a monthly personnel report that identifies all employees coded to Title 1 by location. There is a semi-annual in-person staff validation process. The team includes the enrollment and planning, Talent, and Budget Departments. The grants team will schedule standing meetings (biweekly) with the grant manager, accountant, and the Director of Budget to ensure all payroll is correct as it relates to Title I Part A. This will begin immediately following the next pay period. When discrepancies are identified, the Title 1 Grant Accountant will prepare an journal entry to move the payroll charges out of the Title 1 fund to the correct fund by journal entry

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2023-001 – Significant Deficiency and Nonmaterial Noncompliance – Allowable Costs and Activities Program: Title I Grants to Local Educational Agencies (ALN 84.010) – United States Department of Education – Virginia Department of Education; Federal Award Year: 2023. Criteria: Office of Management and Budget's (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subtitle A, Chapter II, Part 200, Subpart E – Cost Principles subsection 200.430 – Compensation – Personal Services subsection (i) – Standards for Documentation of Personnel Expenses subsection (1) states: Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. 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; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); (iv) Encompass federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vi) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two (2) or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: For a sample of forty (40) payroll and forty (40) non-payroll transactions, grant management could not provide certifications of time incurred and charged to the grant for two (2) employees. Cause: Employees and supervisors did not adhere to School Board time certification policies and procedures. Effect: Time incurred by personnel could be incorrectly allocated to federal programs. Questioned Costs: Two (2) grant charged employees approximating $6,400, from a sample population approximating $132,000. Recommendation: Employees charging time to a grant should have approved timesheets/records prior to payroll certification and processing. Views of Responsible Officials and Planned Corrective Action: Weekly staffing reports are sent to the locations for administrators to identify employees assigned to their location. Title 1 Grant Manager is sent a monthly personnel report that identifies all employees coded to Title 1 by location. There is a semi-annual in-person staff validation process. The team includes the enrollment and planning, Talent, and Budget Departments. The grants team will schedule standing meetings (biweekly) with the grant manager, accountant, and the Director of Budget to ensure all payroll is correct as it relates to Title I Part A. This will begin immediately following the next pay period. When discrepancies are identified, the Title 1 Grant Accountant will prepare an journal entry to move the payroll charges out of the Title 1 fund to the correct fund by journal entry

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Action: Weekly staffing reports are sent to the locations for administrators to identify employees assigned to their location. Title 1 Grant Manager is sent a monthly personnel report that identifies all employees coded to Title 1 by location. There is a semi-annual in-person staff validation process. The team includes the enrollment and planning, Talent, and Budget Departments. The grants team will schedule standing meetings (biweekly) with the grant manager, accountant, and the Director of Budget to ensure all payroll is correct as it relates to Title I Part A. This will begin immediately following the next pay period. When discrepancies are identified, the Title 1 Grant Accountant will prepare an journal entry to move the payroll charges out of the Title 1 fund to the correct fund by journal entry

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2023-002
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

For a sample of four (4) students, grant management could not provide timely documentation for one (1) sample supporting the removal of a student from the regulatory adjusted cohort. Cause: Employees and supervisors did not maintain supporting documentation. Effect: Eligible participants may not receive opportunities to participate. Questioned Costs: None Recommendation: Grant administrator should maintain adequate documentation. Views of Responsible Officials and Planned Corrective Action: The Director of Academic Support will report monthly to the Grants Team during the regularly scheduled meeting the required information pertaining to this finding to make sure RPS is in compliance. This will begin in November at our regularly scheduled meeting.

