Hancock County Board of Education

FA 2024-001 Improve Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Reporting Internal Control Impact: Material Weakness Compliance Impact: Material 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: $819,799.49 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures 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 (ARP) 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 $3,951,662.00 were expended and reported on the Hancock 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…” In addition, 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. 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...” 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…” Lastly, provisions included in the Uniform Guidance, Section 200.302(a) state in part that “the non- Federal entity’s financial management systems must… be sufficient to permit the preparation of reports required by general and program-specific terms and conditions.” In addition, provisions included in the Uniform Guidance, Section 200.302(b)(2) state in part that the non-federal entity’s financial management system must provide for “accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements.” Condition: A review of the School District’s accounting records and approved expenditures reflected within the ESSER program Consolidated Application reviewed the following deficiencies: • A sample of 13 nonpersonal services expenditures was randomly selected for testing using a non-statistical sampling approach. These expenditures were reviewed to determine if appropriate internal controls were implemented and applicable compliance requirements were met. It was noted that prior approval was not obtained from GaDOE for two expenditures totaling $505,229.40 as these expenditures were not reflected in the approved budget or subsequent amendment within the Consolidated Application system as required. • A sample of 37 employees was randomly selected for testing using a non-statistical sampling approach. These employees were reviewed to determine if internal controls were implemented and applicable compliance requirements were met. It was noted that prior approval was not obtained from GaDOE for 29 expenditures totaling $181,761.00 as these expenditures were not reflected in the approved budget or subsequent amendment within the Consolidated Application system as required. • A review of indirect cost amounts charged to the ESSER program revealed that the total indirect cost amount budgeted by the School District, which totaled $600,000.00, was recorded as indirect cost expenditures during the period under review. However, the School District should have applied the indirect cost rate approved by the GaDOE to actual expenditures incurred during the fiscal year to calculate a maximum indirect cost amount of $467,190.96. Therefore, unallowable indirect costs totaling $132,809.04 were recorded within the ESSER fund. • Expenditures reported on the ARP ESSER completion report for the period July 1, 2023 through September 30, 2024 were not supported by the general ledger for several functions and objects reflected in the amended consolidated application. Questioned Costs: Upon testing a sample of $690,319.93 in nonpersonal services expenditures, known questioned costs of $505,229.40 were identified for expenditures not properly approved through the Consolidated Application process. Using the total nonpersonal services expenditures population of $2,507,902.88, we project the likely questioned costs to be approximately $1,835,476.87 In addition, upon testing a sample of $418,831.17 in personal services expenditures, known questioned costs of $181,761.05 were identified for expenditures not approved in the consolidated application. Using the total personal services expenditures population of $1,303,995.07 (excluding benefits payments), we project the likely questioned costs to be approximately $565,897.50. Furthermore, known questioned costs $132,809.04 were identified for unallowable indirect costs charged to the ESSER program. Therefore, the known and likely questioned costs identified for all unallowable payments totaled $819,799.49 and $2,534,183.41, respectively. The following Assistance Listing Numbers were affected by known and likely questioned costs: 84.425D & 84.425U. Cause: In discussing this deficiency with the School District, they stated that they did not consider the expenditure purchases unallowable and recorded them in the wrong account number due to oversight. Indirect costs were charged according to the budget without regard of the appropriate indirect cost rate. Effect: The School District is 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 evaluate 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.

FA 2024-001 Improve Controls over Expenditures Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Activities Allowed or Unallowed Allowable Costs/Cost Principles Reporting Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education 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 S425D210012 (Year: 2021), S425U210012 (Year: 2021) $819,799.49 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: The Hancock County School District has updated the policies and procedures to ensure that these coding errors do not occur in the future. The updates included but are not limited to: The District has corrected the coding in the general ledger for FY 26 and has implemented additional coding cross-checks to ensure alignment with the approved Con App. The function/object coding has been corrected in the FY 26 budget crosswalk, and coding protocols have been reinforced. Personnel coding has been corrected, and a verification procedure is now in place at the point of hiring and funding assignment. The Federal Program department will meet with the Finance Department to review funding codes prior to submission. Estimated Completion Date: June 30, 2026 Contact Person: Matthias Jones, Finance Director Telephone: 706-444-5775 ext. 125 Email: mjones@hancock.k12.ga.us

