Calcasieu Parish School Board

2025-002) PREPARATION OF SCHEDULE OF EXPENDITURES AND FEDERAL AWARDS Assistance Listing Numbers Name of Federal Program or Cluster 97.036 Disaster Grants-Public Assistance (Presidentially Declared Disasters) Criteria: Uniform Guidance 2 CFR §200.510(b) requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) that accurately reports federal awards expended during the fiscal year in accordance with the terms and conditions of the grant agreements, including proper identification of federal programs and amounts expended. To ensure compliance, management should maintain effective internal controls over the identification, accumulation, preparation, review, and approval of SEFA information. Effect: Because the SEFA initially provided for audit was incomplete and inaccurate, additional audit procedures and revisions were required to identify the correct federal expenditures and programs. These deficiencies delayed the completion of the Single Audit and increased the risk that:  Federal expenditures could be misstated,  Major programs could be incorrectly identified or omitted, and  The Single Audit reporting package filed could be incomplete or inaccurate. Recommendation: The School Board should further strengthen its internal controls over SEFA preparation by implementing documented procedures for:  Identifying federal awards and determining when expenditures should be reported on the SEFA,  Reconciling SEFA amounts to underlying accounting records and grant documentation,  Reviewing grant agreements and FEMA reimbursement terms for proper expenditure recognition, and  Performing an independent supervisory review and approval of the SEFA prior to submission for audit. View of Responsible Official: Management is creating methods to more effectively determine the amounts to include in the schedule. We more fully understand the unique accounting requirements for FEMA reporting and will apply this to ensure more accurate reporting in the Schedule. Condition: The initial Schedule of Expenditures of Federal Awards (SEFA) prepared by the School Board was not accurate or complete. The total SEFA expenditures originally reported by management were $163,714,831, while the final SEFA total, as determined during the audit and adjusted in accordance with Uniform Guidance and applicable grant requirements, was $97,482,542, resulting in a net decrease of $66,232,289. These revisions were identified and recorded during the audit process in order for the SEFA to fairly present federal awards expended. . This finding is repeated from the prior year. See the Summary Schedule of Prior Year Findings and Questioned Cost item 2024-003. Questioned Cost: None Universe/ Population: None Sample size: None Cause: Grant agreements and FEMA disaster-related reimbursement documentation were not sufficiently reviewed or interpreted to determine the appropriate amounts reportable as federal expenditures for SEFA purposes. In addition, management’s internal controls over identifying, accumulating, and reviewing disaster-related federal expenditures were not designed or operating effectively to ensure SEFA completeness and accuracy in accordance with 2 CFR Part 200, Appendix XI (Compliance Supplement) requirements.

Assistance Listing Numbers Name of Federal Program or Cluster Special Education Cluster: 84.027A Grants to States (Part B) 84.173A Preschool Grants Criteria: Uniform Guidance establishes procurement standards and contractor eligibility requirements applicable to federally funded procurements. Specifically: • 2 CFR §200.318(a) requires non-Federal entities to maintain oversight and to document that procurements are conducted in compliance with federal statutes, regulations, and the terms and conditions of the federal award. • 2 CFR §§200.319–200.320 require entities to document compliance with applicable competitive or noncompetitive procurement methods, including justification and approval of the procurement method used. • 2 CFR §200.320(c) permits noncompetitive (sole-source) procurements only under specific circumstances and requires documentation supporting the sole-source procurement determination. • 2 CFR §200.327 requires contracts funded with federal awards to include applicable contract provisions described in Appendix II to Part 200. • 2 CFR §200.214 prohibits the award of contracts to suspended or debarred parties and requires verification of contractor eligibility prior to award. • OMB Compliance Supplement, Part 3 – Procurement and Suspension and Debarment. Condition: Contracts did not contain required uniform guidance contract provisions and required vendor eligibility and procurement documentation was not retained. From a population of 32 federally funded vendor contracts, a sample of 6 contracts was selected for testing. Based on audit testing, the following deficiencies were noted: 1. All 6 contracts tested did not include all required federal contract provisions. 2. Procurement files did not include documentation verifying that contractors were not suspended or debarred; however, none of the contractors tested were identified as suspended or debarred. 3. Documentation supporting compliance with Uniform Guidance §§200.318–200.320 was not consistently maintained. 4. One contract contained a sole-source justification dated approximately seven years prior; however, the file did not include documentation meeting the requirements of 2 CFR §200.320(c) for the period under audit. Questioned Cost: None Universe/ Population: 32 Vendor contracts Sample size: 6 Vendor contracts Cause: Procurement controls and documentation requirements were not adequately designed or consistently applied to ensure compliance with Uniform Guidance procurement standards. Effect: The lack of required procurement documentation increases the risk of noncompliance with Uniform Guidance and limits the School Board’s ability to demonstrate compliance to oversight agencies. Recommendation: The School Board should update procurement policies, templates, and review procedures to ensure compliance with Uniform Guidance §§200.318–200.327, including maintaining current sole-source justifications and suspension/debarment documentation. View of Responsible Official: Management will include the required contract provisions per the Uniform Guidance. Verification of proof of non-debarment will be required to be documented and maintained with the contract. Any sole source justification will be updated annually and documentation maintained.