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2023-002 – Significant Deficiency and Nonmaterial Noncompliance – Allowable Costs and Activities Program: Title I Grants to Local Educational Agencies (ALN 84.010) – United States Department of Education – Virginia Department of Education; Federal Award Year: 2023. Criteria: Annual Report Card, High School Graduation Rates – SEAs and LEAS must have implemented appropriate policies and procedures for documenting the removal of a student from the adjusted cohort. Condition: For a sample of four (4) students, grant management could not provide timely documentation for one (1) sample supporting the removal of a student from the regulatory adjusted cohort. Cause: Employees and supervisors did not maintain supporting documentation. Effect: Eligible participants may not receive opportunities to participate. Questioned Costs: None Recommendation: Grant administrator should maintain adequate documentation. Views of Responsible Officials and Planned Corrective Action: The Director of Academic Support will report monthly to the Grants Team during the regularly scheduled meeting the required information pertaining to this finding to make sure RPS is in compliance. This will begin in November at our regularly scheduled meeting.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Action: The Director of Academic Support will report monthly to the Grants Team during the regularly scheduled meeting the required information pertaining to this finding to make sure RPS is in compliance. This will begin in November at our regularly scheduled meeting.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2023-003
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The grant administrator was unable to provide quarterly and annual reporting requirements for fiscal year 2023. Cause: Documentation was not maintained for audit purposes. Effect: Accountability for use of the funds can not be demonstrated. Questioned Costs: None Recommendation: Grant administrator should maintain adequate documentation. Views of Responsible Officials and Planned Corrective Action: According to Appendix: American Rescue Plan CSLFRF HVAC Replacement and Improvement Grant Assurances of the 2021 CSLFRF HVAC Application it is stated the LEA/grantee assures: IX. It will submit such reports to the state educational agency as the state educational agency and Secretary may require to enable the state educational agency and the Secretary to perform their duties under the program; The LEA has also submitted an official correspondence to the Auditors from the Commonwealth of Virginia Department of Education’s Director of the Office of Federal Pandemic Relief Programs stating the following: On April 25, 2023, the Virginia Department of Education conducted monitoring to ensure that certain federally funded programs and activities supported with Elementary and Secondary School Emergency Relief (ESSER) formula grants; ESSER and Governor’s Emergency Education Relief (GEER) state setaside grants; and Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) HVAC grants were implemented as stipulated by law. These federally funded programs were reviewed as operated by Richmond City Public Schools. Furthermore, RPS is a subrecipient. As such it is our stance that RPS was not required to create or submit quarterly financial activity reports to US Treasury. We were also not required to submit quarterly financial reports to the recipient (i.e. the Commonwealth of Virginia). Instead, RPS regularly submitted expenditures for reimbursement to VDOE on a nearly monthly basis via OMEGA. We also maintained financial records (invoices, GL transactions) via AS400 and LINQ and conducted annual single audits as required by the Single Audit Act & 2 CFR part 200, subpart F. We also complied with all monitoring activities conducted by VDOE. In turn, VDOE (the award recipient) used these artifacts to create and submit its quarterly financial reports to US Treasury, as required by statute. For more evidence of this "passthrough" structure of reporting, see the attached SLFRF Compliance and Reporting Guidance published by US Treasury and Updated October 2025 Part 2 Section B (p. 21-22) for a detail of which entities are required to submit quarterly reports. The following recipients are required to submit quarterly Project and Expenditure Reports: - States and U.S. territories - Tribal governments that are allocated more than $30 million in SLFRF funding - Metropolitan cities and counties with a population that exceeds 250,000 residents Coronavirus State and Local Fiscal Recovery Funds C - Metropolitan cities and counties with a population below 250,000 residents that are allocated more than $10 million in SLFRF funding - NEUs [Non-Entitlement Units of Government] that are allocated more than $10 million in SLFRF funding RPS does not fall into any of the aforementioned categories. We humble ask that you reconsider this finding.

