Ascension Parish School BoardLocal Government

Questioned Costs: Not applicable Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.510 requires, an auditee to prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR section 200.502. With respect to Disaster Grant – Public Assistance Grants, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA) when (1) FEMA has approved the nonfederal entity’s Project worksheet, and (2) the nonfederal entity has incurred the eligible expenditures. Federal awards expended in years after the fiscal year in which the Project is approved are to be recorded on the nonfederal entity’s SEFA in those subsequent years. Universe/Population: Not applicable. Condition: The dollar amount of federal awards expended for the Disaster Grant – Public Assistance was not reported accurately on the prepared schedule provided by management. Cause: Internal controls have not been properly established over the reconciliation of FEMA approved projects with allowable expenditures for reporting on the SEFA. Effect: Improper reporting of expenditures resulted in an incorrect assessment of the major federal programs to be audited as the dollar threshold distinguishing type A and B programs remained volatile based on revisions and reconciliation of expenditures recorded in the fund for which disaster grant funding was to be the source of reimbursement. Recommendations: The School Board should develop and establish a process with its outsourced administrator of FEMA funded projects to ensure the proper federal awards are reported on the SEFA. View of Responsible Official: Management concurs with this finding, see corrective action plan dated March 27, 2024.

2023-002: Compliance and Internal Control over Procurement - Sole Source and Suspension and Debarment Special Education Cluster Assistance Listing Numbers – 84.027A; 84.027X; 84.173A; and 87.173X Passthrough Agency: Louisiana Department of Education Questioned Costs: $84,880 Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.320 requires, among other things, that specific criteria be met for the procurement of noncompetitive proposals. Procurement of noncompetitive proposals is procurement through solicitation of a proposal from only one source, also known as a sole source vendor. This method may only be used when one or more of the following circumstances apply: • The item is available only from a single source. • The purchase is in response to a public emergency that will not permit a delay resulting from the competitive process. • The purchase is expressly authorized by awarding or pass-through agency in response to a written request from the non-Federal entity or after solicitation of a number of sources, competition is determined inadequate. To ensure compliance with these requirements, justification of the use of noncompetitive proposals and research on the availability from multiple sources must be documented. Documentation of authorization must be retained, and any initial solicitations from multiple sources which are concluded to be inadequate, and such reasoning must be documented. In addition, non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods or services awarded under a non-procurement transaction (e.g. a grant or cooperative agreement) that is expected to equal or exceed $25,000. Universe/Population: The total population for procurement considerations was all vendors of the Special Education Cluster whose transactions for the year ended June 30, 2023, exceeded the micro-purchase threshold of $10,000. Payroll and benefit-related transactions were excluded from the population. Based on these requirements, the population consisted of thirty-eight vendors totaling $1,729,409. There was a total of twenty-four vendors whose payments exceeded $25,000 when considering compliance with suspension and debarment regulations. Only five of the twenty-four were related to covered transactions.Condition: Five vendors with expenditures totaling $654,205 were selected for testing. We noted one of the vendors selected for testing was deemed to be a sole source provider of reading teacher support packages by the School Board totaling $84,880. A sole source letter was obtained from the vendor, which outlined the uniqueness of the goods and services to be provided. However, it was determined that School Board did not appropriately follow the process for reviewing and documentation a sole source provider, per their federal procurement policy. This is a partially repeated finding from the prior fiscal year. For the five vendors selected for testing over suspension and debarment, the School Board asserts it checked the sam.gov website and none of the vendors were suspended or debarred. Our testing confirmed that these five vendors were not suspended or debarred. However, documentary evidence that a vendor was not suspended or debarred was not maintained in the School Board’s records. Cause: The School Board did not adhere to its established procurement policy for noncompetitive proposals to sole source vendors and control and internal review process was not properly followed. In addition, turnover in job functions without properly documented procedures resulted in the School Board not maintaining the records needed to evidence compliance with suspension and debarment requirements. Effect: Without proper internal controls over procurement to sole source or professional service vendors or suspension and debarment regulations, the School Board may enter into contracts with vendors where the price may not be fair or reasonable or disallowed if the vendor has been suspended or debarred from doing business with the federal government. Recommendations: The School Board should strengthen controls at the program administration level to ensure appropriate consideration to competitors are given and adequate documentation is obtained with respect to procurement of professional services and sole source products in accordance with the Uniform Guidance 2 CFR section 200.320(f). In addition, all vendors paid with federal resources should be checked for suspension or debarment. This documentation should be approved by the program director, as well as the purchasing director, and retained as evidence of the internal controls over procurement and suspension and debarment. View of Responsible Official: Management concurs with this finding, see corrective action plan dated March 27, 2024.