PREPARATION OF SCHEDULE OF EXPENDITURES AND FEDERAL AWARDS QUESTIONED COSTS: N/A Criteria: The Uniform Guidance Subpart F section 200.510 requires the preparation of the Schedule of Expenditures of Federal Awards (SEFA) that includes an accurate reporting of federal awards expended based on the terms and conditions of the grants along with the amount of funds disbursed to sub-recipients. 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 identification of federal expenditures, timely and accurate preparation and review of the amounts reported on the SEFA. Condition: The initial SEFA prepared by the School Board’s did not accurately include or identify all the federal award expenditures. This finding is repeated from the prior year. See the Summary Schedule of Prior Year Findings and Questioned Cost item 2022-003. Universe/ Population: None Sample size: None Cause: The grant awards or agreements were not properly interpreted or reviewed to identify or determine the proper amount to be reported as expenditures or SEFA. The 2 CFR Part 200, Appendix XI, Compliance Supplement publishes and distributed by the President of the United States’ Office of Management and Budget includes requirements for SEFA reporting that were not complied with. Effect: The SEFA provided to us for audit did not contain all the federal programs or the correct amounts of federal expenditures based on the terms of the grant awards and requirements to reporting on some of the federal programs reported. Inaccuracies or excluding information on the SEFA causes delays in completing the single audit and risks filing a SEFA that is incomplete or inaccurate. In addition, auditors may not identify and test the correct major federal programs in accordance with the Uniform Guidance. Recommendation: The School Board should strengthen its controls including its review and approval processes over the identification of federal programs, and the information and balances that are accumulated and reported on the SEFA to make sure the expenditures reported are an accurate representation of federal expenditures. View of Responsible Official: Management agrees with finding. Disaster Grants through FEMA are managed by rules and processes that are not easily accounted for in traditional accounting systems. Procedures will be strengthened to fully and accurately identify all federal program expenditures and record in the appropriate accounting funds.

Late Completion and Filing of Single Audit Questioned Costs: N/A Criteria: The Office of Management and Budget (OMB) designated the Census Bureau as the National Clearinghouse (or Federal Audit Clearinghouse FAC) for the receipt of Single Audit Reports from state and local governments. In this capacity, the Census Bureau serves as the central collection point and repository for audit reports prepared and submitted under provisions of the Single Audit Act of 1984 (amended in 1996), and Uniform Guidance section 200.512. States, local governments, Indian Tribes or Tribal Organizations, institutions of higher education (IHEs), and nonprofit organizations that annually expend $750,000 or more in federal awards must perform a Single Audit and complete Form SFSAC for every fiscal period during which they meet the reporting dollar threshold. The central collection point for single audit reports is the Federal Audit Clearing House Internet Data Entry System (IDES) website. Without any waivers, the report is due no later than nine months after an entity’s fiscal year end. Condition(s): The School Board did not file its single audit report with the Federal Audit Clearing House in the timeline established by regulation which is nine months after the year end of June 30, 2023. The School Board did request and received an approval of an extension to file the audit report with the Louisiana Legislative Auditor within three months of the year end to file by March 31, 2024; however, the School Board did not receive an extension to file within nine months of its year-end from the federal government. This finding is repeated from the prior year. See the Summary Schedule of Prior Year Findings and Questioned Cost item 2022-004. Universe/ Population: None Sample size: None Cause: The completion of the School Board’s audit was delayed due to the lack of proper procedures and controls to identify and record expenditures reportable on the SEFA associated with the FEMA disaster grant. The School Boards data and supporting schedules were not maintained in a manner to identify the expenditures subject to being reported on the SEFA for the FEMA disaster grant. Management was ultimately able to provide the necessary support to complete the audit. Effect: The lack of timely filing may result in delays or denial of federal grant assistance. Recommendation: The School Board should implement procedures to ensure all future filings are completed timely. View of Responsible Official: Management agrees with the finding. Management will implement procedures referenced in Finding 2023-001 and 2023-003 that will help facilitate gathering information necessary for proper recording at year end to avoid this issue in the future and allow timely completion of the audit.

