St Johns County School District

Finding 2025-001 - Student Financial Aid Cluster, Assistance Linting No. 84.063, Special Test and Provisions – NSLDS Reporting, Immaterial Noncompliance and Significant Deficiency in Internal Control over Compliance Criteria: The Institutions participating in the Pell Grant Program are required to report enrollment information to the National Student Loan Data System (NSLDS) under the Pell Grant. Condition: In testing the District’s NSLDS reporting, we observed that certain students enrolled in the First Coast Technical College ("FCTC") had not been reported in the NSLDS system. We further noted that the reporting for other students enrolled in FCTC contained inaccuracies in the dates enrolled, withdrawn, or graduated. Context: Of the 18 students selected for testing, 7 had not been reported in the NSLDS system. Additionally, of the 11 students who had been reported, the NSLDS reporting contained inaccuracies when compared to the District’s internal records. Cause: The District experienced significant staff turnover throughout the period of March 2024 to June 2025, which resulted in newly appointed employees still familiarizing themselves with the District’s system and processes during the period. Effect: The District’s NSLDS reporting was not complete or accurate for students enrolled in the FCTC. Questioned Costs: $-0- Recommendation: We recommend the District identify the individual(s) who are responsible for NSLDS reporting and ensure they receive adequate training in the reporting requirements of the NSLDS system. We would further recommend the District establish a process, independent of the individual(s) responsible for reporting, for reviewing the NSLDS reporting to provide reasonable assurance that the NSLDS reporting is complete and accurate. Response / Planned Corrective Action: Management acknowledges the auditor's findings and will enhance procedures over the NSLDS system to ensure accurate and timely reporting moving forward.

Finding - District controls did not always ensure compliance with the Davis-Bacon Act for Federally funded construction projects exceeding $2,000, resulting in questioned costs totaling $216,031. Criteria - The ES Fund provides Federal funds for school facility repairs and improvements to reduce the risk of virus transmission and exposure to environmental health hazards, and to support student health needs. Title 29, Section 5.5, Code of Federal Regulations (Davis-Bacon Act), requires the District to include prevailing wage rate clauses in any construction contract exceeding $2,000 that is financed either wholly or in part by Federal funds and ensure that contractors pay workers the prevailing wage rates established by the United States Department of Labor. This includes a requirement for the contractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). The United States Department of Labor established “prevailing wages” by geographic area and interprets the Davis-Bacon Act to apply to construction, alteration, or repair of public buildings or public works. Condition - During the 2022-23 fiscal year, the District expended $216,031 from the ES Fund for projects related to two construction contracts totaling $412,189 for heating, ventilation, and air-conditioning (HVAC) renovation projects. While each of the two contracts included a general requirement to comply with all Davis-Bacon Act provisions, the contracts did not explicitly require, and the contractors did not submit, weekly certified payrolls to the District demonstrating prevailing wage rates were paid. Cause - The contracts did not specifically require contractors to submit to the District weekly certified payrolls and District personnel overlooked this requirement. Effect - Absent specific contract clauses and weekly certified payrolls, there is an increased risk that contractors and subcontractors paid with Federal moneys will not pay workers the prevailing wage rates established by the United States Department of Labor. Although we requested, the District did not provide the certified payrolls from the contractors demonstrating that the prevailing wage rates were paid for the construction contracts. Consequently, the $216,031 expended by the District are questioned costs. Recommendation - The District should enhance procedures to ensure compliance with all Davis-Bacon Act requirements. Such enhancements should ensure that applicable Federally funded facility contracts specifically require submittal of weekly certified payrolls and that District personnel verify the payrolls were received. In addition, the District should document to the FDOE the allowability of the questioned costs or contact the FDOE regarding necessary corrective action. District Response - The District's procedures will be enhanced to ensure compliance with the Davis-Bacon Act prevailing wage requirements by specifically updating Federally-funded construction contracts with the requirement for submittal of weekly certified payroll from the vendor to appropriate District personnel for review.

FINDING #2019-001 U.S. Department of Education - CFDA 84.063 - Student Financial Assistance Cluster - Federal Pell Program Immaterial Noncompliance Reporting (Common Origination and Disbursement) Criteria: Title 2 CFR 690.82 requires institutions to submit accurate data for each student through the Common Origination and Disbursement (COD) system. Condition: Student files that were approved by the DOE under the Heightened Cash Monitoring Level 2 (HCM2) method of reimbursement for the period July 1, 2018 through June 30, 2019 consisted of 146 disbursements totaling $304,226 for award year 2018, and 34 disbursements totaling $39,349 for award year 2019. From this population, we examined District records supporting disbursements for 16 disbursements totaling $35,641 related to award year 2018, and 2 disbursements totaling $4,866 related to award year 2019. Of the disbursements examined, we found that the District reports to COD included incorrect Cost of Attendance (COA) for all of the 16 disbursements related to award year 2018. All 2019 award year disbursements in our sample were reported correctly. Questioned Costs: None. Context: During fiscal year 2018, the U.S. Department of Education (DOE) conducted a program review of the District?s First Coast Technical College?s (FCTC) expenditures under the Federal Pell Grant Program (Pell). As a result of the findings of the DOE?s program review, FCTC?s Pell program was placed on the HCM2 method of reimbursement effective December 13, 2017. Under HCM2, FCTC continues to obligate funds under the Pell program to eligible students and requests reimbursements from the DOE through documentation of student eligibility. As a result, obligated Pell funds processed by FCTC in an earlier award year are subjected to approval by the DOE, and if approved, may not be recorded on the SEFA until a later fiscal year. The COA information related to award year 2018 was entered into COD by FCTC personnel during or prior to award year 2018. District personnel administering the Pell program were new to their positions and were still being trained during the 2018 award year. Prior to receiving proper training, the personnel responsible for administering the Pell program did not always report the proper COA in COD. Although District personnel administering the Pell program have now received necessary training and began reporting correct information as of the 2019 award year, corrections to information already entered into COD were not made. Cause: Personnel responsible for administering the Pell program did not know whether information entered in a prior year or earlier could or should be changed while under HCM2, which has strict submission guidelines. In addition, the personnel responsible for administering the Pell program did not consider correction necessary since the COA information that was entered incorrectly into COD did not affect the calculation of awards or the amounts ultimately disbursed to students. The actual COA, which was properly used for the award calculations, and the COA that was entered into COD are both well above the highest threshold in the Pell Payment Schedules provided by the DOE. Effect: Information entered incorrectly in prior award years was not corrected prior submission of the report in the current year. There was no effect on the calculation of awards or disbursements to be provided to students. Recommendation: We recommend the District consult with the DOE to deterime whether the prior year COD reports should be corrected. Views of Responsible Officials: As indicated in the finding, District personnel administering the Pell program were new to their positions as a result of the transition of First Coast Technical College (FCTC) from a charter school to a District operated school. In conjunction with this transition, FCTC was placed on HCM2. Futhermore, as indicated in the finding, while the Cost of Attendance (COA) was incorrect in COD for the 2018 award year, the COA is correct for the 2019 award year. In addition, the COA for the 2018 and 2019 award years was correctly reported under HCM2 for the required student information. At the direction of the DOE, District personnel can correct the COA in COD for the 2018 award year.

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