DeKalb County School District

EIN: 586000227

UEI: GU56TZLJ71X9

Data as of August 19, 2026

10
Audit Years
17
Total Findings
8
Repeat Findings

FY 2025-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 27, 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 September 27, 2026 (38 days from today).

What is a management decision? →
2025-001
Cost Allowability
REPEATQUESTIONED COSTS
Condition

Compliance Requirement: Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program Federal Award Number: 255GA324N1199 (Year: 2025) Questioned Costs: $7,474 Repeat of Prior Year Finding: FA 2024-001, FA 2023-004 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Child Nutrition Cluster. Background Information: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential childcare institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $60,051,234.81 were expended and reported on the DeKalb County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2025. Criteria: As a recipient of federal awards, the School District is required to establish, document, and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the recipient or subrecipient… (g) Be adequately documented…” Furthermore, provisions included in the Uniform Guidance, Section 200.430 – Compensation-Personal Services prescribe standards for documentation of personnel expenses and state, in part, that “(a) … Costs for compensation are allowable to the extent that they satisfy… specific requirements… and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the recipient or subrecipient consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a recipient’s or subrecipient’s laws, rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (g)…, [as follows:] (g) 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 that provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the recipient or subrecipient…” Condition: A sample of 60 employees was randomly selected for testing using a non-statistical sampling approach. These employees were reviewed to determine if internal controls were properly functioning, and applicable compliance requirements were met. The following deficiencies were noted: • One employee was paid on the incorrect pay scale and thus was overpaid by $4,903. • Two employees were paid on the incorrect pay scale and thus were underpaid by $1,287. • Additional pay totaling $967 for 2 employees was incorrectly charged to the federal program. • Documentation of retrospective pay totaling $317 could not be located for 1 employee. Questioned Costs: Upon testing a sample of $1,643,657 in personnel services expenditures, known questioned costs of $7,474 were identified for payroll charges not supported by adequate documentation. Using the total personnel services expenditure population of $20,618,901 (excluding benefits payments), we project the likely questioned costs to be approximately $93,759. The following Assistance Listing Numbers were affected by known and likely questioned costs: 10.553 and 10.555. Cause: A lack of oversight by personnel in the Office of Federal Grants and Program Compliance led to noncompliance with the requirements of the Uniform Guidance in relation to charging of personnel costs to a federal program.   Effect: The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to pay employees with CNC funds the appropriate amount and/or maintain documentation supporting those payments could result in the expenditure of funds for unallowable purposes. This may also expose the School District to unnecessary financial strains and shortages within the CNC funds as ED or GaDOE may require the School District to return funds associated with improperly documented expenditures. Recommendation: The School District should evaluate their internal control process related to the approval and retention of documentation to support employee compensation payments. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that CNC employees are paid appropriately. Furthermore, management should develop and implement a monitoring process to ensure that these procedures are functioning properly. Views of Responsible Officials: The District acknowledges the audit team’s findings regarding undocumented additional pay and the isolated instances of overpayment identified during the testing of School Food Nutrition program. While the District remains committed to absolute fiscal accuracy, we believe the following context is essential for a complete understanding of the program’s scale and the nature of the identified error. • Scale of Operations: The District’s School Food Nutrition program is a massive operation, serving over 90,000 students across 124 separate kitchens. This decentralized environment requires the management of approximately 900 personnel and a total salary expenditure of $20,618,901. • Statistical Significance vs. Actual Error: The audit identified actual errors totaling $7,474. While the District understands that federal auditing standards (Uniform Guidance) require this amount to be extrapolated across the entire $20.6M population-resulting in a projected error exceeding the $25,000 mandatory reporting threshold-it is important to note that the actual identified discrepancy represents only 0.036% of the program’s personnel budget. • Accuracy Rate: Even when utilizing the extrapolated figure of $25,000, the District maintains a 99.64% accuracy rate in payroll processing for this program. We believe this demonstrates a robust internal control environment, particularly given the complexities of managing 124 distinct points of service. • Disproportionate Reporting Thresholds: The District notes that the $25,000 reporting threshold is a fixed statutory limit that does not scale with the size of the Local Educational Agency (LEA). Consequently, a District of our size is held to a significantly more compressed margin of error (less than one-eighth of one percent) than a smaller district with fewer employees and sites. Auditor’s Concluding Remarks: While the questioned costs identified by auditors appear to be relatively small in the context of the School District’s overall School Nutrition expenditures, the amounts exceed the reporting threshold established by the Uniform Guidance. This threshold is designed to ensure consistent reporting of noncompliance across entities of all sizes. Given the information reflected above, we reaffirm our finding and will review the status of the finding during our next audit.

