EAST FELICIANA PARISH SCHOOL BOARD

2020 ? 002) Preparation of Schedule of Expenditure of Federal Awards (SEFA) Timely Filing of Federal Data Collection Form Questioned Costs: N/A Criteria: The Uniform Guidance Subpart F section 200.510 and section 200.512, respectively, 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 and submission of data collection form within the earlier of 30 days after receipt of the auditor?s report or nine months after the end of the audit period. In addition, the SEFA should identify amounts passed through to subrecipients along with proper identification of the catalog of federal domestic assistance (CFDA) number for each grant. In order for the SEFA to be prepared accurately, properly report the amounts expended for federal awards, as well as, ensuring timely filing of the data collection form, a system of controls should be in existence that includes the review of the amounts reported on the SEFA, documentation of the consideration of whether federal funding meets the definition of a federal award, and establishment of procedures to ensure timely filing of the data collection form. Condition: The SEFA prepared by the School Board?s personnel included as federal awards, expended amounts related to Teacher Incentive Federal (TIF) grant funding for which the School Board was deemed a vendor and not a sub-recipient of the federal award. Also, the SEFA included expenditures for the Temporary Assistance for Needy Families (TANF) grant when the School Board received notice from the Louisiana Department of Education during the year that the TANF grant was no longer a federal grant. The SEFA prepared by the School Board?s personnel did not include amounts passed through to sub-recipients. Slaughter Community Charter School is a sub-recipient of the School Board that receives Title I funding. The funding was not identified on the SEFA. The SEFA prepared by the School Board?s personnel contained incorrect CFDA numbers for federal programs. The Title I School Improvement grant is CFDA 84.010, but the prepared SEFA used CFDA 84.388. In addition, the non-cash commodities is CFDA 10.555. The prepared SEFA used CFDA 10.565. The federal data collection form was not filed within the established timeline under Uniform Guidance which is within 30 days of the financial report release date.Cause: The School Board lacks processes and procedures necessary to ensure that expenditures associated with federal grants only are itemized on the SEFA. In addition, the reimbursements received for both the TIF and the TANF grants were recorded in the general ledger to an account number designated as federal revenues. Processes were lacking to ensure grant personnel communicate changes in funding from federal to state or other to accounting personnel and follow through to make sure the proper changes and adjustments are recorded in the general ledger. The SEFA was also incorrectly prepared using the wrong CFDA numbers in addition to not correctly identifying sub-recipient pass through funds. With respect to the timely filing of the federal data collection form, the School Board personnel did not make sure the data collection form was completed and submitted within the due date. Effect: The SEFA provided to us did not contain the correct amounts of federal awards, which is the basis used to determine the major federal programs to be audited in a fiscal year. Errors such as the ones identified on the SEFA could result in additional audit work to achieve the necessary audit coverage required by Uniform Guidance or incorrect information regarding federal grants to be reported. Additionally, overlooking the timely filing of the data collection form results in non-compliance with the Uniform Guidance, not being considered a low risk auditee, and results in additional audit coverage requirements and additional time necessary to complete the Single Audit for the next two years. Recommendation: The School Board should strengthen its controls including its review 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 including proper recording of revenue in an account as non-federal, as applicable. The School Board should implement a procedure to ensure the timing of the federal data collection form is done in accordance with regulations. View of Responsible Official: The District was unaware that the Temporary Assistance for Needy Families was no longer a federal program. This program has historically been reported as federally funded and reported as such on the District?s SEFA. However, we are now aware of the Louisiana Department of Education?s memorandum declaring the program non-federal for 2020. We will review the status of this program in 2021 for reporting purposes. The federal data collection form was prepared and certified by the District in December 2019 for the fiscal year ended June 30, 2019. However, we understand that the auditor certification was not timely completed resulting in a delay in submission. We consider this matter isolated and will be resolved as 2020 will be filed timely.

