JONES COUNTY SCHOOL DISTRICTLocal Government

III Federal Award Findings and Questioned Costs FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment 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 Titles: 10.553 – School Breakfast Program; 10.555 – National School Lunch Program 10.582 - Fresh Fruit and Vegetable Program Federal Award Numbers: 255GA324N1199 (Year: 2025), 255GA324L1603 (Year: 2025) Questioned Costs: $6,267 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that the School District’s procurement and suspension and debarment procedures were followed. 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 child care 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 is granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Agriculture, and GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the various CNC programs. CNC funds totaling $3,568,611.24 were expended and reported on the Jones 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. Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state, “(a)… the recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations… (b) Recipients and subrecipients must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Procurement Methods provide guidance for informal procurement methods and state “If simplified acquisition procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.” Condition: A sample of 40 procurement transactions was randomly selected for testing using a nonstatistical sampling approach. These transactions were reviewed to determine if appropriate internal controls were implemented and applicable compliance requirements were met. 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 reviewed. Questioned Costs: Upon testing a sample of $159,951.89 in procurement transactions, known questioned costs of $6,267 were identified for expenditures that did not follow the School District’s procurement procedures. Using the total population of $1,778,019 in procurement transactions, we project the likely questioned costs to be approximately $69,659. The following Assistance Listing Numbers were affected by known and likely questioned costs: 10.553, 10.555, and 10.582. Cause: In discussing these deficiencies with the School District, they stated that the internal control procedures related to procurement were not being followed appropriately. In addition, management did not adequately monitor the procurement internal control procedures. Effect: The School District was not in compliance with the Uniform Guidance and GaDOE guidance. Failure to appropriately implement procedures to address procurement and suspension and debarment compliance requirements exposes the School District to unnecessary risk of error and misuse of federal funds and could result in the expenditure of federal funds with unqualified vendors. In addition, this deficiency could lead to the return of federal funds associated with unallowable expenditures. Recommendation: The School District should evaluate and improve internal control procedures to ensure that required procurement methods are properly identified and followed and required procurement and suspension and debarment 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.

FA 2021-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.371C Federal Award Number: S371C170002-17C Striving Readers Questioned Costs: $144,020.30 Repeat of Prior Year Finding: FA 2020-001, FA 2019-002 Description: A review of expenditures charged to the Striving Readers program (CFDA 84.371C) revealed that the School District?s internal control procedures were not operating appropriately to ensure that expenditures were appropriately reviewed, approved, and documented. Criteria: 2 CFR 200.403 prescribes the factors affecting allowability of costs and states in part 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? (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?? 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.? 2 CFR 200.318(b) states in part that the Non-Federal entity ?must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts.? 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.? 2 CFR 180.300 states in part that the non-Federal entity must ?verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.? Furthermore, 2 CFR 200.303(a) states in part that the ?non-Federal entity must: (a) 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? (c) Evaluate and monitor the non-Federal entity?s compliance with statutes, regulations and the terms and conditions of Federal awards.? Condition: A sample of 60 expenditures was randomly selected for testing using a non-statistical sampling approach. Nine 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. The following deficiencies were noted: ? For 16 expenditures, supporting documentation for the L4GA Literacy Grant purchase requisition was not found in the voucher package. ? For one expenditure, purchase orders were completed after the invoice date. ? For one expenditure, evidence of receipt was not attached to the voucher package. In addition, a sample of 60 procurement transactions was randomly selected for testing using a nonstatistical sampling approach. Nine 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. The following deficiencies were noted: ? Contract files documenting the significant history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and basis of contract price, were not available for 11 transactions. ? The appropriate procurement method was not used for the dollar amount and conditions associated with 24 procurement transactions. ? Procurements did not provide full and open competition for in 12 instances. ? In those cases where competition was limited, documentation was not maintained on file for six transactions. ? A cost or price analysis was not performed in connection with 11 procurement actions exceeding the simplified acquisition threshold, including contract modifications, and the analysis supporting the procurement action was not on-file. Furthermore, a sample of five covered transactions was randomly selected for testing of suspension and debarment requirements using a non-statistical sampling approach. Four individually significant covered transactions were also selected for testing. For eight of the 44 transactions tested, documentation could not be provided to support the School District?s verification that the vendors were not suspended or debarred or otherwise excluded from participating in the transaction as is required per their policy. Questioned Costs: Questioned costs of $144,020.30, with likely questioned costs of $266,812.20, were identified for expenditures that did not follow the School District?s procurement procedures. Cause: The School District?s did not follow its policies and procedures that govern Striving Readers. The School District used the National Institute of Governmental Purchasing (NIGP) to exempt books from its procurement requirements; however, this is not allowable for purchases made with federal awards. Effect: Failure to ensure that expenditures are reviewed and documentation is maintained on-file appropriately exposes the School District to unnecessary risk of error and misuse of Federal funds. In addition, failure to appropriately implement procedures to address procurement, suspension and debarment compliance requirements could result in the expenditure of Federal funds with unqualified vendors and 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 review current internal control procedures related to the Striving Readers program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that all expenditures reflect evidence of review and are documented appropriately. In addition, the School District should evaluate and improve internal control procedures to ensure that required procurement and suspension and debarment documentation is properly identified, safeguarded, and retained. Furthermore, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.