Corrective Action Plan

Despite the high overall accuracy rate, the District is taking immediate steps to address identified compensation and documentation issues. We have corrected pay scale deficiencies to ensure employees receive proper compensation and implemented additional review controls to prevent future errors. We have also strengthened our account coding procedures to ensure compensation charges are applied to the appropriate funding sources. Additionally, we have updated our digital time-tracking approval workflow to require contemporaneous authorization and improve documentation retention for all supplemental and retrospective compensation. Estimated Completion Date: March 31, 2026 Contact Person: Byron Schueneman, Chief Financial Officer

Prior Finding References

2024-001, 2023-004

About Allowable Costs / Cost Principles →

FY 2024-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on June 10, 2025. 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 10, 2025, which was (253 days ago).

What is a management decision? →
2024-001
Cost Allowability
QUESTIONED COSTS
Condition

FA 2024-001 Improve Controls over Employee Compensation Compliance Requirement: Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program COVID-19 – 10.555 – National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024) 225GA324N1099 (Year: 2024) Questioned Costs: $102,234 Repeat of Prior Year Finding: 2023-004 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Child Nutrition Cluster. Background Information: The Child Nutrition Cluster (CNC) is comprised of various programs that are intended to assist states in administering and overseeing food service program operators that provide healthful, nutritious meals to eligible children in public and non-profit private schools, residential childcare institutions, and summer programs. This Cluster of programs also fosters healthy eating habits in children by providing fresh fruits and fresh vegetables to children attending elementary and secondary schools and encourages the domestic consumption of nutritious agricultural commodities. CNC funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture. GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $58,647,091.23 were expended and reported on the DeKalb County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2024. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented…” Furthermore, provisions included in the Uniform Guidance, Section 200.430 – Compensation-Personal Services prescribe standards for documentation of personnel expenses and state, in part, that “(a) … Costs for compensation are allowable to the extent that they satisfy… specific requirements…, and that the total compensation for individual employees: (1) is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity’s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i)…, [as follows:] (i) 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…” Condition: A sample of 60 employees was randomly selected for testing using a non-statistical sampling approach. These employees were reviewed to determine if internal controls were properly functioning, and applicable compliance requirements were met. The following deficiencies were noted: • One employee who no longer worked for the School District received salary payments totaling $8,715. • Two employees did not have any of the required certifications, or comparable documentation, to support their salary payments totaling $48,837. • One employee was missing required certifications, or comparable documentation, to support a portion of their salary payments totaling $8,128. • One employee’s salary in the amount of $2,671 was incorrectly charged to the federal program for one pay period. • Documentation of additional pay totaling $33,883 could not be located for 14 employees. Questioned Costs: Upon testing a sample of $1,399,390 in personnel services expenditures, known questioned costs of $102,234 were identified for payroll charges not supported by adequate documentation. Using the total personnel services expenditure population of $18,999,516 (excluding benefits payments), we project the likely questioned costs to be approximately $1,388,035. The following Assistance Listing Numbers were affected by known and likely questioned costs: 10.553 and 10.555. Cause: A lack of oversight by personnel in the Office of Federal Grants and Program Compliance led to noncompliance with the requirements of the Uniform Guidance in relation to charging of personnel costs to a federal program. Effect: The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to pay employees with CNC funds the appropriate amount and/or maintain documentation supporting those payments could result in the expenditure of funds for unallowable purposes. This may also expose the School District to unnecessary financial strains and shortages within the CNC funds as ED or GaDOE may require the School District to return funds associated with improperly documented expenditures. Recommendation: The School District should evaluate their internal control process related to the approval and retention of documentation to support employee compensation payments. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that CNC employees are paid appropriately. Furthermore, management should develop and implement a monitoring process to ensure that these procedures are functioning properly. Views of Responsible Officials: We concur with this finding.

Corrective Action Plan

FA 2024-001 Improve Control over Employee Compensation Compliance Requirement: Allowable Costs/Cost Principle Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19-10.555 - National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: $102,234 Prior Year Finding: 2023-004 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Child Nutrition Cluster. Corrective Action Plans: The District is developing correction action to strengthen controls, policies, and procedures and ensure adherence through improved monitoring. Estimated Completion Date: June 30, 2026 Contact Person: Connie Walker, School Nutrition Executive Director Telephone: 678-676-1780 Email: Connie_R_Walker@dekalbschoolsga.org

About Allowable Costs / Cost Principles →

FY 2023-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on April 28, 2025. 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 October 28, 2025, which was (296 days ago).