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2023-003 – Significant Deficiency and Compliance Qualification – Reporting Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) – United States Department of Education – Virginia Department of Education; Federal Award Year: 2023. Criteria: Project and Expenditure reports should be submitted to the VDOE quarterly and annually. Condition: The grant administrator was unable to provide quarterly and annual reporting requirements for fiscal year 2023. Cause: Documentation was not maintained for audit purposes. Effect: Accountability for use of the funds can not be demonstrated. Questioned Costs: None Recommendation: Grant administrator should maintain adequate documentation. Views of Responsible Officials and Planned Corrective Action: According to Appendix: American Rescue Plan CSLFRF HVAC Replacement and Improvement Grant Assurances of the 2021 CSLFRF HVAC Application it is stated the LEA/grantee assures: IX. It will submit such reports to the state educational agency as the state educational agency and Secretary may require to enable the state educational agency and the Secretary to perform their duties under the program; The LEA has also submitted an official correspondence to the Auditors from the Commonwealth of Virginia Department of Education’s Director of the Office of Federal Pandemic Relief Programs stating the following: On April 25, 2023, the Virginia Department of Education conducted monitoring to ensure that certain federally funded programs and activities supported with Elementary and Secondary School Emergency Relief (ESSER) formula grants; ESSER and Governor’s Emergency Education Relief (GEER) state setaside grants; and Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) HVAC grants were implemented as stipulated by law. These federally funded programs were reviewed as operated by Richmond City Public Schools. Furthermore, RPS is a subrecipient. As such it is our stance that RPS was not required to create or submit quarterly financial activity reports to US Treasury. We were also not required to submit quarterly financial reports to the recipient (i.e. the Commonwealth of Virginia). Instead, RPS regularly submitted expenditures for reimbursement to VDOE on a nearly monthly basis via OMEGA. We also maintained financial records (invoices, GL transactions) via AS400 and LINQ and conducted annual single audits as required by the Single Audit Act & 2 CFR part 200, subpart F. We also complied with all monitoring activities conducted by VDOE. In turn, VDOE (the award recipient) used these artifacts to create and submit its quarterly financial reports to US Treasury, as required by statute. For more evidence of this "passthrough" structure of reporting, see the attached SLFRF Compliance and Reporting Guidance published by US Treasury and Updated October 2025 Part 2 Section B (p. 21-22) for a detail of which entities are required to submit quarterly reports. The following recipients are required to submit quarterly Project and Expenditure Reports: - States and U.S. territories - Tribal governments that are allocated more than $30 million in SLFRF funding - Metropolitan cities and counties with a population that exceeds 250,000 residents Coronavirus State and Local Fiscal Recovery Funds C - Metropolitan cities and counties with a population below 250,000 residents that are allocated more than $10 million in SLFRF funding - NEUs [Non-Entitlement Units of Government] that are allocated more than $10 million in SLFRF funding RPS does not fall into any of the aforementioned categories. We humble ask that you reconsider this finding.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Action: According to Appendix: American Rescue Plan CSLFRF HVAC Replacement and Improvement Grant Assurances of the 2021 CSLFRF HVAC Application it is stated the LEA/grantee assures: IX. It will submit such reports to the state educational agency as the state educational agency and Secretary may require to enable the state educational agency and the Secretary to perform their duties under the program; The LEA has also submitted an official correspondence to the Auditors from the Commonwealth of Virginia Department of Education’s Director of the Office of Federal Pandemic Relief Programs stating the following: On April 25, 2023, the Virginia Department of Education conducted monitoring to ensure that certain federally funded programs and activities supported with Elementary and Secondary School Emergency Relief (ESSER) formula grants; ESSER and Governor’s Emergency Education Relief (GEER) state setaside grants; and Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) HVAC grants were implemented as stipulated by law. These federally funded programs were reviewed as operated by Richmond City Public Schools. Furthermore, RPS is a subrecipient. As such it is our stance that RPS was not required to create or submit quarterly financial activity reports to US Treasury. We were also not required to submit quarterly financial reports to the recipient (i.e. the Commonwealth of Virginia). Instead, RPS regularly submitted expenditures for reimbursement to VDOE on a nearly monthly basis via OMEGA. We also maintained financial records (invoices, GL transactions) via AS400 and LINQ and conducted annual single audits as required by the Single Audit Act & 2 CFR part 200, subpart F. We also complied with all monitoring activities conducted by VDOE. In turn, VDOE (the award recipient) used these artifacts to create and submit its quarterly financial reports to US Treasury, as required by statute. For more evidence of this "passthrough" structure of reporting, see the attached SLFRF Compliance and Reporting Guidance published by US Treasury and Updated October 2025 Part 2 Section B (p. 21-22) for a detail of which entities are required to submit quarterly reports. The following recipients are required to submit quarterly Project and Expenditure Reports: - States and U.S. territories - Tribal governments that are allocated more than $30 million in SLFRF funding - Metropolitan cities and counties with a population that exceeds 250,000 residents Coronavirus State and Local Fiscal Recovery Funds C - Metropolitan cities and counties with a population below 250,000 residents that are allocated more than $10 million in SLFRF funding - NEUs [Non-Entitlement Units of Government] that are allocated more than $10 million in SLFRF funding RPS does not fall into any of the aforementioned categories. We humble ask that you reconsider this finding.

About Reporting →

FY 2022-06-30

$123,962,653 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.

FY 2021-06-30

LOW-RISK AUDITEE$74,863,877 federal awards expended

FAC accepted this audit on May 17, 2023 — management decision was due November 17, 2023.