2023-003: Internal Controls over Allowable Costs CCDF Cluster: 93.575 - Child Care and Development Block Grant 93.596 - Child Care Mandatory and Matching Funds of the Child Care and Development Fund Passthrough Agency: Louisiana Department of Education Questioned Costs: Not applicable. Criteria: A non-federal entity is responsible for the establishment and maintenance of internal controls over a Federal award to provide reasonable assurance that an entity is managing an award in compliance with Federal statutes, regulations and the terms and conditions of the award. The School Board requires a memorandum of understanding (MOU) for each vendor as part of its internal control structure over compliance with federal program regulations. The Coordinated Funding Request Application and MOU is to be completed and approved by both the Child Care Provider Director and Director for Early Childhood or Superintendent. Universe/Population: A population of 25 state approved daycare centers/childcare facilities existed. Expenditures related to these vendors totaled $1,121,125 for the fiscal year ended June 30, 2023. Condition: Out of the 25 approved daycare/childcare facilities, we selected a sample of 13 to test the established controls over program compliance. This was a non-statistical sample. The School Board was unable to provide MOUs for 8 out of the 13 vendors selected in our testing. While expenditures are reviewed and approved for each request submitted and our testing did not reveal any non-compliance with program regulations, established policies and procedures were not followed by the School Board. Cause: The CCDF Program director retired in February 2024. Given the turnover in a key position, the new administration found it difficult to locate the MOU documentation requested. Effect: Without adhering to internal controls established over federal compliance, the School Board may be at risk for non-compliance with Federal statutes, regulations or terms and conditions of the Federal award. Recommendations: The School Board should remind personnel of the need to comply with established procedures and work to obtaining all missing MOUs from approved daycare/childcare providers. View of Responsible Official: Management concurs with this finding, see corrective action plan dated March 27, 2024.

2023-004: Internal Controls and Timeliness of Reporting CCDF Cluster: 93.575 - Child Care and Development Block Grant 93.596 - Child Care Mandatory and Matching Funds of the Child Care and Development Fund Passthrough Agency: Louisiana Department of Education Questioned Costs: Not applicable. Criteria: A non-federal entity is responsible for the establishment and maintenance of internal controls over a Federal award to provide reasonable assurance that an entity is managing an award in compliance with Federal statutes, regulations and the terms and conditions of the award. Periodic expense reports are due to the Louisiana Department of Education within 15 days of the closing of each quarter. Universe/Population: A total of 28 reports were required to be filed during the period under audit. These consisted of 21 quarterly reports and 7 final reports. Condition: Out of the 28 reports filed, we selected a sample of 9. This was a non-statistical sample. While reports were all filed, 4 out of the 9 were not filed within the 15-day deadline. The number of days late after the reporting deadline ranged between 18 and 125 days. Cause: Responsibility of filing the quarterly reports historically rested with the grant accountant. Turnover in this position during the fiscal year did not allow for a smooth transition of job duties and adherence to established procedures. Effect: The School Board was not in compliance with established timelines for periodic expense reports. Recommendations: The School Board should remind personnel of the need to comply with established procedures and additional internal controls may be necessary to ensure reports are to be filed timely in accordance with federal guidelines. View of Responsible Official: Management concurs with this finding, see corrective action plan dated March 27, 2024.

Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.320 requires, among other things, that specific criteria be met for the procurement of noncompetitive proposals. Procurement of noncompetitive proposals is procurement through solicitation of a proposal from only one source, also known as a sole source vendor. This method may only be used when one or more of the following circumstances apply: ? The item is available only from a single source. ? The purchase is in response to a public emergency that will not permit a delay resulting from the competitive process. ? The purchase is expressly authorized by awarding or pass-through agency in response to a written request from the non-Federal entity or after solicitation of a number of sources, competition is determined inadequate. Additionally, The Uniform Guidance federal regulations per 2 CFR section 200.320 also requires, among other things, that specific criteria be met for the procurement of professional services. Procurement of professional services are required to follow the following procedures: ? The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. ? Formal procurement methods require public advertising unless a non-competitive procurement can be used. To ensure compliance with these requirements, justification of the use of noncompetitive proposals and research on the availability from multiple sources must be documented. Documentation of authorization must be retained, and any initial solicitations from multiple sources which are concluded to be inadequate, and such reasoning must be documented. Universe/Population: The total population was all vendors of the Special Education Cluster whose transactions for the year ended June 30, 2022, exceeded the micro-purchase threshold of $10,000. Payroll and benefit-related transactions were excluded from the population. Based on these requirements, the population consisted of twenty-five vendors totaling $1,179,048. Conditions: Four vendors with expenditures totaling $451,259 were selected for testing. We noted one of the vendor selected for testing was deemed to be a sole source provider of hardware and software equipment by the School Board totaling $45,000. A sole source letter was obtained from the vendor, which outlined the uniqueness of the goods and services to be provided. However, it was determined that School Board did not appropriately follow the process for reviewing a sole source provider, per their federal procurement policy. Additionally, the form used by the School Board to document the justification of a sole source vendor was deemed insufficient for the following reasons: (1) an adequate analysis or comparison of like products was not properly completed and (2) the request form was not approved (i.e. no signature) by the purchasing department. For the remaining three vendors selected, we noted that payments were made for professional service in excess of procurement thresholds under Uniform Guidance which were not properly procured. Cause: The School Board did not adhere to its established procurement policy for professional services or noncompetitive proposals to sole source vendors and control and internal review process was not properly followed. Effect: Without proper internal controls over procurement to sole source or professional service vendors, the School Board may enter into contracts with vendors where the price may not be fair or reasonable. Recommendations: The School Board should strengthen controls at the program administration level to ensure appropriate consideration to competitors are given and adequate documentation is obtained with respect to procurement of professional services and sole source products in accordance with the Uniform Guidance 2 CFR section 200.320(f). This documentation should be approved by the program director, as well as the purchasing director, and retained as evidence of the internal controls over procurement.

Criteria: The Uniform Guidance Subpart F section 200.510 requires the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to include an accurate reporting of federal awards expended based on the terms and conditions of the grants. For the SEFA to be prepared accurately and properly report the amounts expended for federal awards, a system of controls should be in existence that includes the timely preparation and review of the amounts reported on the SEFA. Conditions: The SEFA prepared by the School Board?s personnel (1) did not include all federal award programs, (2) did not properly present new federal award programs within the correct group or cluster of programs based on the Assistance Listing numbers, and (3) did not reconcile to the federal revenue reflected in the general ledger. Cause: A formal review and reconciliation, by an individual not involved in the determination of the federal awards reported was not performed to determine if the SEFA was complete and prepared in accordance with the Uniform Guidance. Effect: The SEFA provided did not contain the correct amounts of federal expenditures and/or correct presentation established by the terms of the grant awards, which is the basis used to determine the major federal programs to be audited in the fiscal year. Recommendations: The School Board should strengthen its controls including its review, reconciliation, and approval processes over the information and balances accumulated and reported on the SEFA. This will help ensure the expenditures reported are an accurate representation of federal costs, reconcilable to federal revenue reflected in the general ledger, and include all federal grant award programs.