What is a management decision? →
2023-004
Activities Allowed or Unallowed
MATERIAL WEAKNESSQUESTIONED COSTS
Condition

Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Pass-Through Agency: Georgia Department of Education Finding: 2023-004 – Allowable Costs Criteria: In accordance with the terms of the Child Nutrition Grant and 2 CFR 200, Cost Principles for States, Local Governments, and Indian Tribes, specific documentation must be maintained to support salaries and wages charged to the federal program. Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semiannually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports or equivalent documentation. Condition and Context: For the fiscal year ended June 30, 2023, internal controls over compliance were not sufficient to ensure the District was properly charging payroll costs which were reimbursed by the Child Nutrition grant. In our sample of forty (40) employees who were paid with Child Nutrition funds, we noted two of the selected employees did not have any of the required monthly certifications, six employees were missing one or more month’s certifications, and four employees’ certifications were missing signatures from the supervising official. Cause: A lack of oversight by personnel in the Office of Federal Grants and Program Compliance led to noncompliance with the requirements of the Uniform Guidance in relation to charging of personnel costs to a federal grant. Effects or Possible Effects: Personnel salaries unrelated to eligible Child Nutrition activities could be charged to and reimbursed by the District’s federal grants. Questioned Costs: All amounts paid to those employees who did not have a semiannual certification could be questioned. These amounted to $247,000. When comparing the known questioned costs to the sample total of $16,683,000, the error rate for the selected sample was 5%. The error rate projected onto the total population of payroll costs, resulted in a likely questioned cost of $4,884,000. Recommendation: We recommend District personnel perform periodic reviews of the general ledger to ensure appropriate documentation is obtained for all payroll costs charged to the Child Nutrition grant. Furthermore, in instances where changes are made to employee assignments (including termination) involving federal grants, we recommend the District review payroll costs for those employees in the periods immediately following the changes to ensure they are appropriately reflected in the accounting records and thus properly charged to the District’s federal grant programs. Auditee’s Response: We concur with this finding.

Corrective Action Plan

2023-004 Allowable Costs Program Name: Child Nutrition Cluster Assistance Listing Number: 10.553 and 10.555 Pass-Through Agency: Georgia Department of Education Criteria: In accordance with the terms of the Child Nutrition Grant and 2 CFR 200, Cost Principles for States, Local Governments, and Indian Tribes, specific documentation must be maintained to support salaries and wages charged to the federal program. Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports or equivalent documentation. Corrective Action Plan: We concur with this finding. The District is developing corrective actions to strengthen Child Nutrition Cluster Department internal controls, policies, and procedures and ensure adherence through improved monitoring. Through collaboration, the Finance Division and the School Nutrition Department will review payroll detail reports and ensure periodic certifications for all employees are completed timely. Estimated Completion Date: Fiscal Year 2025 Contact Person: Dr. Connie Walker, School Nutrition Executive Director Telephone: 678-676-1200 E-mail: Connie_R_Walker@dekalbschoolsga.org

About Activities Allowed or Unallowed →
2023-005
Equipment & Real Property
MATERIAL WEAKNESSQUESTIONED COSTS
Condition

U.S. Federal Communications Commission Program Name: Emergency Connectivity Funds Assistance Listing Number: 32.009 Finding: 2023-005 – Equipment & Real Property Management Criteria: Internal controls should be in place to ensure that equipment and real property management requirements are met as specified in the guidance provided by the Federal Communications Commission (FCC). FCC guidance specified that the District was required to maintain asset inventories of the devices purchased with the ECF program. The Uniform Guidance requires any recipients of federal awards to comply with the equipment and real property management requirements indicated by the grantor agency. Condition: The District did not have adequate internal controls to ensure compliance with equipment and real property management requirements. Context/cause: During our testing of equipment and real property requirements, the District made bulk purchases of laptops and wi-fi hot spots that had a total purchase value over the $10,000 capital asset threshold. Upon the initial review of the District’s capital asset listing, these bulk equipment purchases were not included. An adjustment in the General Fund totaling $19,776,000 was required to report the capital outlay expenditure and grant revenue. Effect: Equipment purchases made with grant funding could be improperly excluded from the capital asset listing which would misstate the District’s capital asset balances. Questioned Costs: $19,776,000 Recommendation: We recommend the District enhances internal controls to ensure accuracy and compliance with equipment and real property requirements. Auditee’s Response: We concur with this finding.

Corrective Action Plan

2023-005 Equipment and Real Property Management Program Name: Emergency Connectivity Funds Assistance Listing Number: 32.009 Pass-Through Agency: Criteria: Internal controls should be in place to ensure that equipment and real property management requirements are met as specified in the guidance provided by the Federal Communications Commission (FCC). FCC guidance specified that the District was required to maintain asset inventories of the devices purchased with the ECF program. The Uniform Guidance requires any recipients of federal awards to comply with the equipment and real property management requirements indicated by the grantor agency. Corrective Action Plan: We concur with this finding. The District is developing corrective actions to strengthen Technology Division internal controls, policies, and procedures and ensure adherence through improved monitoring. The Capital Asset policy will be updated to document the District’s guidelines around bulk purchases, which will go before the Board for approval. Finance will work with all Divisions to ensure qualifying purchases are recorded in the financial records and properly inventoried. Estimated Completion Date: Fiscal Year 2025 Contact Person: Dr. Kermit Belcher, Interim Chief Technology Officer Telephone: 678-676-1200 E-mail: Kermit_Belcher@dekalbschoolsga.org

About Equipment and Real Property Management →

FY 2022-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on July 5, 2023. 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 January 5, 2024, which was (958 days ago).

