Franklin Parish School Board

Criteria: Contracts and subcontracts involving construction activity with federal funds are subject to the Davis-Bacon prevailing wage requirements. As such, the School Board, as a subgrantee to the State of LA, must monitor its construction contractors through review of payrolls for payment of Davis Bacon Act prevailing wage requirements. Condition: The School Board conducted construction activities with the ESSER funds, including roofing, window replacements, and other, but did not monitor its contractors’ compliance with Davis Bacon wage requirements. Universe/ Population: Approximately $345,000 was spent on construction type activities that under projects that would have required monitoring. None of the contractors performing the activity were monitored. Effect: The School Board is non-compliant with the requirements to monitor its subrecipients with respect to Davis-Bacon compliance. Cause: Construction activities are rarely conducted with educationally related federal grants and the administration was unfamiliar with the requirements. Recommendation: The School Board should be wary of all grant requirements prior to acceptance of the grant award. View of Responsible Officials and Corrective Action Plan: The Federal Programs Director acknowledges that we were not compliant with the Davis-Bacon requirement concerning prevailing wages. This project was completed early in the process of receiving ESSER funding and we were unaware of the Davis-Bacon wage requirements. Moving forward, the Federal Programs department and the Business department will work together to ensure that all Davis-Bacon requirements are met.

Criteria: Non-federal entities must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326 (the Uniform Guidance) and use their own documented procurement procedures, which reflect applicable State and local laws and regulations provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Internal controls should be designed to ensure compliance with these federal requirements.Additionally, contracts involving federal funds must include certain provisions of Appendix II part 200. Condition: The Child Nutrition Program is administered for the School Board by the CNP department. The Department’s purchase of produce products was not subjected to bidding or other means of competitive solicitation in accordance with the Unform Guidance. Additionally, the contracts with vendors do not include the provisions contained in Appendix II part 200. Universe/ Population: Food purchases subject to the procurement regulations totaled approximately $1,000,000, among 5 vendors, of which 4 contracts totaling $800,000 were subject to audit. Of the 4 audited, 1 contract with purchases totaling $120,000 for the fiscal year was found to be non-compliant. Effect: The School Board may be non-compliant with the Uniform Guidance with respect to this contract for produce products. Cause: A shortage of suppliers in the geographic area may have led to the decision to forego the pricing and/or bidding process. Recommendation: Pricing, bidding or other forms of solicitation allowed by the Uniform Guidance should be conducted by the School Board’s Child Nutrition Department. Contracts should be standardized to include the language and provisions of Appendix II part 200. View of Responsible Official and Corrective Action Plan: The Child Nutrition Supervisor acknowledges the finding regarding the purchase of produce products for SY 2022-23. There is only one regional produce distributor that successfully delivers to the Franklin Parish area with accurate invoices and timely deliveries based on past history. Due to staff changes and re-assignment of essential job functions, the produce bid was overlooked for this this year only. Moving forward, the CNP Supervisor bas established a procurement schedule for developing and revising necessary formal bids in compliance with Federal and State requirements and all CNP central office staff. During SY 2022-23, the Franklin Parish Child Nutrition Program experienced multiple shortages of canned and frozen vegetables and fruits. This made it essential to fill in with fresh produce to meet meal pattern requirements. This created a marked increase in the cost of the fresh produce available to us and increased our reliance on fresh produce.

Criteria: 2 CFR 200.318 (a section of the procurement standards applicable to federal grant programs) require that time and materials contracts include a not?to-exceed amount to be stated within the contract. Furthermore, appendix II to the standards require certain compliance matters to be included in contracts. Condition: The School Board purchased conflict resolution services in the amount of approximately $25,000, however, the contract for these services was for time and materials at a preset rate (which is allowed), but a maximum not-to-exceed was not included in the contract. Also, the compliance matters required by appendix II were not included in the contract. Universe/population: A sampling of six procurements totaling $110,042 were selected for testing from a population of 10 totaling $200,388. Effect: If not-to-exceed amounts are not stated in the contract, the School Board and the Program risk paying more than necessary for goods and services. If the provisions of appendix II are not included then the School Board risks lacking various protections under federal law. Cause: This appears to the result of oversight. Recommendation: All contracts involving federal programs should include the provisions of 2 CFR 200.318 and appendix II of the Uniform Guidance. Views of Responsible Officials: While we did not have the wording "not to exceed a specific amount" on the contract in question, we did have a set amount of time to not exceed. This amount of time and the cost per hour was figured into the budget. The budget was reviewed prior to making expenditures and monitored on at least a monthly basis to not exceed the amount budgeted. However, we now realize the need to include such wording. Moving forward, we will amend the current contracts to add a "not to exceed a specific amount" and continue to monitor the budget to not exceed the budget for the 2022-2023 fiscal year. We will also add the wording "not to exceed a specific amount" on all contracts for the 2023-2024 school year.