FA 2021-002 Strengthen Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment 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 and 10.555 Child Nutrition Cluster Federal Award Number: 215GA324N1199 Questioned Costs: $1,251.42 Description: A review of expenditures charged to the Child Nutrition Cluster (CFDA 10.553 and 10.555) revealed that the School District?s internal control procedures were not operating appropriately to ensure that expenditures were appropriately reviewed, approved, and documented and that the School District?s procurement procedures were followed. 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.? 2 CFR 200.318(b) states in part that the Non-Federal entity ?must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts.? 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.? 2 CFR 180.300 states in part that the non-Federal entity must ?verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.? Furthermore, 2 CFR 200.303(a) states in part that the ?non-Federal entity must: (a) 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? (c) Evaluate and monitor the non-Federal entity?s compliance with statutes, regulations and the terms and conditions of Federal awards.? Condition: A sample of 60 procurement transactions 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. The following deficiencies were noted: ? The appropriate procurement method was not used for the dollar amount and conditions associated with three procurement transactions. ? Procurements did not provide full and open competition for in three instances. Questioned Costs: Questioned costs of $1,251.42, with likely questioned costs of $43,622.83, were identified for expenditures that did not follow the School District?s procurement procedures. Cause: The School District?s did not follow its policies and procedures that govern the procurement process for federal programs. Effect: Failure to ensure that expenditures are reviewed and documentation is maintained on-file appropriately exposes the School District to unnecessary risk of error and misuse of Federal funds. In addition, failure to appropriately implement procedures to address procurement, suspension and debarment compliance requirements could result in the expenditure of Federal funds with unqualified vendors and 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 and suspension and debarment documentation is properly identified, safeguarded, and retained. Furthermore, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.

FA 2020-001 Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education CFDA Number and Title: 84.371 Striving Readers Federal Award Numbers: S371C170002, S371C110049 Questioned Costs: $49,047.28 Repeat of Prior Year Finding: FA 2019-002 Description: A review of expenditures charged to the Striving Readers program (CFDA 84.371) revealed that the School District?s internal control procedures were not operating appropriately to ensure that expenditures were appropriately reviewed, approved, and documented. Criteria: 2 CFR 200.403 prescribes the factors affecting allowability of costs and states in part 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? (c) Be consistent with policies and procedures that apply uniformly to both federallyfinanced and other activities of the non-Federal entity? (g) Be adequately documented?? 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.? 2 CFR 200.318(b) states in part that the Non-Federal entity ?must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts.? 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.? 2 CFR 180.300 states in part that the non-Federal entity must ?verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.? Furthermore, 2 CFR 200.303(a) states in part that the ?non-Federal entity must: (a) 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? (c) Evaluate and monitor the non-Federal entity?s compliance with statutes, regulations and the terms and conditions of Federal awards.? Condition: A sample of 60 expenditures was randomly selected for testing using a non-statistical sampling approach. Six 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. The following deficiencies were noted: ? For 13 expenditures, supporting documentation for the L4GA Literacy Grant purchase requisition was not found in the voucher package. ? For one expenditure, purchase orders were completed after the invoice date. ? For two expenditures, evidence of proper approval was not reflected within the voucher package. ? For six expenditures, evidence of receipt was not attached to the voucher package. In addition, a sample of 60 procurement transactions was randomly selected for testing using a nonstatistical sampling approach. Six 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. The following deficiencies were noted: ? Contract files documenting the significant history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and basis of contract price, were not available for 27 transactions. ? The appropriate procurement method was not used for the dollar amount and conditions associated with 24 procurement transactions. ? Procurements did not provide full and open competition for in 20 instances. ? A cost or price analysis was not performed in connection with nine procurement actions exceeding the simplified acquisition threshold, including contract modifications, and the analysis supporting the procurement action was not on-file. Furthermore, a sample of five covered transactions was randomly selected for testing of suspension and debarment requirements using a non-statistical sampling approach. Four individually significant covered transactions were also selected