2020-002 - Preparation of Schedule of Expenditure of Federal Awards (SEFA) timely filing of Federal Data Collection Form The District was unaware that the Temporary Assistance for Needy Families was no longer a federal program. This program has historically been reported as federally funded and reported as such on the District's SEFA. However, we are now aware of the Louisiana Department of Education's memorandum declaring the program non-federal for 2020. We will review the status of this program in 2021 for reporting purposes. The federal data collection form was prepared and certified by the District in December 2019 for the fiscal year ended June 30, 2019. However, we understand that the auditor certification was not timely completed resulting in a delay in submission. We consider this matter isolated and will be resolved as 2020 will be filed timely. The District has assigned Mr. Tommy LeJeune with Faulk & Winkler, LLC to address this matter which ?will be corrected for the 2021 fiscal year end audit by December 31, 2021.

2019-002

2020 ? 003) Special Test and Provisions Questioned costs: None 84.010A Title I Annual Report Card, High School Graduation Rate Graduation Rate Cohort Documentation Criteria: The School Board is required to 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 East Feliciana 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 37 students who are considered leavers of the cohort. This is also considered the population size. Sample: Based on sampling guidance for audits performed under the Uniform Guidance, a non-statistical sample of 4 leavers was selected for testing. Condition(s): In testing internal controls and compliance with respect to 34 CFR ?200.19(b), 1 of 4 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: The District will implement procedures to enhance steps taken for determining a cohort graduation and documents required for a graduation index. Such procedures will be enhanced at the school level with collaboration from the central office.

2020-003 - Special Tests and Provisions -Title I The District will implement procedures to enhance steps taken for determining a cohort graduation and documents required. for a graduation index. Such procedures will be enhanced at the school level with collaboration from the central office. This matter has been assigned to Ms. Susan Smith to be resolved immediately but no later than June 30, 2021.

2020 ? 004) Level of Effort Questioned costs: None 84.010A Title I Maintenance of Effort Report Preparation and Filing Criteria: Section 8521 of the Elementary and Secondary Education Act (ESSA) provides that in order continue to receive funding for ESEA programs, the school board is required to report its Annual Financial Report (AFR) information to the state. To be in compliance with the maintenance of effort requirement, the School Board?s combined fiscal effort for student or the aggregate expenditures from state and local funds for free public education for the preceding year cannot be less than ninety percent of the combined fiscal effort or aggregate expenditures for the second preceding year. Condition(s): The information reported on the maintenance of effort form to the state Department of Education (DOE) included accounting information and balances that did not agree with the annual financial report or the audited financial statement balances. Due to the balances reported being in error, the form submitted reported that Maintenance of Effort calculation was less than ninety percent of the aggregate expenditures of the School Board when compared to the previous fiscal year; however, the form reported that the fiscal effort per student was met; although the per student effort was achieved with the incorrect balances. As an audit procedure, a recalculation of the form was performed with the correct data and both the aggregate expenditures and the per student effort met the requirements of being within ninety percent of the previous fiscal year. Cause: The School Board is not updating previously entered information from its AFR to the financial statements when reporting to the Louisiana Department of Education. Effect: Without proper internal controls and review of information, there is the possibility that the School Board may not be in compliance with its Maintenance of Effort requirement. The information submitted to the grantor must be complete and accurate to avoid the possibility of delays or denial of future grant funding. Recommendation: The School Board should establish procedures to review its AFR information and update accordingly once the financial statements are issued each year. Amended forms should be submitted when the original forms filed contain errors. Repeat Finding: No. View of Responsible Official: The District will review this matter with proper representatives with the Louisiana Department of Education (LDOE). Since the annual financial report is submitted in September and the audit is issued in December, any adjustments to financial records suggested by auditors is not reflected in the annual financial data previously submitted to LDOE. We will review revision procedures with LDOE officials.