2022-003) Preparation of Schedule of Expenditures and Federal Awards Questioned Costs: N/A Assistance Listing Numbers Name of Federal Program or Cluster 97.036 Disaster Grants-Public Assistance (Presidentially Declared Disasters) 84.425D ?Achieve? ? COVID-19 - ESSER II Formula 32.009 Emergency Connectivity Fund Criteria: The Uniform Guidance Subpart F section 200.510 requires the preparation of the Schedule of Expenditures of Federal Awards (SEFA) that includes an accurate reporting of federal awards expended based on the terms and conditions of the grants along with the amount of funds disbursed to sub-recipients. 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 identification of federal expenditures, timely and accurate preparation and review of the amounts reported on the SEFA. Condition: The initial SEFA prepared by the School Bord?s did not accurately include or identify all the federal program expenditures. Universe/ Population: None Sample size: None Cause: The grant awards or agreements were not properly interpreted or reviewed to identify or determine the proper amount to be reported as expenditures or SEFA. Effect: The SEFA provided to us for audit did not contain all the federal programs or the correct amounts of federal expenditures based on the terms of the grant awards and requirements to reporting on some of the federal programs reported. Inaccuracies or excluding information on the SEFA causes delays in completing the single audit and risks filing a SEFA that is incomplete or inaccurate. Recommendation: The School Board should strengthen its controls including its review and approval processes over the identification of federal programs, and the information and balances that are accumulated and reported on the SEFA to make sure the expenditures reported are an accurate representation of federal expenditures. View of Responsible Official: Management agrees with finding. Disaster Grants through FEMA are managed by rules and processes that are not easily accounted for in traditional accounting systems. ESSER II and III grants relatively new and designed to be implemented over multiple years leading to shifting of expenditures from one grant to another depending on spending priorities. Procedures will be strengthened to fully and accurately identify all federal program expenditures and record in the appropriate accounting funds.

2022-004) Late Completion and Filing of Single Audit Questioned Costs: N/A Assistance Listing Numbers Name of Federal Program or Cluster 97.036 Disaster Grants-Public Assistance (Presidentially Declared Disasters) Criteria: The Office of Management and Budget (OMB) designated the Census Bureau as the National Clearinghouse (or Federal Audit Clearinghouse FAC) for the receipt of Single Audit Reports from state and local governments. In this capacity, the Census Bureau serves as the central collection point and repository for audit reports prepared and submitted under provisions of the Single Audit Act of 1984 (amended in 1996), and Uniform Guidance section 200.512. States, local governments, Indian Tribes or Tribal Organizations, institutions of higher education (IHEs), and nonprofit organizations that annually expend $750,000 or more in federal awards must perform a Single Audit and complete Form SFSAC for every fiscal period during which they meet the reporting dollar threshold. The central collection point for single audit reports is the Federal Audit Clearing House Internet Data Entry System (IDES) website. Without any waivers, the report is due no later than nine months after an entity?s year end. Condition(s): The School Board did not file its single audit report with the Federal Audit Clearing House in the timeline established by regulation which is nine months after the year end of June 30, 2022. The School Board did request and received approval of an extension to file the audit report with the Louisiana Legislative Auditor within six months of the year end; however, the School Board did not receive an extension to file within nine months of its yearend from the federal government. Universe/ Population: None Sample size: None Cause: The completion of the School Board?s audit was delayed due to the lack of proper procedures and controls to identify and record expenditures reportable on the SEFA associated with the FEMA disaster grant. The School Boards data and supporting schedules were not maintained in a manner to identify the expenditures subject to being reported on the SEFA for the FEMA disaster grant. Management was ultimately able to provide the necessary support to complete the audit. Effect: The lack of timely filing may result in delays or denial of federal grant assistance.Recommendation: The School Board should implement procedures to ensure all future filings are completed timely. View of Responsible Official: Management agrees with the finding. Management will implement procedures referenced in Finding 2022-001 and 2022-003 that will help facilitate gathering information necessary for proper recording at year end to avoid this issue in the future and allow timely completion of the audit.

