Suwannee County District School BoardLocal Government

Finding: The District did not always maintain required documentation to support adjustments to the high school graduation rate cohort. Criteria: Title 20, Section 7801(25), United State 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 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 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 that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. Also, before a student is removed from the cohort for enrolling in a home education program, District procedures require District personnel to verify of record that the student enrolled in the program. Condition: To determine whether the District maintained appropriate documentation to support the removal of student counts from the 2021-22 fiscal year graduation rate cohort, we requested District records supporting 40 selected students who were removed from the cohort. The removal of 36 students from the cohort was appropriately supported by District records. However, for 4 other students, District records included parent-signed copies of school withdrawal forms documenting intentions for student enrollment in a home education program but excluded verification of record that the students enrolled in the program. Cause: District personnel indicated that the documentation deficiencies occurred because of District oversight. Effect: Subsequent to our audit inquiry, in September 2022 District personnel attempted to verify that the 4 students enrolled in home education programs or other programs that culminated in the award of a regular high school diploma. However, the attempts produced no evidence to support removal of the students from the cohort. Consequently, the District corrected the withdrawal code for the 4 students to ?status unknown? and added the students back to the cohort. Without appropriate documentation supporting the 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 follow-up to confirm of record that students who plan to enroll in home education programs actually enroll to justify removal of the students from the high school graduation rate cohort. District Response: In response to the deficiency identified by this finding, the Suwannee County School District will ensure each high school principal designates an onsite person to process all student withdrawals. This designee will be responsible for verifying that the Letter of Intent for home education has been properly completed at the time of the withdrawal. Additional follow-up will occur in the event assistance is needed with the transition.

Finding: The District did not always accurately or timely report Program enrollment data. Criteria: Title 34, Section 685.309(a)(2), Code of Federal Regulations, requires the District to submit reports in accordance with deadlines established by the U.S. Department of Education (ED). The ED Dear Colleague Letter GEN 14-07 requires that enrollment information be requested from schools every 60 days and schools respond to those requests using the NSLDS within 15 days of the date that the ED sends the electronic enrollment reporting roster to the school or to the school?s designated third-party servicer. Schools have the ability to report enrollment data to the NSLDS by batch or online submission. The NSLDS permits schools to request enrollment information be sent more often than every 60 days and allows schools to enter ad-hoc updates to a student?s enrollment on the NSLDS Web site. In addition, effective supervisory oversight should include review and approval of enrollment data to verify the timeliness and accuracy of activity reported to the NSLDS. Condition: The District received enrollment information requests from the ED every 60 days and District procedures provided for financial aid personnel to update the student records on the NSLDS Web site using the online update function of the NSLDS Web site within 15 days of receiving the enrollment information from the ED. However, District personnel did not determine that enrollment records for students who enrolled or had enrollment status changes during the 2021-22 fiscal year were always timely reported in the NSLDS nor were supervisory review procedures established to verify the timeliness and accuracy of reported activity. From the population of 83 students who received Program funds and enrolled or had status enrollment changes during the 2021-22 fiscal year, we examined records related to 25 selected students to determine whether the District accurately and timely reported enrollment data using the NSLDS. We found that: ? As of July 19, 2022, the District had not reported enrollment to the NSLDS for 2 students and 306 days had elapsed since the 15-day deadline. ? The enrollment status changes for those 2 students and 2 other students were reported to the NSLDS 22 to 245 days, or an average of 127 days, after the 15-day deadline. Cause: Due to financial aid office staff changes and lack of effective supervisory oversight, student enrollment and enrollment status changes were not always timely and accurately reported. Effect: When the NSLDS is not timely provided correct enrollment information, the effectiveness of the NSLDS for monitoring and evaluating Program grant recipients is diminished. Recommendation: The District should enhance procedures to ensure that enrollment and enrollment status changes for Program grant recipients are timely reported in the NSLDS. Such enhancements should include appropriate training for financial aid office staff and supervisory review and approval to verify the timeliness and accuracy of the information reported. District Response: In response to the deficiency identified by this finding, the District will update the National Student Loan Data System (NSLDS) monthly to reflect Federal Financial Aid enrollment status changes and will ensure the delivery of appropriate training for financial aid office staff and supervisors.