What is a management decision? →
2022-001
Activities Allowed or Unallowed / Cost Allowability
QUESTIONED COSTS
Condition

FA 2022-001 Improve Budgetary Controls over Expenditures Compliance Requirements: Activities Allowed/Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021) Questioned Costs: $62,747.69 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed instances in which expenditures had not been properly approved by the pass-through entity. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $199,433,680.30 were expended and reported on the DeKalb County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? To assist school districts in improving their financial management systems and associated compliance over federal programs, GaDOE published the Financial Management for Georgia Local Units of Administration (FMGLUA) manual. The FMGLUA manual requires that LEAs submit a budget as part of each federal program?s Consolidated Application process. The program budget reflects details regarding the manner in which each school district intends to expend the program funds. The Consolidated Application, including the budget, for each program must be reviewed and approved by GaDOE personnel before the LEA is authorized to expend program funds. Amendments to the budget are to be submitted to and approved by GaDOE when a school district intends to spend funds in a manner not initially reported. Further, LEA personnel must also provide program-specific assurances related to the ESSER program within the Consolidated Application system. These assurances are reflected in the Uniform Guidance, Section 200.415 ? Required Certifications, and include provisions that require LEAs ?to assure that expenditures are proper and in accordance with the terms and conditions of the Federal award and approved project budgets?? Condition: A sample of 60 nonpersonal services expenditures was randomly selected for testing using a non-statistical sampling approach. Four individually significant items were also selected for testing. These expenditures were reviewed to determine if appropriate internal controls were implemented and applicable compliance requirements were met. Upon completing this testing, it was noted that three individually significant items totaling $48,037.69 and two randomly selected expenditures totaling $14,710.00 were not appropriately approved by GaDOE through the Consolidated Application process as required. Questioned Costs: Upon testing a sample of $2,037,733.28 in nonpersonal services expenditures, known questioned costs of $14,710.00 were identified. Using the total nonpersonal services expenditure population of $47,278,482.26, we project the likely questioned costs to be approximately $798,116.60. In addition, known questioned costs identified for improper payments associated with individually significant items tested totaled $48,037.69; therefore, the known and likely questioned costs identified for all unallowable payments throughout the sample and individually significant items tested totaled $62,747.69 and $846,154.29, respectively. Cause: In discussing these deficiencies with management, they stated that inadequate staffing levels led to the School District?s failure to establish appropriate internal control procedures, such as a review by appropriate personnel to ensure compliance with the Consolidated Application prior to the expenditure of federal funds. Additionally, the existence of multiple programs and associated Consolidated Applications led to the School District?s failure to establish appropriate internal control procedures to ensure the expenditure was approved on the specific Consolidated Application that funded the expenditure. Effect: The School District was not in compliance with the Uniform Guidance or GaDOE guidance related to the ESSER program. Failure to accurately develop and amend budget information through the Consolidated Application process and verify compliance with applicable policies and regulations prior to the expenditure of federal program funds may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with unapproved and unallowable expenditures. Recommendation: The School District should revise current internal control procedures related to the ESSER program. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that potential expenditures are approved through the Consolidated Application process and deemed to be allowable before spending federal funds. In addition, management should develop and implement a monitoring process to ensure that control procedures are being followed. Views of Responsible Officials: We concur with this finding.

Corrective Action Plan

FA 2022-001 Improve Budgetary Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) Questioner Costs: $62,747.69 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed instances in which expenditures had not been properly approved by the pass-through entity. Corrective Action Plans: We concur with this finding. The District is developing correction actions to strengthen internal controls, policies, and procedures and ensure adherence through improved monitoring. Estimated Completion Date: Fiscal Year 2024 Contact Person: Dr. Myisha Warren, Executive Director of Federal Programs Telephone: 678-676-1200 Email: Myisha_Warren@dekalbschoolsga.org

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2022-002
Activities Allowed or Unallowed / Cost Allowability
QUESTIONED COSTS
Condition