2021-001
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

Per the Program Manager, no monitoring activities (e.g., desk reviews or site visits performed at subrecipients? location) were performed during the fiscal year ended June 30, 2021. Cause: Per program management, no monitoring visits were scheduled due to risks related to the coronavirus (COVID-19) pandemic. Effect: The Richmond Public Schools is unable to ensure subrecipients effectively adhered to program requirements and Federal regulations. Questioned Costs: Undeterminable; however, Richmond Public Schools provided pass through funds totaling $1,148,895 to subrecipients as reimbursed expenditures. Recommendation: The Richmond Public Schools should effectively implement subrecipient monitoring controls to includes onsite monitoring visits and desk reviews to ensure program funds are being used as the grant intended. Views of Responsible Officials and Planned Corrective Action: RPS school and programs were either moved to virtual or suspended as a result of COVID. Thus the Head Start monitoring protocols were postponed, as a result of COVID. They resumed beginning with the 2021- 2022 school year. ? Contact Person: Kalota Stewart Gurley, Program Manager ? Corrective Action: Monitoring activities will resume for the 2021-2022 School year. ? Anticipated Completion Date: June 2022

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2021-001: Material Weakness and Compliance Qualification ? Subrecipient Monitoring Program: Head Start (ALN 93.600 - U.S. Department of Health and Human Services; Federal Award Number: not available; Federal Award Year: 2021 Criteria: Per 42 USC 9836a(d) and 45 CFR Sections 1304.51i(2) and (3), ?HSAs must establish and implement procedures for the ongoing monitoring of their own Head Start and Early Head Start operations, as well as those of their delegate agencies, to ensure that these operations effectively implement federal regulations, including procedures for evaluating delegate agencies and procedures for defunding them. Grantees must inform delegate agency governing bodies of any identified deficiencies in delegate agency operations identified in the monitoring review and assist them in developing plans, including timetables, for addressing identified problems.? Condition: Per the Program Manager, no monitoring activities (e.g., desk reviews or site visits performed at subrecipients? location) were performed during the fiscal year ended June 30, 2021. Cause: Per program management, no monitoring visits were scheduled due to risks related to the coronavirus (COVID-19) pandemic. Effect: The Richmond Public Schools is unable to ensure subrecipients effectively adhered to program requirements and Federal regulations. Questioned Costs: Undeterminable; however, Richmond Public Schools provided pass through funds totaling $1,148,895 to subrecipients as reimbursed expenditures. Recommendation: The Richmond Public Schools should effectively implement subrecipient monitoring controls to includes onsite monitoring visits and desk reviews to ensure program funds are being used as the grant intended. Views of Responsible Officials and Planned Corrective Action: RPS school and programs were either moved to virtual or suspended as a result of COVID. Thus the Head Start monitoring protocols were postponed, as a result of COVID. They resumed beginning with the 2021- 2022 school year. ? Contact Person: Kalota Stewart Gurley, Program Manager ? Corrective Action: Monitoring activities will resume for the 2021-2022 School year. ? Anticipated Completion Date: June 2022

Corrective Action Plan

Material Weakness and Compliance Qualification 2021-001 Subrecipient Monitoring Recommendation: The Richmond Public Schools should effectively implement subrecipient monitoring controls to include onsite monitoring visits and desk reviews to ensure program funds are being used as the grant intended. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: RPS school and programs were either moved to virtual or suspended as a result of COVID. Thus, the Head Start monitoring protocols were postponed, as a result of COVID. They resumed beginning with the 2021- 2022 school year. Name(s) of the contact person(s) responsible for corrective action: Ka Iota Stewart Gurley, Program Manager Planned completion date for corrective action plan: June 2022

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FY 2020-06-30

LOW-RISK AUDITEE$54,812,976 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 30, 2021 — management decision was due September 30, 2021.

FY 2019-06-30

LOW-RISK AUDITEE$56,907,865 federal awards expendedNo findings recorded this year

FAC accepted this audit on April 6, 2020 — management decision was due October 6, 2020.

FY 2018-06-30

$64,156,702 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 28, 2019 — management decision was due September 28, 2019.

FY 2017-06-30

$61,762,024 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 29, 2018 — management decision was due September 29, 2018.

FY 2016-06-30

$57,588,851 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 20, 2018 — management decision was due September 20, 2018.

Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.

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