2020 ? 001) Graduation Rate Cohort Documentation 84.010 Title I Basic Grant #28-20-T1-10 Questioned Costs: None. Criteria: The School Board must report graduation rate data for all public high schools at the school level using the 4-year adjusted cohort rate under 34 CFR section 200.19(b)(1)(i)-(iv)). Only students who earn a regular high school diploma may be counted as a graduate for purposes of calculating the 4-year adjusted cohort graduation rate. To remove a student from the cohort, a school must confirm, in writing, that the student transferred out, emigrated to another country, or is deceased. The Calcasieu Parish School Board is responsible for assigning exit codes to any student who leaves the School Board. Only specific exit codes are deemed legitimate reasons for leaving the School Board and will cause the leaver to not be included in the cohort?s graduation index calculations. These codes relate to death, transfers out of the state or country, transfers to non-public schools, transfers to home study/in-school private schooling, and transfers to Early College Admissions Programs. Specific documentation must be maintained in order for students to be considered legitimate leavers from the cohort. Documentation must be clearly dated before October 1st following the student?s exit from the Louisiana Student Information System. The School Board is also responsible for developing a system of internal controls to ensure the proper documentation is retained for all leavers of the cohort. Universe/ Population Size: The sample of cohort removals was selected from a universe that includes all students that left the School Board due to transferring to a diploma awarding school or program, death, or emigration to another country. Based on these requirements, the total universe is 845 students who are considered leavers of the cohort. This is also considered the population size. Sample Size: Based on sampling guidance for audits performed under the Uniform Guidance, a non-statistical sample of 25 leavers was selected for testing. Condition(s): In testing internal controls and compliance with respect to 34 CFR ?200.19(b), 3 of 25 leavers had exceptions to the required documentation set forth by the Louisiana Administrative Code Title 28, Part LXXXIII, Chapter 6, ?611. This rate of exception indicates that the School Board does not have adequate internal control procedures in place to ensure that all documentation is maintained contemporaneously with the removal of the student to support the removal from a cohort. Cause: The School Board has relied on the individual schools to acquire and retain all documentation related to the removal of students. At the program level, a centralized control and periodic review did not exist to ensure documentation is adequately maintained contemporaneously with the removal of the students from the cohort. Effect: Without proper internal controls over the graduation rate cohort reporting process, documentation may not be properly retained, and therefore the School Board may be noncompliant with the requirements of the Title I program. Recommendation: The School Board should establish procedures at the School and program administration levels to ensure appropriate documentation is obtained related to removal of students from a cohort in accordance with Louisiana Administrative Code Title 28, Part LXXXIII, Chapter 6, ?611. Repeat Finding: No. View of Responsible Official: School Board and school administrators have received the Louisiana standards for accountability, the official state steps for determining a cohort for graduation and documentation required for a graduation index. The district will provide the following exit code interventions which will promote compliance for future years: Exit Code Interventions ? Initial training outlining state-approved exit codes and documentation required for each exit code. o Attendees: Counselors, curriculum contacts, principals, and graduation coaches from all schools. ? Follow-up trainings each year outlining state-approved exit code updates and documentation required for each exit code. o Attendees: Counselors, curriculum contacts, principals, and graduation coaches from all ? Over Age student review to identify students? type of exit. This is a total of three meetings a year with schools bringing documentation when students exit. o Attendees: Counselors, curriculum contacts, principals, and graduation coaches from Washington Marion, Barbe, and LaGrange ? Training on how to conduct state-required Data Certification for graduation cohort data, exit codes, and documents for each exit code. o Attendees: Counselors, curriculum contacts, principals, and graduation coaches from all schools ? Plans to train schools (January or February 2022) on how to pull their cohort data and exit codes from JCampus. Schools will follow up on this training by checking documentation required for each exit code.