FA 2022-002 Improve Controls over Indirect Costs Compliance Requirements: Activities Allowed/Unallowed Allowable Costs/Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $559,442.53 Description: The School District charged indirect cost expenditures to the Elementary and Secondary School Emergency Relief Fund program in excess of the maximum amount allowed. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $199,433,680.30 were expended and reported on the DeKalb County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity, (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost?? To assist school districts in improving their financial management systems and associated compliance over federal programs, GaDOE published the Financial Management for Georgia Local Units of Administration (FMGLUA) manual. The FMGLUA manual requires that LEAs exclude certain costs in the calculation of the net expenditures to which the approved indirect cost rate can be applied, including the cost of capitalizable assets, rental costs, tuition remission, scholarships and fellowships, payments to charter schools, and subawards in excess of $25,000. Condition: A review of the School District?s accounting records and supporting documentation revealed that costs associated with capitalizable equipment, payments to charter schools, and rental costs were not appropriately deducted in the calculation of the net expenditures to which the approved unrestricted indirect cost rate was applied. Therefore, the School District claimed an additional $559,442.53 in indirect costs beyond the maximum indirect cost amount allowed. Questioned Costs: Known questioned costs of $559,442.53 were identified for excess indirect cost expenditures claimed. These known questioned costs related to expenditures that were not tested as part of a sample, and therefore, should not be projected to a population to determine likely questioned costs. Cause: In discussing these deficiencies with management, they stated that inadequate controls over decentralized activity input led to the School District?s failure to establish appropriate internal control procedures over recording ledger activity. Effect: The School District is not in compliance with the Uniform Guidance or GaDOE guidance related to the ESSER program. Failure to ensure that appropriate indirect cost amounts are charged to the ESSER program may expose the School District to unnecessary financial strains and shortages as GaDOE may require the School District to return funds associated with these unallowable expenditures. Recommendation: The School District should revise current internal control procedures related to the ESSER program. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that ledger activity is recorded accurately. In addition, management should develop and implement a monitoring process to ensure that control procedures are being followed. Views of Responsible Officials: We concur with this finding.

Corrective Action Plan

FA 2022-002 Improve Controls over Indirect Costs Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021), S425U2120012 (Year: 2021) Questioner Costs: $559,442.53 Description: The School District charged indirect cost expenditures to the Elementary and Secondary School Emergency Relief Fund program in excess to the maximum amount allowed. Corrective Action Plans: We concur with this finding. The District is developing corrective actions to strengthen internal controls, policies, and procedures and ensure adherence through improved monitoring. Estimated Completion Date: Fiscal Year 2024 Contact Person: Dr. Myisha Warren, Executive Director of Federal Programs Telephone: 678-676-1200 Email: Myisha_Warren@dekalbschoolsga.org

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2022-003
Equipment & Real Property
Condition

FA 2022-003 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: COVID-19 ? 84.425D ? Elementary and Secondary School Emergency Relief Fund COVID-19 ? 84.425U ? American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Numbers: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S425U210012 (Year: 2021) Questioned Costs: None Identified Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Elementary and Secondary School Emergency Relief Fund program. Background: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the American Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allotted funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $199,433,680.30 were expended and reported on the DeKalb County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2022. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Provisions included in the Uniform Guidance, Section 200.313(d)(1) state, ?Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property.? In addition, the Uniform Guidance, 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 following deficiencies were noted when reviewing the ESSER program equipment listing and related invoice documentation: ? Equipment items totaling $163,730.00 were included on the financial statement capital asset listing but were excluded from the program equipment listing; therefore, property records did not include the following required components for the omitted equipment items: (1) A description of the property, (2) a serial number or other identification number, (3) the source of funding for the property (including the FAIN), (4) who holds title, (5) the acquisition date, (6) cost of the property, (7) percentage of Federal participation in the project costs for the Federal award under which the property was acquired, (8) the location, and (9) use and condition of the property. ? Building improvements of $3,573,167.42 were excluded from the program equipment listing. ? Because these items were not included on the program equipment listing, a complete physical inventory was not performed and reconciled back to the property records. Cause: In discussing this deficiency with the School District, they stated that those items included on the capital asset listing and excluded from the program equipment listing were discovered after preparation and submission of the program equipment listing but prior to the submission of the financial statement capital asset listing. In addition, the building improvements are capitalized at a higher threshold for financial statement purposes and were overlooked by the School District when preparing the program equipment listing. Effect: The School District is not in compliance with the Uniform Guidance or GaDOE guidance related to the ESSER program. Failure to maintain a complete and accurate equipment listing and reconcile results of the physical inventory performed to the property records exposes the School District to unnecessary risk of error and misuse of equipment and/or Federal funds. Recommendation: The School District should develop and maintain an equipment listing that reflects all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment. In addition, management should implement controls to ensure that a complete physical inventory of equipment is performed, and the results are reconciled back to the equipment listing at least once every two years. Further, management should develop and implement a monitoring process to ensure that control procedures are being followed. Views of Responsible Officials: We concur with this finding.

Corrective Action Plan

FA 2022-003 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S425U2120012 (Year: 2021) Questioner Costs: None Identified Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: We concur with this finding. The District is developing corrective actions to strengthen internal controls, policies, and procedures and ensure adherence through improved monitoring. Estimated Completion Date: Fiscal Year 2024 Contact Person: Dr. Myisha Warren, Executive Director of Federal Programs Telephone: 678-676-1200 Email: Myisha_Warren@dekalbschoolsga.org

About Equipment and Real Property Management →

FY 2021-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on June 2, 2022. 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 2, 2022, which was (1357 days ago).

