ATTALLA CITY SCHOOLSLocal Government

Funds from COVID-19 Education Stabilization Fund (ESF) were used to fund construction contracts in excess of $2,000 without the inclusion of prevailing wage rate clauses as required by Title 29, U.S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the “Davis-Bacon Act”). The Board did not have controls in place to ensure the Davis-Bacon Act wage rate requirements were included in construction contracts. Therefore, the construction project contract awarded during the fiscal year did not include prevailing wage rate clauses nor did the contractors submit weekly certified payrolls to the Board. Response: Management will implement controls to ensure future contracts funded with COVID-19 Education Stabilization Funds (ESF) in excess of $2,000 specify applicability of wage rate requirements.

2022-001

Reference Number: 2022-001 Compliance Requirement: Special Tests and Provisions Type of Finding: Internal Control and Compliance Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance CFDA Number and Title: 84.425 ? COVID-19 Education Stabilization Fund Federal Award Agency: U.S. Department of Education Pass-through Entity: Alabama Department of Education Funds from COVID-19 Education Stabilization Fund (ESF) were used to fund construction contracts in excess of $2,000 without the inclusion of prevailing wage rate clauses as required by Title 29, U.S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the ?Davis-Bacon Act?). The Board did not have controls in place to ensure the Davis-Bacon Act wage rate requirements were included in construction contracts. Therefore, the construction project contract awarded during the fiscal year did not include prevailing wage rate clauses nor did the contractors submit weekly certified payrolls to the Board. Response: Management will implement controls to ensure future contracts funded with COVID-19 Education Stabilization Funds (ESSER) in excess of $2,000 specify applicability of wage rate requirements. Anticipated Completion Date: Contact Person(s): Laura Leak, Chief School Financial Officer

Testing of the Board?s time and effort disclosed that personnel costs charged to federal programs is not supported by time and effort records in accordance with the Uniform Guidance subpart D ?200.430(i)(1)(vii). We recommend the Board document time and effort charged to federal programs in a manner that specifically identifies which employees? costs is charged to federal programs and maintains documentation supporting such allocation. Management responds that such documentation will be maintained. This finding generated no questioned costs. Response: Management will maintain such documentation to meet time and effort reporting requirements.

Finding 2020-001 Cluster: Child Nutrition Cluster Grantor: U.S. Department of Agriculture Award Name: Child Nutrition Award Year: Various Award Number: 196 - Passed through Alabama Department of Education CFDA Number: 10.553, 10.555, 10.559 Testing of the Board's summer feeding meal reimbursements revealed discrepancies in total meals claimed for reimbursement and actual meals served per meal count sheets. This material weakness resulted from insufficient controls to correctly document the number of meals served and reconcile meal counts to claims for reimbursement. We recommend the Board implement controls to ensure correct and accurate meals served are claimed for reimbursement. Response: Management has implemented controls subsequent to year end to ensure meals served are accounted for correctly. The manager verifies with the cashier that the correct number of meals served match the production records and tally sheets. This ensures when students get a meal late, remote feedings, or other causes of discrepancies are noted. The manager's production records are documented separately not changed to match the cashier's numbers of meals served. Lunchroom managers will meet with CNP Management monthly. If edit checks do not match tally sheets it will be noted separately and documented with signatures from lunchroom manager and director. This ensures accurate meal claims. Anticipated Completion Date: December 7, 2020 Contact Person(s): Jennifer Jones, Director of General Services

Finding 2020-002 Cluster: Child Nutrition Cluster Grantor: U.S. Department of Agriculture Award Name: Child Nutrition Award Year:Various Award Number: 144 - Passed through Alabama Department of Education CFDA Number: 10.553, 10.555, 10.559 During the testing of the Board's summer feeding meal reimbursements, changes to original source documentation without supporting documentation or other evidentiary matter noting the basis for such changes were noted. We recommend the Board implement controls prohibiting changes to original source documentation in all circumstances and that any changes considered necessary be documented separately to preserve the integrity of the audit trail. Response: Management has implemented controls subsequent to year end to prevent any changes to original source documentation ; any changes necessary must be documented separately . The manager and assistant manager now verify that their production records match their daily meal count. If there is a discrepancy then documentation is added to the production record not altered (when students have field trips, early dismissal, remote meals, etc.) The manager and cashier have been informed to pay more attention when entering their daily counts into the bulk entry edit check. The CNP management meet monthly with each lunchroom manager to review the production records, tally sheets, and edit checks. Any discrepancies are documented separately and signed by lunchroom manager and director. Anticipated Completion Date: December 7, 2020 Contact Person(s): Jennifer Jones, Director of General Services

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