Jefferson Davis Parish School Board

U.S. Department of Education 2025-006 Weakness in Internal Control Over Compliance of Suspension and Debarment Federal Program: Special Education Cluster (IDEA); Special Education – Grants to States (IDEA, Part B) Assistance Listing No. 84.027, Special Education – Preschool Grants (IDEA, Part B – Preschool) Assistance Listing No. 84.173 Grant Period: Year Ended June 30, 2025; Pass-through Entity: Louisiana Department of Education Condition: During review of transactions entered into during the audit period under the Special Education Cluster, the School Board did not have internal controls designed or implemented to ensure verification of suspension and debarment status for covered transactions. Although audit testing determined no vendors were suspended or debarred, the absence of controls could result in material noncompliance in the future. Criteria: The requirements for nonprocurement suspension and debarment are contained in Office of Management and Budget (OMB) guidance at 2 CFR part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension,” and are adopted by federal agencies through Title 2 of the Code of Federal Regulations, applicable program legislation, and the terms and conditions of the federal award. When a recipient or subrecipient enters into a covered transaction with an entity at a lower tier, the recipient or subrecipient must verify that the entity, as defined in 2 CFR 180.995 and the applicable agency adopting regulations, is not suspended, debarred, or otherwise excluded from participation in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA), (2) obtaining a written certification from the entity, or (3) including a clause or condition in the covered transaction with that entity (2 CFR 180.300). These requirements are further described in the OMB Compliance Supplement. Cause of Condition: Review of covered transactions entered into during the audit period under the Special Education Cluster indicated that internal controls were not adequately designed or implemented to ensure compliance with federal suspension and debarment requirements. Potential Effect of Condition: Although no vendors were identified that were suspended or debarred during the period tested, the absence of a designed and implemented verification control increases the risk that the School Board could enter into transactions with ineligible vendors in the future. Such transactions could result in noncompliance with applicable requirements and may expose the School Board to potential repayment of questioned costs, withholding of funding, or other administrative remedies in the event noncompliance occurs. Recommendation: Management should design, implement, and maintain effective internal controls to ensure compliance with federal nonprocurement suspension and debarment requirements for all covered transactions under the Special Education Cluster. In addition, management should establish and enforce written policies and procedures requiring verification of suspension and debarment status for all applicable vendors and service providers prior to entering into covered transactions. Management’s Response: Management agrees with the finding and will work on designing and implementing internal controls to ensure suspension and debarment verifications are performed and documented for covered transactions under the Special Education Cluster.

U.S. Department of Agriculture 2025-007 Weakness in Internal Controls Over Compliance of Allowable Costs/Cost Principles of Payroll Disbursements Federal Program: Child Nutrition Cluster — USDA Commodities (15.550), School Breakfast Program (10.553), National School Lunch Program (10.555), Summer Food Service Program for Children (10.559) Grant Period: Year Ended June 30, 2025; Pass-through Entity: Louisiana Department of Education Condition: During payroll disbursement control testing and Single Audit compliance procedures, the auditors identified weaknesses in internal controls over compliance of allowable costs/cost principles of payroll disbursements in the Child Nutrition Cluster. Specifically, controls were not sufficient to consistently prevent or detect AESOP schedule mismatches, unsupported payroll master file entries, and timekeeping system interface discrepancies. As a result, minor payroll errors were not identified or corrected on a timely basis and minor improper payments charged to the Child Nutrition Cluster occurred. Criteria: Uniform Guidance requires non‑Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award (2 CFR § 200.303(a)). Effective internal controls over compliance of allowable costs/cost principles of payroll disbursements to Federal programs includes controls to ensure employee schedules, payroll master file changes, and time and attendance data are accurate, supported, and appropriately reviewed to prevent or detect improper payments. Cause of Condition: Control testing and Single Audit compliance procedures on payroll disbursements indicated that internal controls were not adequately designed or implemented to ensure compliance with requirements of allowable costs/cost principles that Federal award costs must be allowable, reasonable, and necessary for the performance of the Federal program. Potential Effect of Condition: As a result, the School Board did not have adequate internal controls over compliance related to allowable costs and cost principles for payroll disbursements charged to the Child Nutrition Cluster. Essentially controls were not properly designed and implemented to provide reasonable assurance that payroll expenditures were accurate, allowable, and adequately supported. The identified misstatements included $2.11 related to GAP pay errors and $116.96 of unsupported substitute pay. Although these amounts were individually immaterial, a per‑item projection of the identified errors to the full payroll population of approximately 974 transactions resulted in an estimated maximum projected exposure of approximately $2,800. While this projected amount was determined to be trivial and not expected to result in questioned costs, the control deficiencies increased the risk that improper payroll payments would not be prevented or detected on a timely basis and that unallowable payroll costs could remain charged to Federal programs. Recommendation: Management should design, implement, and maintain effective internal controls over compliance of allowable costs/cost principles of payroll disbursements to Federal programs to provide reasonable assurance that payroll expenditures comply with Uniform Guidance requirements. In addition, management should establish and enforce procedures to ensure employee schedules, payroll master file changes, and time and attendance records are accurate, supported, and appropriately reviewed prior to payroll processing, and that payroll costs charged to the Child Nutrition Cluster represent compensation for actual services performed. Review procedures should be formalized and consistently evidenced through signatures, initials, electronic timestamps, dates, checklists or system audit trails. Management’s Response: Management agrees with the finding and has reviewed the payroll items identified during the audit and has taken corrective action to address schedule discrepancies and unsupported payroll entries. Management has conducted a review of employee schedules within the timekeeping system to ensure alignment with payroll records and has corrected errors identified. Management plans to continue performing periodic reviews of payroll data to identify potential discrepancies and to take corrective action as needed. Management will also evaluate identified payroll discrepancies on a case‑by‑case basis to determine whether recovery or adjustment is appropriate.