What is a management decision? →
2021-001
Activities Allowed or Unallowed
QUESTIONED COSTS
Condition

FA 2021-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs / Cost Principles Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education AL Number and Title: COVID-19 84.425D ? Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) S425D20012 (Year: 2020) Questioned Costs: $29,094 Description: A review of expenditures charged to the Elementary and Secondary Emergency Relief Fund programs (Assistance Listing Number 84.425D) revealed that the School District?s internal control procedures were not operating to ensure that expenditures were appropriately documented to support allowability. Background Information: On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The CARES Act was designed to mitigate the economic effects of the COVID-19 pandemic in a variety of ways, including providing additional funding for local educational agencies (LEAs) navigating the impact of the COVID-19 outbreak. Provisions included in Title VIII of the CARES Act created the Education Stabilization Fund to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. The CARES Act allocated $30.75 billion, the Coronavirus Response and Relief Supplemental Appropriations Act allocated an additional $81.9 billion, and the America Rescue Plan Act added $165.1 billion in funding to the Education Stabilization Fund. Multiple Education Stabilization Fund subprograms were created and allocated funding through the various COVID-19-related legislation. Of these programs, the Elementary and Secondary School Emergency Relief (ESSER) Fund was created to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. ESSER funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE was responsible for distributing funds to LEAs and overseeing the expenditure of funds by LEAs. ESSER funds totaling $43,030,709 were expended and reported on the DeKalb County Board of Education?s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2021. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. In addition, provisions included in Title VIII of the CARES Act state that the Education Stabilization Fund was established ?to prevent, prepare for, and respond to coronavirus.? Specifically, Section 18003(d) of the CARES Act lists 12 allowable uses of ESSER funds by LEAs. Furthermore, provisions included in the Uniform Guidance, Section 200.403 ? Factors Affecting Allowability of Costs state that ?costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? (g) Be adequately documented?? Lastly, provisions included in the Uniform Guidance, Section 200.430 ? Compensation-Personal Services prescribe standards for documentation of personnel expenses and state, in part, that ?(a) ? Costs for compensation are allowable to the extent that they satisfy? specific requirements?, and that the total compensation for individual employees: (1) is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i)?, [as follows:] (i) 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?? Condition: A random sample of 60 employees was selected for testing using a non-statistical sampling approach. These employees were reviewed to determine if internal controls were properly functioning, and applicable compliance requirements were met. The following deficiencies were noted: ? Three Human Resources/Payroll employees received supplements totaling $23,000 for which Board approval was not obtained and documentation did not exist to evidence additional work performed. ? The School District could not provide documentation for salary payments totaling $3,320 to two employees. ? One employee received a retention bonus in the amount of $1,413 but was not classified under an eligible job code for such payment. ? Documentation could not be provided to support the rate paid to one employee and resulted in a total overpayment of $1,361. Questioned Costs: Upon testing a sample of $131,698 in personal services expenditures, known questioned costs of $29,094 were identified for expenditures not supported by adequate documentation. Using the total nonpersonal services expenditure population of $37,797,179 (excluding benefits payments), we project the likely questioned costs to be approximately $959,493. Cause: In discussing these deficiencies with management, they stated that preliminary guidance associated with the ESSER program was ambiguous, and cumulative, clarifying guidance was not published until more than a year after the initial ESSER funding was allocated to the School District. Therefore, the School District misinterpreted the initial guidance that was available at the beginning of Fiscal Year 2021. Therefore, there was a lack of internal controls over salaries paid with ESSER funding. Effect: The School District is not in compliance with the Uniform Guidance or ED guidance related to the ESSER program. Failure to ensure that appropriate documentation exists to support the allowability of payments from the ESSER fund may expose the School District to unnecessary financial strains and shortages as ED or GaDOE may require the School District to return funds associated with improperly documented expenditures. Recommendation: The School District should review current internal control procedures related to ESSER program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that expenditures are appropriately documented and reflect the connection to the purpose of the ESSER program funds, which is ?to prevent, prepare for, and respond to coronavirus.? Furthermore, management should develop and implement a monitoring process to ensure that controls are operating appropriately. Views of Responsible Officials: We concur with this finding.

Corrective Action Plan

FA 2021-001 Strengthen Controls over Expenditures Compliance Requirement: Allowable Costs / Cost Principles ? Direct Costs Internal Control Impact: Significant Deficiency Compliance Requirement: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: Education Stabilization Fund (84.425) Federal Award Number: S425S210012 Questioned Costs: $959,493.00 Description: A review of expenditures charged to the elementary and Secondary Emergency Relief Fund programs (Assistance Listing 84.425D) revealed that the School District?s internal control procedures were not operating to ensure that expenditures were appropriately documented to support allowability. Corrective Action Plans: We concur with the finding. We will work with all entities to ensure that all existing internal controls are adhered to by developing and implementing an improved monitoring process. Estimate Completion Date: 08-01-2022 Contact Person: Shaun Thompson, Title I and ESSER Director Telephone: 678-676-0452 Email: Shaun_O_Thompson@dekalbschoolsga.org

About Activities Allowed or Unallowed →

FY 2020-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on July 24, 2022. 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 January 24, 2023, which was (1304 days ago).