FA 2020-001 Strengthen Controls over Earmarking Requirements Compliance Requirement: Matching, Level of Effort, Earmarking Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Health and Human Services Pass-Through Entity: Direct CFDA Number and Title: 93.600 Head Start Federal Award Number: 04CH4743-04-00 Questioned Costs: None Identified Repeat of Prior Year Finding : FA 2019-003, FA 2018-004 Description: The policies and procedures of the School District did not provide adequate internal controls over the earmarking requirements associated with the Head Start program. Criteria: 45 CFR 1302.14(b)(1) states, ?A program must ensure at least 10 percent of its total funded enrollment is filled by children eligible from services under IDEA (Individuals with Disabilities Act), unless the responsible HHS official grants a waiver.? Condition: Our review of the targeted earmarking requirement revealed that the proper number of children eligible for service under the Individuals with Disabilities Act were not enrolled in the Head Start program. The School District was required to enroll a minimum of 17 children with disabilities in the Head Start program to be in compliance with Federal regulations. However, only 8 of these children were enrolled in the program. Cause: In discussing this deficiency with the School District, they indicated that a waiver for the requirement to enroll the minimum number of children with disabilities was not obtained appropriately. Effect or Potential Effect: Failure to ensure that earmarking requirements are met appropriately may lead to a reduction in funding for the Head Start program in future years and could result in unnecessary financial strains and shortages within the Head Start program fund. Additionally, the School District is not in compliance with Federal regulations specific to the Head Start program. Recommendation: The School District should review current internal control procedures related to Head Start program earmarking requirements and ensure that the appropriate number of children eligible for service under the Individuals with Disabilities Act are enrolled in the program or a waiver is obtained in the future. Furthermore, management should develop and implement a monitoring process to ensure that controls are properly implemented. Views of Responsible Officials: We concur with this finding.

FA 2020-001 Strengthen Controls over Matching Requirements Compliance Requirement: Matching, Level of Effort, Earmarking Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Health and Human Services Pass-Through Entity: Direct CFDA Number and Title: 93.600 Head Start Federal Award Number: 04CH4743-04-00 Questioned Costs: None Identified Repeat of Prior Year Finding: FA 2019-003, FA 2018-004 Corrective Action Plan: The Hancock County School District is in the process of updating the policies and procedures manual and will establish internal controls procedures to ensure earmarking requirements are met for the Head Start Program. Estimated Completion Date: June 30, 2021 Contact Person: Matthias Jones, Finance Director Telephone: 706-444-5775 Ext. 125 E-mail: mjones@hancock.k12.ga.us

2019-003

See Schedule of Findings and Questioned Costs for chart/table FA 2019-002 Description: The policies and procedures of the School District did not 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: ? Property records did not include the following required components: (1) A serial number of other identification number, (2) the source of funding for the property (including the FAIN), (3) percentage of Federal participation in the project costs for the Federal award under which the property was acquired, and (4) use and condition of property. ? There was no evidence that a physical inventory has been performed in either the current year or the previous year. Cause: In discussing this deficiency with the School District, they stated that a physical inventory was performed, but the proper documentation was not completed to document the review. In addition, a lack of resources and inadequate policies and procedures over equipment maintenance contributed to the issues noted. 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. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 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 at least once every two years. Views of Responsible Officials: We concur with this finding.

See Corrective Action Plan for chart/table

2018-003

See Schedule of Findings and Questioned Costs for chart/table Description: The policies and procedures of the School District did not provide adequate internal controls over the matching requirements associated with the Head Start program. Criteria: 45 CFR 1302.14(b)(1) states, ?A program must ensure at least 10 percent of its total funded enrollment is filled by children eligible from services under IDEA [Individuals with Disabilities Act], unless the responsible HHS official grants a waiver.? Condition: Our review of the targeted earmarking requirement revealed that the proper number of children eligible for service under the Individuals with Disabilities Act were not enrolled in the Head Start program. The School District was required to enroll a minimum of 18 children with disabilities in the Head Start program to be in compliance with Federal regulations. However, only 9 of these children were enrolled in the program. Cause: In discussing this deficiency with the School District, they indicated that a waiver for the requirement to enroll the minimum number of children with disabilities was not obtained appropriately. Effect or Potential Effect: Failure to ensure that matching requirements are met appropriately may lead to a reduction in funding for the Head Start program in future years and could result in unnecessary financial strains and shortages within the Head Start program fund. Additionally, the School District is not in compliance with Federal regulations specific to the Head Start program. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Recommendation: The School District should review current internal control procedures related to Head Start program matching requirements and ensure that the appropriate number of children eligible for service under the Individuals with Disabilities Act are enrolled in the program or a waiver is obtained in the future. Furthermore, management should develop and implement a monitoring process to ensure that controls are properly implemented. Views of Responsible Officials: We concur with this finding.

See Corrective Action Plan for chart/table

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