Finding: District controls did not always ensure compliance with the Davis-Bacon Act for Federally funded construction projects exceeding $2,000. Criteria: The ESSER 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 and subcontractors pay workers the prevailing wage rates established by the Department of Labor. 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 work. Condition: During the 2020-21 fiscal year, the Board entered into a construction contract for reroofing and HVAC repairs to the Suwannee Riverside Elementary School for $1,293,043.62 and another construction contract for similar repairs at the Suwannee Middle School for $245,188.51, and had expended ESSER funds totaling $185,779.55 and $109,144.64, respectively, on the two projects as of June 30, 2021. In response to our inquiry, District personnel indicated that they had not performed direct comparisons of wage rates paid by the contractor and subcontractors for the two projects with the prevailing wages established by the United States Department of Labor. In addition, we noted that the purchase orders, requests for proposal, bid specifications, and contracts for the two projects did not contain clauses that required the contractors and subcontractors to comply with the Davis-Bacon Act provisions. Subsequent to our inquiry, the District obtained certified payrolls from the contractor demonstrating the prevailing wage rates were paid for these projects. Cause: District personnel indicated they were not aware that the Davis-Bacon Act applied to the two projects. Effect: Without an appropriate understanding of the Davis-Bacon requirements and when to apply the requirements, there is an increased risk that that construction contractors and subcontractors paid with Federal moneys will not pay workers the prevailing wage rates established by the Department of Labor. Recommendation: The District should establish procedures to comply with all provisions of the Davis-Bacon Act. Such procedures should include appropriate training for staff to understand the Davis-Bacon Act requirements and when the requirements should be applied. In addition, the procedures should ensure that Federally funded contracts involving construction, alteration, or repair of District facilities include the required prevailing wage rate clauses and that wage rates paid by the contractor and subcontractors for such projects are directly compared to and determined to be consistent with the prevailing wages established for the geographic area by the United States Department of Labor. District Response: In response to the deficiency identified by this finding, the District will comply with the provisions of the Davis-Bacon Act in the event federal funds are expended on future projects which are subject to the Act.

Finding: The District did not always accurately and timely report Program enrollment data. Criteria: Title 34, Section 685.309(a)(2), CFR, requires the District to submit reports in accordance with deadlines established by the U.S. Department of Education (ED). The ED Dear Colleague Letter GEN 14-07 requires that enrollment information be requested from schools every 60 days and schools respond to those requests using the NSLDS within 15 days of the date that the ED sends the electronic enrollment reporting roster to the school or to the school?s designated third-party servicer. Schools have the ability to report enrollment data to the NSLDS by batch or online submission. While reporting enrollment information every 60 days will satisfy the enrollment reporting requirement, the NSLDS permits schools to report more frequently than required by allowing schools to request enrollment information be sent more often than every 60 days and by allowing schools to enter ad-hoc updates to a student?s enrollment on the NSLDS Web site. Condition: The District received enrollment information requests from the ED every 60 days and District procedures provided for financial aid personnel to update the student records on the NSLDS Web site using the online update function of the NSLDS Web site within 15 days of receiving the enrollment information from the ED. However, District personnel did not determine that enrollment records for students with enrollment status changes during the 2020-21 fiscal year were timely reported in the NSLDS nor were supervisory review procedures established to verify the timeliness and accuracy of reported activity. From the population of 108 students who received Program funds and had enrollment status changes during the 2020-21 fiscal year, we examined records related to 25 students to determine whether the District accurately and timely reported enrollment changes using the NSLDS. We found that: ? The enrollment status changes for 13 of the 25 students were reported to NSLDS 3 to 153 days, or an average of 29 days, after the 60-day deadline. Additionally, for one of the 13 students, the reported enrollment status change date was incorrectly dated September 30, 2021, instead of the correct date of May 3, 2021. ? At the time of our inquiry on October 12, 2021, the District had not reported the enrollment status change for 1 of the 25 students, which was 45 days past the 60-day deadline. Cause: Due to financial aid office staff changes, District personnel did not completely understand NSLDS enrollment reporting requirements and the District lacked supervisory review procedures to verify timely and accurate reporting. Effect: When the NSLDS is not timely provided correct enrollment information, the effectiveness of the NSLDS for monitoring and evaluating the enrollment status of Program grant recipients is diminished. Recommendation: The District should enhance procedures to ensure that enrollment status changes for Program grant recipients are timely and accurately reported in the NSLDS. Such enhancements should include appropriate training for financial aid office staff and supervisory review and approval to verify the timeliness and accuracy of the information reported. District Response: In response to the deficiency identified by this finding, the District will update the National Student Loan Data System (NSLDS) monthly to reflect Federal Financial Aid enrollment status changes.

