Clarendon County School District

Failure to Comply with Special Test and Provision Guidelines - U.S. Department of Education, COVID-19 Education Stabilization Fund (ESF) (AL 84.425D) Pass-through from the South Carolina Department of Education Criteria: The terms of the Education Stabilization Fund (ESF) and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the District to inform private schools of available funding through the program. Condition: The District was unable to provide the proper documentation to show they performed the required steps for private schools in the area during the year ended June 30, 2021. Effect: The District has not complied with the special test and provision requirements, and therefore it is unknown whether proper funds were allocated to private schools. Cause: There was a lack of appropriate internal control policies and procedures implemented at the District during the fiscal year to ensure the requirements and procedures were performed for the program. Recommendation: Finance and management should be familiar with all aspects of the requirements and ensure that it has been followed for programs administered by the District. View of Responsible Officials and Planned Corrective Action: The District agrees with the finding and management will take necessary steps to adhere to the reporting requirements.

Failure to Comply with Reporting Guidelines - U.S. Department of Education, COVID-19 Education Stabilization Fund (ESF) (AL 84.425D) Pass-through from the South Carolina Department of Education Criteria: The terms of the Education Stabilization Fund (ESF) and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the District to submit quarterly reports to the SCDOE on the use of the ESSER funds. Condition: The District did not submit the required reports during the year ended June 30, 2021. Effect: The District has not complied with the reporting requirements, and the SCDOE did not receive the information. Cause: There was a lack of appropriate internal control policies and procedures implemented at the District during the fiscal year to ensure reporting requirements and procedures were performed for the program. Recommendation: Finance and management should be familiar with all aspects of the reporting requirements and ensure that it has been followed for programs administered by the District. View of Responsible Officials and Planned Corrective Action: The District agrees with the finding and management will take necessary steps to adhere to the reporting requirements.

Allowable Activities and Costs/Cost Principles – U.S. Department of Education, COVID-19 Elementary and Secondary School Emergency Relief Fund (ESSER) (AL 84.425D) Pass-through from the South Carolina Department of Education Criteria: In accordance with the terms of the Education Stabilization Fund (ESF) and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), charges to federal awards must, among other things: (1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (2) comply with the established accounting policies and practices of the non-federal entity. Condition and Context: For the fiscal year ended June 30, 2021, the District was not able to provide a list of employees and the amounts charged to the ESSER program. Management was also not properly approving expenditures and there were also missing invoices related to costs charged to the District’s federal award programs and non-federal award programs. We noted in our ESSER sample of payroll disbursements for testing of internal controls over compliance that the District was unable to provide a list of employees and the amounts for each employee that was charged to the program. We also noted in our District-wide sample disbursements for testing of internal controls over compliance that the majority of the checks in our sample had no approval for payment, purchase order, and that numerous invoices were unable to be located. Effects or possible effects: The District’s system of internal control did not identify the issue noted above and as a result, the District did not comply with established policies required by the Uniform Guidance and the SCDOE for charging costs to the federal program. Cause: A lack of oversight by personnel in the Federal Programs Department led to noncompliance with the requirements of the Uniform Guidance in relation to charging of costs to a federal grant. Questioned Costs: $1,401,094 Recommendation: We recommend authorized purchase requisitions and purchase orders be required where appropriate and completed prior to any encumbrance being placed on the District. Any invoice or similar document submitted for payment should be approved by someone other than the AP clerk, with documentation that the goods were received when applicable. We also recommend the District maintain a list of employees and amounts of each employee charged to the program. View of Responsible Officials and Planned Corrective Action: Management concurs with the finding. Management will take the necessary steps in the future to ensure that all invoices are properly approved before payment is rendered.

2020-009. Failure to Comply with Procurement Policy - U.S. Department of Agriculture, School NutritionCluster (CFDA 10.553 and 10.555) pass-through from the South Carolina Department of EducationCriteria: The terms of the School Nutrition Cluster and Title 2 U.S. Code of Federal Regulations (CFR) Part 200,Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UniformGuidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for solesource and emergencies, the following must be attached to the purchase requisition: for small purchases from$2,500.01 to $10,000 - 3 verbal or written quotes; for purchases from $10,000.01 to $25,000 - 3 written quotes arerequired; for small purchases from $25,000.01 to $50,000 - 5 written quotes are required. Competitive sealed bidsare required for any non-exempt procurements exceeding $50,000.Condition: The District did not follow its procurement policy for the year ended June 30, 2020. We did not findpurchase orders were consistently used when appropriate. There were two specific procurements exceeding$50,000 during the year for which we found no evidence of solicitation of bids.Effect of Condition and Questioned Costs: The District has not complied with its procurement policy, and it is notknown whether the District has paid a reasonable and competitive rate for the services provided on these twocontracts. The dollar amount of these two contracts was approximately $36,000.Cause: There was a lack of appropriate internal control policies and procedures implemented at the District duringthe fiscal year to ensure procurement policies and procedures were performed before disbursement of fundsoccurred.Recommendation: Finance and management should be familiar with all aspects of the Procurement Policy andensure that it has been followed for all non-exempt purchases made by the District.View of Responsible Officials and Planned Corrective Action: The District agrees with the finding andmanagement will take necessary steps to adhere to the procurement policy.