2020 ? 002) Allowable Costs ? Reserve Funds 84.010 Title I Basic Grant #28-20-T1-10 93.600 Head Start Program #06CH10115-05-00 Questioned Costs: Title I Program - $104,000 Head Start Program - $36,700 Criteria: Under the Uniform Guidance (the Guidance), reserve funds are allowed with respect to billed central service costs that are accounted for through internal service funds. A working capital reserve of up to 60 calendar days for normal operating purposes is considered reasonable. In addition, with respect to allowable fringe benefit costs, specifically, post-retirement health care costs are allowable if they are funded for that year within six months after the end of that year. Costs funded after the six-month period are allowable in the year funded (when claims are paid). The School System is self-insured for health care claims of both active and retired employees, and all programs and activities (including federal grant programs) pay premiums into a separate internal service fund. Universe/ Population Size: Not applicable Sample Size: Not applicable Condition(s): The School System maintains a separate internal service fund to account for its self-insured health plan for retirees and active employees which bills premium charges to other funds to cover central service costs. Our analysis of net position (reserves) of the health insurance fund identified that the reserves now exceed the maximum amount that the Guidance considers reasonable. Cause: The School System premium payments into the internal service fund have exceed the benefit payments over time causing a fund balance at June 30, 2020 of $22,362,374 in reserve that exceeds the 60-day level allowed by Uniform Guidance. Effect: The level of reserve funds is considered to be in excess of the allowed funding reserve in accordance with Uniform Guidance. Recommendation: The School System should develop a plan to come into compliance with the funding reserve requirements of the Uniform Guidance. Repeat Finding: No View of Responsible Official: The fund balance grew in past years from a variety of factors. For many years CPSB had to set premiums to fund expenditures to a 110% level of anticipated expenditures as a requirement of maintaining excess loss insurance coverage. If expenditures were less than the 110% level, a surplus occurred. We have since dropped excess loss coverage and created a fund balance reserve to guard against any large losses that would have been covered through the excess coverage. This allows premiums to be set to fund expenditures at a 100% level. To reduce fund balance, we have utilized a one-month premium holiday in the past for employees and charges to funds which has the effect of reducing reserves by about $5 million. We will be recommending this action again to the governing board in fiscal year 2022 in an effort to reduce fund balance reserves. Premiums have been held without increases for 4 years. Administration continues to monitor fund balance and will take steps annually to reduce the fund balance level to recommended amounts.

Criteria: The Uniform Guidance federal regulations were fully effective as of December 26, 2017 and therefore, the school board, as a recipient of federal awards was required to implement and comply with the Uniform Guidance for the year ended June 30, 2019. The regulations (200.320) require, among other things, that procurement for non-competitive purchases apply only when the item is available only from a single source. The regulations also require procurement purchases of goods and services in an amount between $10,000 and $250,000 follow the small purchase procedures by obtaining an adequate number of prices/quotes. Additionally, the Uniform Guidance outlines other specific requirements for purchases based on purchase amount thresholds. Condition(s): While testing compliance with the federal procurement regulations, we selected for testing all of the eight vendors with expenditures greater than $10,000 and inquired or reviewed the documentation to support the procurement process. Four of the vendors tested were for noncompetitive purchases, one was for professional services and the remaining three for materials, supplies, and/or equipment. The documentation to support the four noncompetitive purchases totaling $150,535 did not adequately demonstrate the vendor selected was the only available source for the items or services purchased. The purchase of professional services in the amount of $43,475 did not adhere to the small purchase procedures requirements, since an adequate number of quotes was not obtained. Additionally, we obtained the School Board?s adopted Procurement Policy to determine the policies included the requirements of the Uniform Guidance. We found the thresholds for purchase requirements in the School Board?s Procurement Policy had not been updated to reflect the revised thresholds for various purchase levels according to the Uniform Guidance (as amended by Memorandum M-18-18). These thresholds were less than the revised levels. Cause: Personnel administering the grants and those in the School Board purchasing department did not execute and enforce the revised purchasing policy containing the amended Uniform Guidance requirements. Effect: The School Board?s special education program may be noncompliant with the procurement requirements within the Uniform Guidance with respect to these transactions. Recommendation: We recommend for the School Board to better document and research noncompetitive purchases, communicate and enforce the need to obtain price quotes for small purchases, including professional services, and update their internal procurement policies to reflect current federal regulations. Repeat Finding: No

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