District School Board of Pinellas CountyLocal Government

Material Weakness Finding Number: 2025-001 ALN # 84.063: Federal Program: Federal Pell Grant Program Federal Agency: U.S. Department of Education Contract Number and Year: P063P245378 and P063P242749, 2025 Compliance Requirement: Special Tests and Provisions – NSLDS Reporting Questioned Costs: N/A Criteria: Pursuant to 34 CFR §§ 685.309 and 690.83(b)(2), institutions are required to report student enrollment status changes to the National Student Loan Data System (NSLDS) within 30 days of the change or, alternatively, within 60 days through the submission of an enrollment reporting roster. At a minimum, institutions must certify enrollment data at least every 60 days. Reportable changes include, but are not limited to, adjustments in enrollment status, graduation, withdrawal, dropout, or failure to attend. In addition, institutions are required to review, correct, and return enrollment reporting rosters, including any necessary updates, within 15 days of receipt. Further, 2 CFR § 200.303 requires entities receiving federal awards to establish and maintain effective internal controls to ensure compliance with applicable laws and regulations. Condition: Testing of 80 Pell Grant recipients with enrollment status changes identified that the District did not accurately report 13 status changes (7 withdrawals and 6 graduations) to NSLDS. Additionally, for two of the four reporting periods tested, the District did not review, correct, and submit enrollment reporting rosters within the required 15-day timeframe. The District also did not consistently certify enrollment data at least every 60 days. These deficiencies occurred across multiple reporting periods. Cause: The deficiencies were attributable to staff turnover and training gaps, data transmission issues between the District’s third-party servicer (FAME) and NSLDS, and inconsistent processes for updating and certifying enrollment changes. As a result, controls over enrollment reporting were not consistently implemented or operating effectively. Effect: Failure to accurately and timely report enrollment status changes resulted in noncompliance with NSLDS reporting requirements and may impact the accuracy of student aid records maintained by the U.S. Department of Education. Recommendation: The District should strengthen internal controls over enrollment reporting by implementing procedures to ensure all enrollment status changes are accurately recorded, reconciled between internal systems and third-party servicer reports, and submitted to NSLDS within required timeframes. Additionally, the District should provide training to staff and establish monitoring controls to ensure timely review, correction, and certification of enrollment reporting rosters. Response: See attached Corrective Action Plan.

Finding - The District did not always maintain required documentation to support the adjustments to the high school cohort graduation rate. Criteria - Title 20, Section 7801(25), United States Code, requires that the District maintain appropriate documentation to support the removal of a student’s count from the 4-year cohort (defined as a group of students on the same schedule to graduate) used to calculate the high school cohort graduation rate. To remove a student’s count from the cohort, the District must confirm, in writing, that the student transferred from the District, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. Additionally, a student who is retained in the same grade, enrolls in a General Educational Development (GED) Program, or leaves school for any other reason may not be counted as having transferred from the District for the purpose of calculating the graduation rate and must remain in the cohort. To confirm that a student transferred out, official documentation must be obtained from the receiving school or program that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. Condition - To determine whether the District maintained appropriate documentation to support the removal of the 641 students from the 2022-23 fiscal year cohort graduation rate, we requested District records to support 25 selected students who were removed from the cohort. We found that District records did not comply with the Federal documentation requirements for the removal of 5 students from the cohort. Specifically, District personnel indicated that they were made aware of the students' intention at the time of withdrawal but District records did not evidence that the students enrolled in another school or program. Subsequent to our request in October 2023, school personnel obtained and provided to us confirmations that 2 of the students enrolled in educational programs that would culminate in the award of a regular high school diploma. Cause - District personnel indicated that they were unaware of some requirements for removing students from the cohort and did not adequately document student withdrawals. In addition, District personnel indicated that they did not monitor staff to ensure that students were always removed from the cohort for allowable reasons or always maintain records to support those removals. Effect - While the noncompliance was the result of a significant deficiency, the noncompliance does not have a direct impact on funding. Notwithstanding, without appropriate documentation supporting adjustments to the 4-year cohort and related graduation rate calculation, the District cannot demonstrate that the calculation was accurate, limiting the usefulness of the graduation rate as an academic indicator. Recommendation - The District should enhance procedures to ensure that documentation supporting adjustments to the 4-year cohort and related graduation rate calculation is obtained before adjustments are made. Such enhancements should include appropriate training and monitoring to ensure that the required documentation is maintained and supports that all students removed from the cohort graduation rate were removed for the reasons allowed by Federal regulations. District Response - The District will review procedures in alignment with State and Federal guidance. The District’s FTE team will include the Federal guidelines for documentation supporting student withdrawal and subsequent removal from the graduation cohort in their annual and ongoing training with school-based staff responsible for this practice. The District continuously adheres to the State of Florida documentation requirements and guidelines for inclusion for graduation cohorts.

