Chesterfield County School DistrictLocal Government

2023-001 – Internal Controls Surrounding Claim Reconciliation and Reimbursement Finding Type: Material Weakness in Internal Control over Compliance / Material Non-Compliance Program: Education Stabilization Fund (ALN #84.425) Compliance Area: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: Generally Accepted Accounting Principles and 2 CFR Part 200.303 requires that non-Federal entities 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 award. In addition, the SC Department of Education, the Pass-Through Entity, requires that all claims for expenditures through June 30th of any fiscal year be performed prior to August 15. Condition: The District failed to reconcile expenditures to filed claims to ensure that all expenditures were appropriately accounted for and timely claimed by the SC Department of Education deadline of August 15. The failure in the design of internal controls led to the Districts’ oversight of not timely claiming certain funds for the Education Stabilization Fund and the Special Education Cluster in the amount of $834,955 and $1,838,443, respectively. In addition, after performing appropriate reconciliations and final claims of the Education Stabilization Fund, the District had overclaimed funds and is required to return $114,865 to the SC Department of Education for use in future fiscal years. Cause: The District failed to have an adequate documented system of internal controls in place surrounding the claims process for federal claims passed through the SC Department of Education. Effect: Despite the SC Department of Education making an exception to allow the District to claim these funds past the deadline, the failure to properly reconcile and timely claim expenditures could result in the loss of the District’s ability to claim the federal funds. Any expenditures not allowed to be claimed after the State’s deadline would have to be transferred from the federal program to the general fund of the District. Auditor’s Recommendations: The District should implement internal control processes and monitoring to ensure grant expenditures are appropriately reconciled and claims filed quarterly.

2023-002 – Internal Controls over Compliance with Documentation of Personnel Expenses Finding Type: Significant Deficiency in Internal Control over Compliance Program: Education Stabilization Fund (ALN #84.425) Compliance Area: Allowable Costs/Cost Principles Criteria: 2 CFR Part 200.430(i) Standards for Documentation of Personnel Expenses requires that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated, reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities, and 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. Condition: The District did not appropriately reflect the federal awards for which certain employee salaries and wages were charged, including the improper use of a semi-annual certification and timesheets that do not depict the federal award from which the salaries and wages are paid. Cause: The District failed to ensure pre-filled forms were not used for certain employees being charged to federal awards. In addition, the District failed to fully understand the appropriate uses of a semi-annual certification. Effect: Failure to properly document personnel expenses could result in non-compliance and dis-allowed costs, resulting in the loss of federal funds. Auditor’s Recommendations: It is recommended that the District communicate to all departments that pre-filled forms should not be utilized when documenting salaries and wages charged to federal awards. In addition, the District should review the requirement for personnel activity reports and semi-annual certifications to ensure the use of either is appropriate in each circumstance.

2023-003 – Internal Controls over Compliance and Non-Compliance with Wage Rate Requirements Finding Type: Material Weakness in Internal Control over Compliance / Material Non-Compliance Program: Education Stabilization Fund (ALN #84.425) Compliance Area: Special Tests and Provisions Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction requires that nonfederal entities include in their federally funded construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the related DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance. Condition: Certain District federally funded construction contracts did not contain the appropriate contract provisions for contractor compliance with wage rate requirements, nor were weekly certified payrolls obtained from contractors prior to payment. Cause: The District’s design of the internal control procedures surrounding wage rate requirements for federally funded construction contracts was not properly designed so that it failed to appropriately meet the control objectives of identifying and complying with federal requirements. The District, at the time these contracts were signed and approved, was unaware of the federal wage rate requirements. Effect: Failure to comply with federal Wage Rate Requirements could result in non-compliance and dis-allowed costs, resulting in the loss of federal funds. Recommendation: The District should implement standard procedures to ensure all construction contracts funded with federal dollars contain the appropriate contract provisions as well as ensure that certified payrolls are received with each request for payment.