Compliance and Internal Control over Procurement, Suspension and Debarment Assistance Listing #10.558 Child and Adult Care Food Program (CACFP) Questioned Costs: N/A Criteria: The Uniform Guidance federal regulations per 2 CFR Part 180 requires, among other things, that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) collecting a signed certification from the entity, or (3) adding a clause of condition to the covered transaction with that entity. A ?covered transaction? includes contracts for goods and services awarded under a non-procurement transaction (e.g. grant of cooperative agreement) that is expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. The non-federal entity must choose a method and document the consideration of whether the entity was not suspended, debarred, or otherwise excluded so that this determination can be verified. Universe/Population: The total population was considered to be all vendors of the CACFP whose transactions for the year ended June 30, 2021 exceeded the micro-purchase threshold of $10,000. Based on these requirements, the population consistent of 1 vendor (the only vendor) totaling expenditures of $1,165,869 paid to the vendor for goods and services provided under the program. Conditions: In testing compliance and internal controls with respect to the Uniform Guidance 2 CFR section 180.300, the School Board did not properly verify that the vendor was not excluded or disqualified before contracting with the vendor. Additionally, no such clause or representation was included in the signed contract certifying that the vendor was not suspended, debarred, or otherwise excluded from participating in the covered transaction. Cause: The School Board did not adhere to its established procurement policy for federal requirements regarding procurement, suspension, and debarment of vendors under a contract award or a purchase made with federal funds. Additionally, the established control and review process was not properly followed to ensure documentation was adequately maintained and approved in order to support the determination of vendor eligibility. Effect: Without proper internal controls over procurement to eligible vendors, the School Board may potentially enter into contracts with excluded or disqualified vendors. Recommendations: The School Board should strengthen its controls over the procedures for verifying that an entity, with which it plans to enter into a covered transaction, is not debarred, suspended, or otherwise excluded.

Documentation of Internal Controls over Allowable Costs CFDA #84.425D Elementary and Secondary School Emergency Relief Fund (ESSERF), under the CARES Act Questioned Costs: N/A Criteria: The Uniform Guidance (2 CFR section 200.303) requires that non-Federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. More specifically, internal controls over expenditures should be in place to ensure all funds charged to the Federal award and requested for reimbursement are supported with appropriate documentation, which should be reviewed/approved by a member of management that is not involved with the initiation of the expenditures. Furthermore, the Uniform Guidance requires expenditures to be adequately documented in order to be considered allowable costs. Universe/Sample: The total population was all expenditure invoices of the ESSERF (CARES Act) program during the fiscal period of July 1, 2019 through June 30, 2020. Based on these requirements, the population consisted of 79 invoices totaling $1,614,927. Based on sampling guidance for audits performed under the Uniform Guidance, a sample of 40 invoices was selected for testing. Conditions: Of the 40 disbursements selected for testing, 9 invoices did not have documentation evidencing that the disbursement was reviewed/approved by the appropriate level of management. This was not a statistically valid sample. Cause: The School Board did properly follow their established internal control procedures over the major program?s disbursement process to ensure costs allocated to the grant and charged for federal reimbursement were reviewed by the appropriate personnel. Effect: While no evidence indicated that these were not allowable or allocable to the grant, the internal control deficiency described above increased the risk that the School Board will violate federal compliance requirements pertaining to the allowable activities and costs per the grant agreement. Recommendations: The School Board should remind employees about their responsibility to adhere to the established internal controls, specifically those that help ensure expenditures are initiated and approved by the appropriate personnel. Adhering to these internal control procedures will provide reasonable assurance that Federal awards are expended only for allowable activities and that the costs charged to the Federal award are allowable and in accordance with the applicable costs principles.

Questioned Costs: N/A Criteria: The Uniform Guidance Subpart F section 200.510 require the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to include an accurate reporting of federal awards expended based on the terms and conditions of the grants. In order for the SEFA to be prepared accurately and properly report the amounts expended for federal awards, a system of controls should be in existence that includes the timely preparation and review of the amounts reported on the SEFA. Condition:The SEFA prepared by the School Board?s personnel did not properly report the correct amount of the federal awards expended for the Head Start grant. The amount of expenditures reported included those also funded by state funding. Cause:The School Board inadvertently included all expenditures in the Head Start fund versus removing the state funded portion when preparing the SEFA. A formal review by an individual not involved in the determination of the federal awards reported was not performed. Effect:The SEFA provided to us did not contain the correct amounts of federal expenditures which is the basis used to determine the major federal programs to be audited in a fiscal year. Recommendation:The School Board should strengthen its controls including its review and approval processes over the information and balances that is accumulated and reported on the SEFA to make sure the expenditures reported are an accurate representation of federal costs.