What is a management decision? →
2020-001
Equipment & Real Property
REPEAT
Condition

FA 2020-001 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education CFDA Number and Title: Child Nutrition Cluster (CFDA 10.553 and 10.555) Federal Award Numbers: 205GA324N1099 Questioned Costs: None Identified Repeat of Prior Year Finding: FA 2019-001, FA 2018-001, FA 2017-002, and FA 2016-001 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Child Nutrition Cluster. Criteria: 2 CFR 200.313(d)(1) states, ?Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property". In addition, 2 CFR 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 following deficiencies were noted when reviewing the Child Nutrition Cluster equipment listing and physically locating equipment items: ??Property records did not include the following required components for all equipment items: (1) the source of funding for the property (including the FAIN), (2) who holds title, (3) the acquisition date, (4) cost of the property, (5) percentage of Federal participation in the project costs for the federal award under which the property was acquired, and (6) use and condition of property. ??While a physical inventory was performed and a listing is maintained, the property records for the equipment items were not fully updated to reflect the results. Cause: In discussing this deficiency with the School District, they stated that a physical inventory was performed, but due to the delay in the timing of the inventory as a result of COVID, they have not yet been able to resolve all discrepancies identified. In addition, though significant errors were made in updating the equipment listing. School District personnel were unable to complete this process due to time and physical access constraints posed by the COVID closures. Effect or Potential Effect: Failure to maintain a complete an accurate equipment listing and reconcile results of the physical inventory performed to the property records exposes the School District to unnecessary risk of error and misuse of equipment and/or Federal funds. Additionally, the School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance. Recommendation: The School District should develop and maintain an equipment listing that reflects all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of Federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment. In addition, management should implement controls to ensure that a complete physical inventory of equipment is performed, and the results are reconciled back to the equipment listing at least once every two years. Views of Responsible Officials: We concur with this finding.

Corrective Action Plan

FA 2020-001 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Significant Deficiency Compliance Requirement: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education CFDA Number and Title: Child Nutrition Cluster (CFDA 10.553 and 10.555) Federal Award Number: 205GA324N1099 Questioned Costs: None Identified Repeat of Prior Year Finding: FA2019-001, FA 2018-001, FA 2017-001, and FA 2016-001 Corrective Action Plans: Management agrees with this finding. Controls are being implemented to ensure complete and accurate tracking of equipment to include physical inventory audits in accordance with federal regulations, 2 CFR 200.313. School Nutrition employed an Inventory Specialist in May 2020. The Inventory Specialist and the Finance Capital Asset team conducted physical inventories of all District locations in the first quarter of 2021. Estimate Completion Date: June 30, 2021 Contact Person: Charles Burbridge, CFO Telephone: (678) 676-1200 Email: Charles_Burbridge@dekalbschoolsga.org

Prior Finding References

2019-001

About Equipment and Real Property Management →
2020-002
Procurement & Suspension/Debarment
REPEAT
Condition

FA 2020-002 Improve Controls over Procurement Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education CFDA Numbers and Title: 84.027 and 84.173 Special Education Cluster Federal Award Numbers: H027A180073, H173A180081, H027A190073, H173A190081 Questioned Costs: $31,662.24 Repeat of Prior Year Findings: FA 2019-002, FA 2018-002, and FA 2017-002 Description: The policies and procedures of the School District did not provide adequate internal controls over procurement as it relates to Special Education Cluster. Criteria: 2 CFR 200.318(a) states in part that the non-Federal entity must ?use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable Federal law.? In addition, provisions included in 2 CFR 200.320(b) provide guidance for procurement through small purchase procedures and state, ?If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.? Condition: In an effort to determine whether appropriate internal controls were implemented and applicable compliance requirements were met, a test of procurement transactions associated with ten vendors were randomly selected for testing using a non-statistical sampling approach. Upon review of these procurement transactions, it was noted that the School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for four small purchase expenditures. Questioned Costs: Questioned costs of $31,662.24 were identified for expenditures that did not follow the School District?s procurement procedures. Cause: In discussing the deficiencies with management, they stated that internal control procedures related to procurement were not being followed appropriately. In addition, management did not adequately monitor the procurement internal control procedures. Effect or Potential Effect: Failure to appropriately implement procedures to address procurement compliance requirements exposes the School District to unnecessary risk of error and misuse of Federal funds. In addition, this deficiency could lead to the return of grant funds associated with unallowable expenditures. Furthermore, the School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance Recommendation: The School District should evaluate and improve internal control procedures to ensure that required procurement procedures are followed, and appropriate documentation is obtained and retained. In addition, management should develop a monitoring process to ensure that these procedures are operating effectively and as designed. Views of Responsible Officials: We concur with this finding.