2020-4 - Level of Effort --- Title l The District will review this matter with proper representatives with the Louisiana Department of Education (LDOE). Since the annual financial report is submitted in September and the audit is issued in December, any adjustments to financial records suggested by auditors is not reflected in the annual financial data previously submitted to LDOE. We will review revision procedures with LDOE officials. This matter has been assigned to Ms. Jessica Rogillio for resolution by March 31, 2021.

2019-002) Preparation of Schedule of Expenditure and Federal Awards (SEFA) and Timely Filing of Federal Data Collection Form Questioned Costs: N/A Criteria: The Uniform Guidance Subpart F section 200.510 and section 200.512, respectively, 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 and submission of data collection form within the earlier of 30 days after receipt of the auditor?s report or nine months after the end of the audit period. ln order for the SEFA to be prepared accurately, properly report the amounts expended for federal awards, as well as, ensuring timely filing of the data collection form a system of controls should be in existence that includes the review of the amounts reported on the SEFA documentation of the consideration of whether federal funding meets the definition of a federal award, and establishment of procedures to ensure timely filing of the data collection form. Condition: The SEFA prepared by the School Board's personnel included as federal awards, expended amounts related to Teacher Incentive Federal grant funding for which the School Board was deemed a vendor and not a sub-recipient of the federal award. In addition, the federal data collection form was not filed within the established timeline under Uniform Guidance. Cause: The School Board received Teacher Incentive Fund federal funding for services under a memorandum of understanding (MOU) with a California not-for-profit organization, the National Institute for Excellence in Teaching (NIET). The School Board has previously received Teacher Incentive grant funds through the state of Louisiana as a sub recipient in previous years. The School Board incorrectly assumed this funding was a continuation of this previous grant award and did not determine whether a vendor or sub-recipient relationship existed. With respect to the timing filing of the federal data collection form, the prior year audit was significantly delayed and the Superintendent retired who was responsible for completing the federal data collection form submission retired. Effect: Under the terms of the MOU, the School Board is considered a vendor and therefore the funding should not have been considered a federal award and therefore should not have been reported on the SEFA. The SEFA provided to us did not contain the correct amounts of federal awards, which is the basis used to determine the major federal programs to be audited in a fiscal year. Under the terms of your federal awards you are not in compliance with Uniform Guidance regulations and this results in additional coverage requirements to be utilized by the auditors in determining the d liar amount of federal awards to be audited for the fiscal period. Recommendation: The School Board should strengthen its controls including its review processes over the information and balances that is accumulated and reported on the SEF A to make sure the expenditures reported are an accurate representation of federal costs. A determination of whether a vendor or sub-recipient relationship exists with the funding agency should be made with every new federal grant award received. The School Board should implement a procedure to ensure the timing of the federal data collection form is done in accordance with regulations. View of Responsible Official: The NIET award appeared to be a flow-through award from federal sources. The schedule was prepared on that basis which was a conservative approach by the District. However, the arrangement with NIET is not consistent with current or historical grant funding which has normally been governmentally funded. As a result, the amount was placed on the SEFA schedule for auditor review. On the other hand, the District will review grant funding more carefully moving forward to properly identify sub-recipient awards that are federal and non-federally funded. Secondly, the Data Collection Form submission was an inadvertent oversight since the electronic submission email was sent to the District's former superintendent. This matter is considered isolated and has been addressed.

2019-002 Preparation of Schedule of Expenditures of Federal Awards (SEFA) and Timely Filing of Federal Data Collection Form The NIET award appeared to be a flow-through award from federal sources. The schedule was prepared on that basis which was a conservative approach by the District. However, the arrangement with NIET is not consistent with current or historical grant funding which has normally been governmentally funded. As a result, the amount was placed on the SEFA schedule for auditor review. On the other hand, the District will review grant funding more carefully moving forward to properly identify sub-recipient awards that are federal and non-federally funded. This matter is considered resolved. Secondly, the Data Collection Form submission was an inadvertent oversight since the electronic submission email was sent to the District's former superintendent. This matter is considered isolated and has been addressed.

GSA_MIGRATION

GSA_MIGRATION

2015-004