Santa Rosa City Schools District

"Federal Program Information: 84.365 - Title III, English Learner Student Program Federal Grantor Agency: 84.365 ? ESEA (ESSA): U.S. Department of Education Pass-Through Grantor Agency: 84.365 - Special Education: California Department of Education Criteria or Specific Requirements: Pursuant to Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Title III funds can only be used to supplement, not supplant federal, state, and local public funds that, in the absence of such availability, would have been expended for programs for English learners and immigrant children and youth, and in no case to supplant such federal, state, and local public funds. Condition: During the fiscal year, the District was chosen by the California Department of Education (CDE) to undergo a review of its Tittle III program as part of the CDE?s federal program monitoring (FPM) process. The review resulted in findings related to supplanting with Title III and EIA-LEP federal funds. The FPM review noted the following requirements that were not met: 1. General fund resources must be used to provide services and programs for English learners, including English language development (ELD) and access to the core curriculum. The provision of such services and programs must not be contingent on the receipt of state or federal supplementary funds. 2. Each LEA must use EIA-LEP carryover funds only to supplement, not supplant federal, state and local public funds. (20 U.S.C. ? 6825(9); EC?54025[c]: Castaneda v. Pickard (5th Cir. 1981) 648 F.2d 989, 1010, 1012-1013) 3. For LEAs with EIA-LEP carryover, an LEA must utilize no less than 85 percent of those apportionments at school sites for direct services to students. (EC ?? 63000[d], 63001) 4. Each LEA must use Title III funds only to supplement, not supplant federal, state, and local public funds that, in the absence of such availability, would have been expended for programs for English learners and immigrant children and youth and in no case to supplant such federal, state, and local public funds. (20 U.S.C. ? 6825(9); Castaneda v. Pickard (5th Cir. 1981) 648 F.2d 989, 1010, 1012- 1013) 5. The use of Title Ill funds must meet the following requirements: a) An LEA utilizes no less than 98 percent of Title Ill EL apportionments on direct services to English Learners and may not use more than 2 percent of such funds for the administration of this program for a fiscal year. (20 U.S.C. ? 6825[b]) b) An LEA assesses for reasonable Title Ill EL and immigrant alignment with the federal supplement, not supplant requirement. (20 U.S.C. ? 6825(9); Castaneda v. Pickard (5th Cir. 1981) 648 F.2d 989, 1010, 1012-1013) Questioned Costs: The net questioned costs related to this finding were $452,471. Context: The District should maintain controls to prevent noncompliance with Uniform Guidance or detect and correct noncompliance with Uniform Guidance in a timely manner. Effect: The District was not in compliance with Title III supplanting requirements and reversed $452,471 in FY19 expenditures to unearned revenue. As a result of this audit, $452,471 was reclassified from unearned revenue to accounts payable until allowable expenditures are incurred in FY20. Cause: The District's grant monitoring controls were ineffective and District staff were not aware of Title III and EIA-LEP supplanting requirements. Recommendation: We recommend that the District track federal grants by resource and CFDA and include items such as grant award, amount expended, general ledger account code, grant period,supplanting requirements and other compliance requirements for each grant. This tracker should be shared with pertinent employees in each department and updated routinely during the year. This can be done as a part of the budgeting process as well. Corrective Action Plan: The District agrees with the recommendations and will implement the recommended practices to ensure that incurred expenditures are allowable and supplement, rather than supplant federal funds, in order to be in compliance with Uniform Guidance for all federal programs. "

Corrective Action Plan: The District agrees with the recommendations and will implement the recommended practices to ensure that incurred expenditures are allowable and supplement, rather than supplant federal funds, in order to be in compliance with Uniform Guidance for all federal programs. We recommend that the District track federal grants by resource and CFDA and include items such as grant award, amount expended, general ledger account code, grant period,supplanting requirements and other compliance requirements for each grant. This tracker should be shared with pertinent employees in each department and updated routinely during the year. This can be done as a part of the budgeting process as well.