2020-010. Allowable Costs/Cost Principles ? U.S. Department of Agriculture, School Nutrition Cluster (CFDA10.553 and 10.555) pass-through from the South Carolina Department of Education and ? U.S. Departmentof Education Cluster (IDEA) (CFDA 84.027 and 84.173) pass-through from the South Carolina Department ofEducationCriteria: In accordance with the terms of the School Nutrition Cluster and Title 2 U.S. Code of Federal Regulations(CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards(Uniform Guidance), charges to federal awards must, among other things: (1) be supported by a system of internalcontrol which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and(2) comply with the established accounting policies and practices of the non-federal entity.Condition and Context: For the fiscal year ended June 30, 2020, the District was not properly approving invoicesfor costs reimbursed in the School Nutrition Cluster and was unable to locate some invoices in the IDEA EducationCluster. Management was not properly approving expenditures and there were also missing invoices related tocosts charged to the District?s federal award programs and non-federal award programs. We noted in our SchoolNutrition Cluster sample of disbursements for testing of internal controls over compliance that one check in oursample had no approval for payment. We also noted two invoices for the IDEA Education Cluster that the Districtwas unable to locate. We also noted in our District-wide sample of disbursements for testing of internal controls overcompliance that 11 checks in our sample had no approval for payment and one invoice was unable to be located.Effects or possible effects: The District?s system of internal control did not identify the issue noted above and as aresult, the District did not comply with established policies required by the Uniform Guidance and the South CarolinaDepartment of Education for charging costs to the federal program.Cause: A lack of oversight by personnel in the Federal Programs Department led to noncompliance with therequirements of the Uniform Guidance in relation to charging of costs to a federal grant.Questioned Costs: NoneRecommendation: We recommend authorized purchase requisitions and purchase orders be required whereappropriate and completed prior to any encumbrance being placed on the District. Any invoice or similar documentsubmitted for payment should be approved by someone other than the AP clerk, with documentation that the goodswere received when applicable.View of Responsible Officials and Planned Corrective Action: Management concurs with the finding.Management will take the necessary steps in the future to ensure that all invoices are properly approved beforepayment is rendered.99

2019-008 ? Failure to Comply with Procurement Policy - U.S. Department of Agriculture, School Nutrition Cluster (CFDA 10.553 and 10.555) pass-through from the South Carolina Department of Education Criteria: In accordance with the terms of the School Nutrition Cluster and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non- exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: for small purchases from $2500.01 to $10,000 - 3 verbal or written quotes; for purchases from $10,000.01 to $25,000 - 3 written quotes are required; for small purchases from $25,000.01 to $50,000 - 5 written quotes are required. Competitive sealed bids are required for any non-exempt procurements exceeding $50,000. Condition: The District did not follow its procurement policy for the year ended June 30, 2019. We did not find that purchase orders were consistently used when appropriate. There were two specific procurements exceeding $50,000 during the year for which we found no evidence of solicitation of bids. Effect of Condition: The District has not complied with its procurement policy, and it is not known whether the District has paid a reasonable and competitive rate for the services provided on these two contracts. The dollar amount of these two contracts were approximately $36,000. Cause: There was a lack of appropriate internal controls policies and procedures implemented at the District during the fiscal year to ensure that procurement policies and procedures were performed before disbursement of funds occurred. Recommendation: Finance and management should be familiar with all aspects of the Procurement Policy and ensure that it has been followed for all non-exempt purchases made by the District. Views of responsible officials and planned corrective actions: The District agrees with the finding and management will take necessary steps to adhere to the procurement policy.

2019-009. Allowable Costs/Cost Principles ? U.S. Department of Agriculture, School Nutrition Cluster (CFDA 10.553 and 10.555) pass-through from the South Carolina Department of Education Criteria: In accordance with the terms of the School Nutrition Cluster and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), charges to federal awards must, among other things: (1) be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; and (2) comply with the established accounting policies and practices of the non-federal entity. Condition and Context: For the fiscal year ended June 30, 2019, the District was not properly approving invoices for costs reimbursed by the School Nutrition Cluster as well expenditures in other funds not part of federal awards. We noted in our School Nutrition Cluster sample of disbursements for testing of internal controls over compliance that one check in our sample had no approval for payment. We also noted in our District wide sample of disbursements for testing of internal controls over compliance that 11 checks in our sample either had no approval for payment. Effects or possible effects: The District?s system of internal control did not identify the issue note above and as a result, the District did not comply with established policies required by the South Carolina Department of Education for charging costs to the federal program. Cause: A lack of oversight by personnel in the Federal Programs Department led to noncompliance with the requirements of Uniform Guidance in relation to charging of personnel costs to a federal grant.Question Costs: None Recommendation: We recommend authorized purchase requisitions and purchase orders should be required where appropriate and completed prior to any encumbrance being placed on the District. Any invoice or similar document submitted for payment should be approved by someone other than the AP clerk, with documentation that the goods were received when applicable. View of Responsible Officials and Planned Corrective Action: Management concurs with the finding. Management will take the necessary steps in the future to ensure that all invoices are properly approved before payment is rendered.

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