Finding Number 2020-001 CFDA Number 84.010 Program Title Title I Grants to Local Educational Agencies Compliance Requirement Eligibility Pass-Through Entity Florida Department of Education (FDOE) Federal Grant/Contract Number and Grant Year S010A190009 - Fiscal year 2019/2020 Statistically Valid Sample No Finding Type Noncompliance and Significant Deficiency Questioned Costs $301,067 Prior Year Finding Not ApplicableThe District did not always comply with Federal regulations by properly allocating Title I Program funds to eligible schools. Criteria Title 34, Section 200.78, Code of Federal Regulations (CFR), requires the District to allocate Title I schoolwide program funds to schools identified as eligible and selected to participate, in rank order, on the basis of the total number of children from low income families in each school. The District is not required to allocate the same per-pupil amount (PPA) to each participating school attendance area or school provided that it allocates higher PPAs to areas or schools with higher concentrations of poverty than to areas or schools with lower concentrations of poverty. In addition, the CFR allows the District to reduce the amount of program funds allocated to a Title I schoolwide program school if the school is spending supplemental State or local funds for program use. Condition. The District annually applies for Title I Program funding and the application includes a budget and an eligibility survey to document the amounts budgeted per school. During the 2019-20 fiscal year, the District operated 123 District elementary, middle, high, and specialized schools; sponsored 18 charter schools;and expended Title I Program funds totaling $30,033,211 for 66 District schools and 3 charter schools. As part of our procedures, we requested for our examination District records supporting the proper allocation of Title I Program funding to District and charter schools for the 2019-20 fiscal year. The District provided copies of the Title I Program original budget allocations to the schools that demonstrated appropriate initial allocations based on each respective school?s poverty level. However, the final allocations recorded in the District accounting records for 12 District Title I schools were not in rank order based on the percent of students from low income families in each school. Those 12 schools, with poverty levels of 58.53 to 81.62 percent, received less per pupil funding than a school with a lower poverty level. Cause The District had not established effective procedures for monitoring the allocation and use of Title I Program funding at respective schools. According to District personnel, the District expended State and local resources to supplement the Title I funds used at the 69 schools. However, District records did not demonstrate that District personnel properly monitored Title I Program funds or the combination of Title I Program funds supplemented with State and local resources at the school level to ensure compliance with Federal regulations. Effect The District did not comply with Federal regulations by appropriately allocating resources to 12 Title I schools with amounts under allocated ranging from $1,364 to $100,649 per school and questioned costs totaling $301,067. In response to our inquiries, District personnel concurred with the calculated questioned costs and indicated that procedures would be revised to monitor school activity quarterly to ensure that funds are allocated to each Title I school, in rank order, based on the poverty level of each school. Recommendation The District should establish effective monitoring procedures to ensure that resources are properly allocated to Title I schools. In addition, the District should provide documentation to the grantor (FDOE) supporting the allowability of the questioned costs totaling $301,067 or restore this amount to the Title I Program. District Response The district leadership team met to review the audit concerns, revist the intention and purpose for Title I, Par A funds and the importance of maintaining rank and serve. As a result of that meeting, we have implemented effective monitoring procedures to ensure resources are property allocated to Title I schools. Additionally, the questioned costs will be restored to the Title I program.

Finding Number 2019 ? 002 Type of Finding Significant Deficiency CFDA Number 84.938C Program Title Temporary Emergency Impact Aid for Displaced Students (Emergency Impact Aid) Compliance Requirement: Special Tests and Provisions ? Documentation of Enrollment Status Federal Agency: U.S Department of Education; Pass-Through Entities Florida Department of Education Contract Number and Year FY 2018 ? 2019 Statistically Valid Sample Not Applicable Questioned Costs $2,539 (known); $81,514(likely) Prior Year Finding Not a prior year finding Criteria: 34 CFR 76.731 requires institutions keep records to show its compliance with program requirements. In addition, 2 CFR section 200.333 requires non-Federal entity records pertinent to a Federal award to be retained for a period of 3 years from the date of submission of the quarterly or annual financial report. Condition: In FY18-19 the District received funds from the Emergency Impact Aid program for students who enrolled into a Pinellas County District School in the 17-18 school year due to being displaced as a result of Hurricanes Harvey, Irma, and Maria. One student?s FY17-18 enrollment form or other documentation was not retained within the three-year period. Therefore, the District was unable to support the reported displaced student was enrolled, or eligible to be enrolled. Another student?s FY17-18 enrollment form was retained however, it did not indicate enrollment was contributed to a hurricane or natural disaster. No other supporting documents were obtained for the student. Although potentially eligible to be enrolled, there was no support to verify the student should have been reported as displaced. Cause: For the first instance, the enrollment form and other supporting documents from the 17-18 school year was purged from the student?s file at the end of the year in preparation for the new school year. In the second instance, the student was misclassified as displaced in the District?s system due to human error. Effect: As student documents were no maintained within the 3 year timeframe and misclassification of reported displaced student, the District was found to be out of compliance. This could result in inaccurate program funding. Questioned Costs: Questioned costs are the total amount paid through the grant for the two instances in which the documentation to support that the students were displaced and qualified the district for this funding was not maintained. Auditor Recommendation: The District should develop a storage system to retain student files pertinent to Federal awards for as long as is required by the grant. Additionally, to enhance procedures around the input of student data for accurate reporting to the FL DOE. District Response: We have reviewed the results of the finding noted and concur with the assessment of the issues identified. All schools have been instructed to retain this supporting documentation for a period of five years.

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