Corrective Action Plan

FA 2020-002 Improve Controls over Procurement Compliance Requirement: Procurement, Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Requirement: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education CFDA Number and Title: 84.027, 84.173 Special Education Cluster Federal Award Number: H027A180073, H173A180081, H027A190073, H173A190081 Questioned Costs: $31,662.24 Repeat of Prior Year Finding: FA2019-002, FA 2018-002, and FA 2017-002 Corrective Action Plans: Management agrees with this finding. A new Special Education Director has been employed. Corrective action has already occurred and the Special Education Department now ensures, prior to procuring services, that an adequate number of rate or price quotations are obtained from qualified sources. Procedures and policies are designed and implemented to ensure compliance with the procurement provisions of 2 CFR 200.320. Estimate Completion Date: June 30, 2021 Contact Person: Charles Burbridge, CFO Telephone: (678) 676-1200 Email: Charles_Burbridge@dekalbschoolsga.org

Prior Finding References

2019-002

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FY 2019-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on November 16, 2020. 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 May 16, 2021, which was (1922 days ago).

What is a management decision? →
2019-001
Equipment & Real Property
REPEATMATERIAL WEAKNESS
Condition

"See Schedule of Findings and Questioned Costs for chart/table" Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Child Nutrition Cluster. Criteria: 2 CFR ? 200.313 (d)(1) states, "Property records must be maintained that include a description of the property, a serial number or other identification number, the source of property, who holds title, the acquisition date, and cost of the property, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property". In addition, 2 CFR ? 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 District did not maintain an equipment listing for the Child Nutrition Cluster. Cause: Child Nutrition Cluster management was unable to generate an equipment listing. In discussing the deficiency with management, they state that communication difficulties exist between the responsible parties of purchasing equipment, labeling equipment, performance of the annual inventory, and recording equipment items on the listings. Additionally, personnel responsible for equipment record keeping found that equipment purchases were often difficult to accurately distinguish from other purchase types due to insufficient descriptions in the source data. Effect or Potential Effect: Failure to maintain a complete and accurate equipment listing and reconcile results of the physical inventory performed to the property records exposes the School District to unnecessary risk of error and misuse of equipment and/or federal funds. Additionally, the School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance. Recommendation: The School District should develop and maintain an equipment listing that reflects all required information, including a description, an identifying number, the source of funding, the title holder, the acquisition date, the cost, the percentage of Federal participation in the project costs, the location, the use and condition, and any ultimate disposal data for each piece of equipment. In addition, management should implement controls to ensure that a complete physical inventory of equipment is performed, and the results are reconciled back to the equipment listing at least once every two years. Views of Responsible Officials: We concur with this finding.

Corrective Action Plan

"See Corrective Action Plan for chart/table"

Prior Finding References

2018-001

About Equipment and Real Property Management →
2019-002
Procurement & Suspension/Debarment
REPEAT
Condition

"See Schedule of Findings and Questioned Costs for chart/table" Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over procurement as it relates to Special Education Cluster. Criteria: 2 CFR 200.303(a) states that the 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.? Provisions included in 2CFR200.320(b) provide that if small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Condition: A sample of ten procurement transactions were randomly selected for testing using a non-statistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and applicable compliance requirements were met. The following deficiencies were noted: ? The School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for five small purchase expenditures reviewed. ? The School District could not provide fiscal year 2019 contracts for vendors used for three small purchase expenditures reviewed. ? The School District could not provide evidence that rate or price quotations were obtained from the vendor used for one small purchase reviewed. Cause: In discussing the deficiencies with management, they stated that internal control procedures related to procurement were not being followed appropriately. In addition, management did not adequately monitor the procurement internal control procedures. Effect or Potential Effect: Failure to appropriately implement procedures to address procurement compliance requirements exposes the School District to unnecessary risk of error and misuse of Federal funds. In addition, this deficiency could lead to the return of grant funds associated with these unallowable expenditures. Furthermore, the School District is not in compliance with the Uniform Guidance and Georgia Department of Education guidance. Recommendation: The School District should evaluate and improve internal control procedures to ensure that required procurement documentation is properly identified, safeguarded, and retained. In addition, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.

Corrective Action Plan

"See Corrective Action Plan for chart/table"

Prior Finding References

2018-002

About Procurement and Suspension and Debarment →

FY 2018-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on November 16, 2020. 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 May 16, 2021, which was (1922 days ago).

What is a management decision? →
2018-001
Equipment & Real Property
REPEATMATERIAL WEAKNESS
Condition

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-001, 2016-001

About Equipment and Real Property Management →
2018-002
Procurement & Suspension/Debarment
REPEAT
Condition

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-002

About Procurement and Suspension and Debarment →

FY 2017-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on April 29, 2019. 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 October 29, 2019, which was (2487 days ago).

What is a management decision? →
2017-001
Equipment & Real Property
REPEAT
Condition

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-001

About Equipment and Real Property Management →
2017-002
Procurement & Suspension/Debarment
Condition

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment →

FY 2016-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on February 18, 2018. 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 August 18, 2018, which was (2924 days ago).

What is a management decision? →
2016-001
Equipment & Real Property
Condition

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Equipment and Real Property Management →

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