for testing. For three of the four vendors tested, documentation could not be provided to support the School District?s verification that the vendors were not suspended or debarred or otherwise excluded from participating in the transaction as is required per their policy. Questioned Cost: Questioned costs of $49,047.28, with likely questioned costs of $182,259.40, were identified for expenditures that did not follow the School District?s procurement procedures. Cause: The School District?s did not follow its policies and procedures that govern Striving Readers. The School District used the National Institute of Governmental Purchasing (NIGP) to exempt books from its procurement requirements; however, this is not allowable for purchases made with federal awards. Effect or Potential Effect: Failure to ensure that expenditures are reviewed and documentation is maintained on-file appropriately exposes the School District to unnecessary risk of error and misuse of Federal funds. In addition, failure to appropriately implement procedures to address procurement, suspension and debarment compliance requirements could result in the expenditure of Federal funds with unqualified vendors and 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 review current internal control procedures related to the Striving Readers program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that all expenditures reflect evidence of review and are documented appropriately. In addition, the School District should evaluate and improve internal control procedures to ensure that required procurement and suspension and debarment documentation is properly identified, safeguarded, and retained. Furthermore, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.

See Schedule of Findings and Questioned Costs for chart/table Description: A review of expenditures charged to the Child Nutrition Cluster (CFDA 10.553 and 10.555) revealed that the School District?s internal control procedures were not operating appropriately to ensure that expenditures were appropriately reviewed, approved, and documented. Criteria: 2 CFR 200.403 prescribes the factors affecting allowability of costs and states in part 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? (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?? 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.? 2 CFR 200.318(b) states in part that the Non-Federal entity ?must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts.? 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.? III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS In addition, 2 CFR 200.303(a) states in part that the ?non-Federal entity must: (a) 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? (c) Evaluate and monitor the non-Federal entity?s compliance with statutes, regulations and the terms and conditions of Federal awards.? Condition: A sample of 45 expenditures was 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. The following deficiencies were noted: ? Adequate supporting documentation was not maintained for four expenditures. ? Evidence of review and approval was not reflected within the voucher package for one expenditure. In addition, a sample of seven employees was randomly selected for testing using a non-statistical sampling approach. These employees were reviewed to determine if internal controls were functioning properly and applicable compliance requirements were met. The following deficiencies were noted: ? Three employees did not complete the semi-annual certifications for the full year. ? Three employees were paid at the incorrect rate. ? The School District could not provide a board-approved pay scale for one employee?s salary. Furthermore, a sample of 40 procurement transactions 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. The following deficiencies were noted: ? Adequate supporting documentation could not be provided for four expenditures. ? For five expenditures, proper quotes were not gathered per purchasing policy. ? Three procurements did not have contract files documenting the significant history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and basis of contract price. ? The appropriate procurement methods were not used for two expenditures based on the dollar amount and conditions associated with the procurement. ? Five procurements did not provide full and open competition. ? Three procurement transactions in which competition was limited were not supported with adequate justification documentation. ? The School District?s procurement policy reflected inconsistent and inaccurate procurement thresholds. Finally, the auditor selected five vendors associated with covered transactions for testing of suspension and debarment requirements. For two vendors, documentation could not be provided to support the School District?s verification that the vendors were not suspended or debarred or otherwise excluded from participating in the transaction as is required per their policy. Questioned Cost: Questioned costs of $532.07, with likely questioned costs of $26,302.85 were identified for expenditures that were not adequately documented. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Cause: in discussing these deficiencies with the School District, they indicated that the four unsupported expenditures were due to misplacement that occurred during the process of pulling the vouchers for the audit. The entity indicated that the issues noted in payroll, the procurement policy and the one expenditure that did not contain evidence of review were due to oversight. In addition, the School District indicated that the procurement issues occurred due to a continuation of procurement methods with the vendors that were in place prior to the hiring of the current program director. Effect or Potential Effect: Failure to ensure that expenditures are reviewed and documentation is maintained on-file appropriately exposes the School District to unnecessary risk of error and misuse of Federal funds. In addition, failure to appropriately implement procedures to address procurement, suspension and debarment compliance requirements could result in the expenditure of Federal funds with unqualified vendors and 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 review current internal control procedures related to the Child Nutrition Cluster expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that all expenditures reflect evidence of review. In addition, all expenditure voucher packages should be maintained on-file according to the School District?s record retention policy. The School District should evaluate and improve internal control procedures to ensure that required procurement, suspension and debarment documentation is properly identified, safeguarded, and retained. Furthermore, management should develop and implement a monitoring process to ensure that controls are properly implemented and operating appropriately. Views of Responsible Officials: We concur with this finding.

See Schedule of Findings and Questioned Costs for chart/table Description: A review of expenditures charged to the Striving Readers program (CFDA 84.371) revealed that the School District?s internal control procedures were not operating appropriately to ensure that expenditures were appropriately reviewed, approved, and documented. Criteria: 2 CFR 200.403 prescribes the factors affecting allowability of costs and states in part 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? (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?? 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.? 2 CFR 200.318(b) states in part that the Non-Federal entity ?must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts.? 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.? 2 CFR 180.300 states in part that the non-Federal entity must ?verify that the entity with whom you intend to do business is not excluded or disqualified. You can do this by: (a) Checking System for Awards Management (SAM) exclusions; or (b) Collecting a certification from the entity; or (c) Adding a clause or condition to the covered transaction with the entity.? Furthermore, 2 CFR 200.303(a) states in part that the ?non-Federal entity must: (a) 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? (c) Evaluate and monitor the non-Federal entity?s compliance with statutes, regulations and the terms and conditions of Federal awards.? Condition: A sample of 50 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. The following deficiencies were noted: ? For 39 expenditures, supporting documentation for L4GA Literacy Grant purchase requisition was not found in the voucher packages. ? For 16 expenditures, purchase orders were completed after the invoice date. ? For 16 expenditures, proper quotes were not gathered per the purchasing policy. ? For two expenditures, evidence of proper approval was not reflected within the voucher package. III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS In addition, a sample of 22 procurement transactions 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. The following deficiencies were noted with 12 procurement transactions: ? Contract files documenting the significant history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and basis of contract price, were not available. ? The appropriate procurement method used was not appropriate for the dollar amount and conditions associated with the procurement transaction. ? Procurements did not provide full and open competition. ? A cost or price analysis was not performed in connection with all procurement actions exceeding the simplified acquisition threshold, including contract modifications, and the analysis supported the procurement action. Furthermore, the auditor selected five vendors associated with covered transactions for testing of suspension and debarment requirements. For three vendors, documentation could not be provided to support the School District?s verification that the vendors were not suspended or debarred or otherwise excluded from participating in the transaction as is required per their policy. Cause: Per discussion with management, these issues were due to the personnel responsible for the program not being familiar with Federal guidelines, as well as it being the first year of the program. Effect or Potential Effect: Failure to ensure that expenditures are reviewed and documentation is maintained on-file appropriately exposes the School District to unnecessary risk of error and misuse of Federal funds. In addition, failure to appropriately implement procedures to address procurement, suspension and debarment compliance requirements could result in the expenditure of Federal funds with unqualified vendors and 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 review current internal control procedures related to the Striving Readers program expenditures. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that all expenditures reflect evidence of review and are documented appropriately. In addition, the School District should evaluate and improve internal control procedures to ensure that required procurement and suspension and debarment documentation is properly identified, safeguarded, and retained. Furthermore, management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding.