Criteria: 34 CFR ?200.19(b) requires that an LEA must report graduation rate data for all public high schools at the school, LEA, and state levels using the four-year adjusted cohort rate. To remove a student from the cohort, a school or LEA must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. To confirm that a student transferred out, the school or LEA must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. A student who is retained in grade, enrolls in a GED program, or leaves school for any other reason may not be counted as having transferred out for the purpose of calculating graduation rate and must remain in the adjusted cohort Condition: In testing internal controls and compliance with respect to 34 CFR ?200.19(b), 1 of 24 leavers had an exception to the required documentation set forth by the Louisiana Administrative Code Title 28, Part LXXXIII, Chapter 6, ?611, the pass-through agency?s regulation for the program (LDOE). This rate of exception indicates that the School System internal control procedures may not be sufficient to ensure that all documentation is maintained contemporaneously with the removal of the student to support the removal from a cohort. Effect: Without maintenance of required documentation for exiting students, the School System is at risk for non-compliance and potentially loss of Title 1 funding. The compliance effects of this finding are mitigated by documentation obtained from the LDOE prior to the release of this report. Cause: This appears to the result of oversight. Recommendation: All documentation to support removal of a student from the graduation cohort calculation should be maintained. Safeguards and controls to ensure files are complete and that cohort rates include only students with required documentation should be employed. Views of Responsible Officials: School officials will follow up on securing documentation of students who are dropped from school rosters to ensure proper documentation and accurate calculation of the graduation cohort rate.

10.555 Child Nutrition Cluster 10.553 Criteria: The Uniform Guidance requires non-federal grant recipient to minimize the level of federal funds on-hand and for pass-through entities to monitor cash levels of its subrecipients. This guidance also requires financial reports of program activity to be filed accurately. The Louisiana Department of Education (LDE) requires annual reports from subrecipients (SFS-8b) in its efforts to monitor available operating cash of subrecipients and limiting their cash levels to three months operating needs. Condition: While the School System filed the annual report which showed it to be materially compliant with the 3month available cash limit, the report that was filed with the LDE contained a material error. The reported cash for June 30, 2020 per the SFS-8b was $51,173, while our audited amount came to $623,743. Effect: Again, the School Board appears to be compliant with 3-month cash level limit, but inaccurate reporting and tracking of these levels can result in future non-compliance. Cause: The SFS-8b reports are being completed by Child Nutrition Program staff without input or review from the accounting department. Recommendation: We recommend for the accounting department either prepare the form SFS-8b or review and approve the form prior to filing. Amounts reported should be derived from the general ledger and/or approved budgets. Views of Responsible Officials: The SFS-8b reports will be reviewed by the Business Manager prior to submission to the Louisiana Department of Education to ensure that accurate general ledger information is reported

84.027 Special Education Cluster (IDEA) Procurement (continued) 84.173 Grant No(s): 2819B121 that implement Executive Orders 12549 (3 CFR Part 1986 Comp., p. 189) and 12689 (3 CFR Part 1989 Comp., p. 235), ``Debarment and Suspension.?? The Excluded Parties List System in SAM contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: While testing compliance with the federal procurement regulations, we selected 2 of the 10 vendors with expenditures greater than $10,000 and less than $250,000 and observed the documentation to support the procurement process. These 2 vendors provided professional services during year ended June 30, 2019. Our compliance test focused on the proper renewing and awarding of the contracts to determine compliance with the procurement regulations. The two contracts totaled $46,727. The federal award, Special Education Cluster responsible for administering and contracting with these 2 vendors is IDEA Part B, no evidence was provided to demonstrate that quotes and prices were obtained from an adequate number of vendors or providers as required by Federal procurement regulations. Also, no evidence was provided to demonstrate that the vendor was appropriately checked for suspension and debarment. And finally, the contracts did not contain the provisions required by Appendix II to Part 200. Effect: The School Board is not in compliance with the requirements of the Uniform Guidance Procurement regulations. Cause: Personnel administering the grants and those in the School Board purchasing department did not execute and enforce the revised purchasing policy containing the new Uniform Guidance requirements. Recommendation: We recommend for the School Board to more fully implement and follow its revised policies and procedures for purchases made with federal awards so that these newly required federal procurement regulations are followed. We recommend that the School Board include Appendix II to Part II Summary as applicable in their future contracts. Management?s Response and Planned Corrective Action: The School board will include Appendix II to Part II Summary as applicable in future contracts. We will also more fully implement our revised policies and procedures for purchases made with federal awards so that newly required federal procurement regulations are followed.