U.S. DEPARTMENT OF EDUCATION (ED) Finding Number: 2020-001 CFDA Number: 84.063 Program Title: Student Financial Assistance (SFA) Cluster - Federal Pell Grant Program (Pell Grant Program) Compliance Requirement: Special Tests and Provisions ? Verification Pass-Through Entity: Not Applicable Federal Grant/Contract Number and Grant Year: P063P192955 ? 2020 Statistically Valid Sample: No Finding Type: Opinion Modification, Noncompliance and Material Weakness Questioned Costs: $102,733 Prior Year Finding: Not Applicable Finding: The District did not always perform the required Pell Grant Program verification procedures prior to Program award disbursements, update student applications and other information based on information that was verified, or recalculate awards based on the verified information. Because District records did not support Program awards to 26 students, awards totaling $102,733 to those students represent questioned costs subject to disallowance by the grantor. Criteria: Title 34, Sections 668.51 through 668.61, Code of Federal Regulations (CFR), require applicants whose Free Application for Federal Student Aid (application) is selected by the ED for verification to provide to the District certain documentation used in determining the applicant?s expected family contribution (EFC). The documentation required for verification depends on the verification group identified on the student?s Institutional Student Information Record (ISIR). The standard verification group requires verification of, for example, parental income, household size, and number of family members attending postsecondary educational institutions and District personnel use a verification form to document student information verifications. For discrepancies identified by the verification process, the application and the ISIR must be updated with corrected information and the student?s award must be recalculated based on the EFC included on the updated ISIR. For example, changes to family size as a result of the verifications require ISIRs to be updated, which may impact student eligibility. Condition: For the 2019-20 fiscal year, the District reported Pell Grant Program expenditures totaling $724,378 999 on the Schedule of Expenditures of Federal Awards, 200 students participated in the Program, and the ED selected 55 student participants for verification. In August 2020, we requested for examination District records supporting all District verifications; however, correspondence was provided to document verification attempts for only 35 students. As of November 20, 2020, and subsequent to our inquiry, we found that: ? District personnel still had not documented verifications for 4 students with Program awards totaling $13,380. ? Verification documentation for 22 students with awards totaling $89,353 was not complete as: o Income verification was not obtained for 18 students. o Household sizes for 10 students (including 6 students without income verifications) were reported differently on the students? verification forms than on the students? ISIRs. Although we requested, District records were not provided to evidence any efforts to update the application or ISIRs for the household size reported on the verification form or any recalculations of the students? awards. Cause: In response to our inquiry, District personnel indicated that, due to financial aid staff changes, the verification process and documentation requirements were not fully understood and ISIRs were not always updated based on information obtained during the verification process. Also, policies and procedures had not been established to require documented, supervisory review and approval of the verifications to ensure that verifications are accurately and properly performed. Effect: Absent effective verification procedures and supervisory approval of the verifications performed, there is an increased risk for incorrect student award amounts and for the Pell Grant Program to be overcharged. Because the Pell Program awards were unsupported for 26 awards, Program awards totaling $102,733 made to those students represent questioned costs subject to disallowance by the grantor. Recommendation: The District should establish policies and procedures to require and ensure that the required verifications are performed. Such policies and procedures should include documented, supervisory review and approval of student verification information to confirm the accuracy and propriety of the verifications. Also, the District should provide documentation to the ED supporting the allowability of the $102,733 questioned costs or restore this amount to the Program. District Response: In response to the deficiency identified by this finding, designated RIVEROAK Technical College staff implemented corrective verification procedures and implemented additional safeguards whereby supervisory oversight will ensure that required verifications are performed. This supervisory oversight will be an additional compensating control to ensure that verifications are properly documented.