See Schedule of Findings and Questioned Costs for chart/table Description: A review of free and reduced meal applications and seamless summer meal rosters related to the Child Nutrition Cluster (CFDA 10.553 and 10.555) revealed that the School District?s internal control procedures were not operating appropriately to ensure that appropriate reviews and approvals occurred, proper eligibility and verification standards were applied, and adequate documentation was maintained. Criteria: 7 CFR 245.6(c)(1) states in part that "the local educational agency must determine household eligibility for free or reduced price meals either through direct certification or the application process at or about the beginning of the school year.? In addition, 7 CFR 245.6(e) states in part that ?the local educational agency must maintain documentation substantiating eligibility determinations on file for 3 years after the date of the fiscal year to which they pertain?? 7 CFR 245.6a(f)(6) states in part that ?the local educational agency shall make at least one attempt to contact any household that does not respond to a verification request. The attempt may be through a telephone call, e-mail, mail or in person and must be documented by the local educational agency. Non-response to the initial request for verification includes no response and incomplete or ambiguous responses that do not permit the local educational agency to resolve the children?s eligibility for free or reduced price meal and milk benefits.? Additionally, 7 CFR 245.6a(f)(7) states in part that ?the local educational agency shall make appropriate modifications to the eligibility determinations made initially. The local educational agency must notify the household of any change. Households must be notified of any reduction in benefits? Households with reduced benefits or that are no longer eligible for free or reduced price meals must be notified of their right to reapply at any time.? Furthermore, 2 CFR 200.303(a) states in part that the ?non-Federal entity must: (a) 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? (c) Evaluate and monitor the non-Federal entity?s compliance with statutes, regulations and the terms and conditions of Federal awards.? III FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Condition: A sample of 40 free and reduced meal applications was selected for testing using a non-statistical sampling approach. These applications were reviewed to determine if appropriate internal controls were implemented and applicable compliance requirements were met. The following deficiency was noted: ? Evidence of review and approval of the eligibility determination for free and reduced meals was not reflected for nine online applications tested, and the auditor verified that there is no review of eligibility determinations for any online applications. In addition, a review of the School District?s Form DE0107 Claim Data reports, which are submitted to the Georgia Department of Education to obtain reimbursement funds, and the corresponding tally sheets, which are prepared by the School District from their open seamless summer site meal count, was performed all months of the seamless summer meal operation, which included four sites in July 2018 and seven sites in June 2019. The following deficiencies were noted: ? The summer meal tally sheets were not maintained for one day in the July 2018 and three days in the June 2019. The number of meals submitted on the Form DE0107 was 250 greater than the number of meals reported on the tally sheet. ? In addition, nine of the tally sheets were missing appropriate signatures indicating review and approval by the School District personnel. Furthermore, the 21 free and reduced meal applications selected for verification were reviewed to ensure that the School District performed verification procedures properly and made appropriate changes to each student?s eligibility status based upon supporting documentation obtained. The following deficiencies were noted: ? Evidence of review and approval of the final eligibility determination for free and reduced meals was not reflected for one application tested. ? Evidence of required income documentation used in determining eligibility status was not maintained for one application tested. Cause: In discussing these deficiencies with the School District, they indicated that internal control procedures were not adequately designed to ensure that online free and reduced meal applications and summer meal tally sheets contain evidence of review and approval. The District indicated it was unaware of the requirement to review and approve online applications since the initial determination was made by the software system. In addition, the School District indicated that an oversight occurred in the approval process for the one verification form that did not contain evidence of review and approval and the one verification form that was missing documentation on income correspondence used in determining eligibility. Furthermore, the School District indicated that the variance in summer meal count is likely due to misplaced tally sheets. Effect or Potential Effect: Failure to maintain required documentation of verification procedures and meal counts for summer feeding and perform supervisory reviews of eligibility determinations and meal count documentation exposes the School District to unnecessary risk of error and misuse of 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 review current internal control procedures related to the Child Nutrition Cluster eligibility determinations for free and reduced meals, verification of free and reduced applications, and documentation supporting reimbursement claims for summer feeding. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that all Federal requirements for eligibility are met, verification procedures are performed appropriately, and adequate documentation is maintained on-file according to the School District?s record retention policy. 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.

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