U.S. Department of Agriculture 2025-008 Weakness in Internal Control Over Compliance of Suspension and Debarment Federal Program: Child Nutrition Cluster — USDA Commodities (15.550), School Breakfast Program (10.553), National School Lunch Program (10.555), Summer Food Service Program for Children (10.559) Grant Period: Year Ended June 30, 2025; Pass-through Entity: Louisiana Department of Education Condition: During review of transactions entered into during the audit period under the Child Nutrition Cluster, the School Board did not have internal controls adequately designed to ensure verification of suspension and debarment status for all covered transactions. While the Child Nutrition Cluster maintains a separate Procurement Plan that includes suspension and debarment requirements, those requirements are explicitly stated only within the formal procurement and formal bid provisions of the plan. The Procurement Plan does not clearly state that nonprocurement suspension and debarment requirements apply to all covered transactions, including those executed through micro‑purchase and small purchase procurement methods, even though federal regulations require these prohibitions to apply regardless of procurement method. Audit testing determined that no vendors were suspended or debarred during the period tested; however, the absence of clearly designed controls applicable to all procurement methods increases the risk of noncompliance in the future. Criteria: The requirements for nonprocurement suspension and debarment are contained in Office of Management and Budget (OMB) guidance at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension,” and are adopted by federal agencies through 2 CFR Part 200, applicable program legislation, and the terms and conditions of the federal award. When a recipient or subrecipient enters into a covered transaction with an entity at a lower tier, the recipient or subrecipient must verify that the entity, as defined in 2 CFR § 180.995 and the applicable agency adopting regulations, is not suspended, debarred, or otherwise excluded from participation in the transaction. Verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions, (2) obtaining a written certification from the entity, or (3) including a clause or condition in the covered transaction with that entity (2 CFR § 180.300). These requirements apply to all covered transactions regardless of procurement method, as further described in the OMB Compliance Supplement. Cause of Condition: Review of the Child Nutrition Procurement Plan and procurement activity indicated that internal controls were not adequately designed to clearly apply nonprocurement suspension and debarment verification requirements to all covered transactions, including those executed through micro‑purchase and small purchase procurement methods. As a result, controls were not consistently designed to ensure compliance with federal suspension and debarment requirements for all covered transactions under the Child Nutrition Cluster. Potential Effect of Condition: Although no vendors were identified that were suspended or debarred during the period tested, the absence of clearly designed and implemented verification controls applicable to all covered transactions, including those executed through various procurement methods, increases the risk that the School Board could enter into transactions with ineligible vendors in the future. Such transactions could result in noncompliance with applicable federal requirements and may expose the School Board to potential repayment of questioned costs, withholding of funding, or other administrative remedies should noncompliance occur. Recommendation: Management should revise the Child Nutrition Procurement Plan to clearly require verification of suspension and debarment status for all covered transactions, including those executed through micro‑purchase and small purchase procurement methods. In addition, management should design, implement, and maintain effective internal controls to ensure suspension and debarment verifications are performed and documented for all applicable vendors prior to entering into covered transactions under the Child Nutrition Cluster. Management’s Response: Management agrees with the finding and will update the Child Nutrition Procurement Plan and related procedures to ensure suspension and debarment requirements are clearly applied to all covered transactions, including those executed through various procurement methods. Management will also work to design and implement internal controls to ensure suspension and debarment verifications are consistently performed and documented for covered transactions under the Child Nutrition Cluster.

U.S. Department of Health and Human Services 2023-003 Monitoring of payments to subrecipient Program: COVID-19 Child Care and Development Block Grant - Assistance Listing No. 93.575; Grant No. 2101LACDC6 & COVID-19 Child Care Development – Assistance Listing No. 93.596; Grant No. 2101LACCC5 Grant Period: Year Ended June 30, 2023; Pass-through Entity Name: Louisiana Department of Education Criteria: Federal compliance requirements call for monitoring of subrecipients to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. It appears that the program has not complied with these requirements. Condition: Audit sample testing identified 2 out of 40 transactions that lacked adequate documentation to support subrecipient reimbursements. This may have resulted in payment of $11,383 in questioned costs. Of this amount, $3,624 is alleged to be a fraudulent invoice submitted by a subrecipient. See finding 2023-002 for additional information. Cause of Condition: It appears that management may not have had adequate controls designed and in place to monitor subrecipient reimbursements. Potential Effect of Condition: The $11,383 is considered questioned costs. Due to the allegation of potential fraud we consider this to be material to the program. Recommendation: Management should consider developing appropriate written policies and procedures to ensure proper monitoring of payments to subrecipients. Management’s Response: We agree with the recommendations and will make necessary changes to policies and procedures.

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