U.S. DEPARTMENT OF EDUCATION Finding Number: 2020-002 CFDA Number: 84.063 Program Title: Student Financial Assistance (SFA) Cluster - Federal Pell Grant Program (Program) Compliance Requirement: Special Test and Provisions ? Enrollment Reporting ? National Student Loan Data System (NSLDS) Pass-Through Entity: Not Applicable Federal Grant/Contract Number and Grant Year: P063P192955 ? 2020 Statistically Valid Sample: No Finding Type: Noncompliance and Significant Deficiency Questioned Costs: Not Applicable Prior Year Finding:= Not Applicable Finding: District did not always timely report Program enrollment data. Criteria: Title 34, Section 685.309(b)(2), CFR, requires the District to submit reports in accordance with deadlines established by the ED. The ED Dear Colleague Letter GEN 14-07 provides that enrollment information will be requested from schools every 60 days and schools will be required to respond to those requests using the NSLDS within 15 days of the date that the ED sends the electronic enrollment reporting roster to the school or to the school?s designated third-party servicer. Schools have the ability to report enrollment data to the NSLDS by batch or online submission. While reporting enrollment information every 60 days will satisfy the enrollment reporting requirement, the NSLDS allows schools to report more frequently than required by allowing schools to request enrollment information to be sent more often than every 60 days and by allowing schools to enter ad-hoc updates to a student?s enrollment on the NSLDS Web site. Condition: The District received enrollment information requests from ED every 60 days and District procedures provided for financial aid personnel to update the student records on the NSLDS Web site using the online update function of the NSLDS Web site within 15 days of receiving the enrollment information from ED. However, District personnel did not determine that enrollment records for students with enrollment status changes during the 2019-20 fiscal year were timely reported in the NSLDS nor were supervisory review procedures established to verify the timeliness of reported activity. From the population of 133 students who received Program funds and had enrollment status changes during the 2019-20 fiscal year, we examined records related to 19 students to determine whether the District accurately and timely reported enrollment changes using the NSLDS. While we found that information was accurately reported, the enrollment status changes for 16 of the 19 students were reported to NSLDS 13 to 192 days, or an average of 74 days, after the 60 day deadline. Enrollment status changes for 9 of the 16 students were not reported until after our inquiry. Cause: Due to financial aid office staff changes, District personnel did not completely understand NSLDS enrollment reporting requirements and the District lacked supervisory review procedures to verify timely reporting. Effect: When the NSLDS is not timely provided enrollment information, the NSLDS cannot be used to monitor and evaluate the enrollment status of Program grant recipients. Recommendation: The District should enhance procedures to ensure that enrollment status changes for Program grant recipients are timely reported in the NSLDS. Such enhancements should include supervisory review and approval to verify the timeliness of information reported. District Response: In response to the deficiency identified by this finding, designated RIVEROAK Technical College staff will conduct updates to the National Student Loan Data System (NSLDS) on a monthly basis to reflect federal financial aid enrollment status changes. An additional compensating control will be the supervisory oversight by the Student Services Coordinator to ensure that updates are both timely and accurate.

U.S. DEPARTMENT OF AGRICULTURE Finding Number: 2020-003 CFDA Number: 10.553, 10.555, 10.559 Program Title: Child Nutrition Cluster (CNC) Compliance Requirement: Allowable Costs/Cost Principals ? Indirect Costs Pass-Through Entity: Florida Department of Agriculture and Consumer Services (FDACS) Federal Grant/Contract Number and Grant Year: Contract # 18288 ? 2020 Statistically Valid Sample: No Finding Type: Nonmajor Federal Program, Noncompliance, and Questioned Costs Greater Than $25,000 Questioned Costs: $95,396 Prior Year Finding: Not Applicable Finding: The District charged indirect costs to the CNC for food expenditures, which is not an allowed cost objective for incurring indirect costs, resulting in questioned costs totaling $95,396. Criteria: Title 2, Part 200, Code of Federal Regulations, provides principles for determining allowable costs, including indirect costs that may be allocated to a Federal program. Indirect costs are costs that are incurred for a common or joint purpose, are not readily identified with a particular final cost objective without effort disproportionate to the results achieved, and are calculated by multiplying allowed costs by an approved indirect cost rate. To require consistent indirect cost rate calculations and application of the rate to allowable CNC expenditures, the U.S. Department of Agriculture (USDA) published USDA Indirect Costs Guidance for State Agencies and School Food Authorities. The guidance provides that food expenditures are excluded when calculating the indirect cost rate and the indirect cost charges because the activities require minimal administrative support. Condition: For the 2019-20 fiscal year, the District correctly excluded food expenditures from the indirect cost rate calculation; however, the District inadvertently charged to the CNC indirect costs for food expenditures. Cause: District personnel responsible for calculating the indirect cost reimbursement were new to the position and unaware of the USDA guidance that food expenditures should be excluded from CNC indirect cost charges. Effect: The District overcharged the CNC for indirect costs and incurred questioned costs totaling $95,396 for the 2019-20 fiscal year. Subsequent to our inquiry, in November 2020, the District restored these questioned costs to the food service program. Recommendation: The District should enhance procedures to ensure that only allowable indirect costs are included in the indirect cost calculation and charged to the CNC food service program. Such enhancements should include indirect cost training for personnel responsible for the CNC. District Response: In response to this finding and subsequent to year end reporting, the District became aware of the exclusion of food expenditures when calculating indirect costs. The District has made the appropriate adjustment in the accounting ledgers for the Food Service and General Funds. Food expenditures will be excluded from the calculation going forward.

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