Lafayette Prish School BoardLocal Government

Condition The School Board did not verify that vendors were not suspended, debarred or otherwise excluded from federal programs before conducting business with them. Criteria Federal regulations require recipients of federal funds to verify that vendors are not suspended, debarred or otherwise excluded from doing business with the federal government prior to awarding contracts or making purchases. Cause The School Board lacked internal controls and formal policies and procedures to ensure vendor verification was performed before engaging in business transactions. Effect Failure to verify vendors’ eligibility could result in noncompliance with federal regulations and potential risk to federal funding. Context A sample of fifteen vendors were selected for audit testing. The test found that three of the vendors tested had not been verified by the School Board prior to the School Board doing business with them. Our sample was a non-statistical sample. Recommendation The School Board should implement and enforce policies and procedures to ensure that all vendors are verified for eligibility before engaging in business transactions. View of Responsible Officials and Planned Corrective Action The Lafayette Parish School Board has a defined process in place to ensure debarment verifications are being performed. As new vendors are setup, a debarment verification is performed when federal funds are to be associated with a vendor. In addition, many vendors are utilized year after year, which is after an initial debarment verification is performed. In this case, debarment verifications for three vendors could not be found, and despite key personnel turnover, staff will ensure that debarment verifications are being performed and stored digitally.

Condition The School Board was unable to provide sufficient documentation for certain grant-funded asset disposals. Four of the assets tested during the audit were missing, and no supporting disposal documentation could be provided. Criteria Federal regulations require that asset dispositions be reported to the grantor when the fair market value at the time of disposal is $5,000 or more, to determine if a portion of the value or proceeds must be reimbursed to the grantor. Additionally, asset disposals must comply with state law and be properly reflected in the property records. Cause The School Board’s internal control policies and procedures were not operating effectively to ensure that all assets were properly safeguarded and/or disposed of in accordance with federal and state requirements. Effect Failure to properly document and account for asset disposals increases the risk of misuse or misappropriation of assets and noncompliance with federal and state regulations. Context A sample of eight disposals were selected for audit from a population of eight disposals. The test found that four of the disposals tested did not have supporting documentation. Our sample was a non-statistical sample. Recommendation The School Board should strengthen and enforce policies and procedures to ensure that all grant-funded and other assets are properly accounted for and disposed of in accordance with federal and state requirements. Views of Responsible Officials and Planned Corrective Action During the recent audit, several assets were randomly selected for review by the auditors. Four of the assets selected were supposed to have been removed from the capital asset listing, but were not removed because the required documentation was not remitted to the Accounting Department. Going forward, accounting staff will visit all schools to conduct a capital asset audit to ensure the capital asset listing is accurate and to provide additional training to school based staff.

Condition During our audit of the School Board’s financial statements for the year ended June 30, 2025, we encountered circumstances that imposed pervasive limitations on the scope of our audit. Specifically: • We were unable to obtain sufficient appropriate audit evidence regarding significant financial statement balances, transactions, and disclosures. • Accounting records and supporting documentation necessary to perform audit procedures were incomplete, unavailable, or unreliable. • Management representations, including written representations required under auditing standards, could not be relied upon due to concerns regarding the reliability of management representations. • These conditions, combined with the risk that management could override internal controls, further limited our ability to obtain evidence that financial reporting was complete and accurate. In addition, these same conditions prevented us from performing required audit procedures over the School Board’s federal programs, including testing of internal control over compliance and compliance with applicable federal statutes, regulations, and terms and conditions of federal awards. As a result, we were unable to obtain sufficient appropriate audit evidence to support an opinion on compliance for each major federal program. Criteria Uniform Guidance (2 CFR §200.303 and §200.514) requires non-federal entities to establish and maintain effective internal control over federal programs and to provide auditors with access to records and personnel necessary to perform a Single Audit. Uniform Guidance §200.516 requires auditors to report material weaknesses and noncompliance when identified. Cause The conditions described above resulted from inadequate recordkeeping and documentation practices, deficiencies in internal control over financial reporting, and management actions and behaviors that restricted the auditor’s ability to obtain reliable audit evidence and representations. These conditions directly impaired the auditor’s ability to perform planned audit procedures and obtain sufficient appropriate audit evidence. These conditions affected both financial reporting and compliance with federal program requirements. Effect Because of these pervasive limitations and the risk of management override, we were unable to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion. The potential effects on the financial statements are both material and pervasive, and therefore we issued a disclaimer of opinion on the School Board’s financial statements for the year ended June 30, 2025. For the same reasons, we were also unable to obtain sufficient appropriate audit evidence to support an opinion on compliance for each of the School Board’s major federal programs and on internal control over compliance. Accordingly, we disclaimed an opinion on compliance for each major federal program under the Single Audit. Context Questioned costs could not be determined due to the disclaimer of opinion. Recommendation We recommend that the School Board take immediate action to strengthen its internal control environment. Specifically, management should: • Ensure that all accounting records and supporting documentation are complete, accurate, and readily available. • Enforce oversight of financial reporting and internal control procedures. • Promote transparency, accountability, and cooperation with auditors to facilitate future audits. • Implement measures to mitigate the risk of management override, including additional supervisory review, approval requirements, and segregation of duties. • Ensure compliance documentation for federal programs is complete, accurate, and available for audit. Views of Responsible Officials and Planned Corrective Action A. OBJECTION On December 29, 2025, following LPSB’s submission of its Response to the Draft Findings of Kolder, Slaven, and Company, LLC (“KS&C”) relating to its 2024-2025 Annual Audit, LPSB received two additional findings characterized as Disclaimers of Opinion. The issuance of these post-response Disclaimers of Opinion regarding the findings highlights KS&C’s apparent lack of objectivity and its failure to adhere to generally accepted government auditing standards in conducting the 24-25 audit. A Disclaimer of Opinion “is expressed when the auditor is unable to obtain sufficient appropriate audit evidence on which to base the opinion, and the auditor concludes that the possible effects on the financial statements of undetected misstatements, if any, could be both material and pervasive.”1 According to LLA, “a local auditee that provides for an audit report with a disclaimer of opinion” is regarded as being in noncompliance with its reporting requirements to LLA under the audit law (Louisiana Revised Statute 24:513). LLA further expects the CPA to include in such a report a finding that provides a full explanation for the disclaimer of opinion.2 The two supplemental responses provided are, however, substantially lacking the “full explanation” mandated by the Legislative Auditors for the serious allegations being presented by KS&C. As with its other findings, these recent findings fail to cite any specific conditions present during the audit period that would have precluded KS&C from forming a conclusion. Therefore, as with the original findings, LPSB, on January 6, 2026, again requested that KS&C provide supporting evidence for its claim that it was unable to obtain “evidence regarding significant financial statement balances, transactions, and disclosures.” KS&C responded by stating that these new findings were based on Finding 16 - Invoices Paid Without Sufficient Supporting Detail (IC & C), Finding 26 - Management Override of Established Internal Controls (IC), Finding 31 - Unsupported Experience-Based Pay Increases (IC), and other undisclosed matters. Notably, none of these specific findings are instances where KS&C was prevented from forming a conclusion. To the contrary, the original findings identified by KS&C reflect otherwise. For instance, in Finding 16, KS&C notes it “tested 539 and identified 213 in which invoices were paid without sufficient documentation.” Despite KS&C’s assertions, LPSB has at no point failed to provide information to KS&C upon request (see Corrective Action sections below). In fact, KS&C issued 33 Findings, each purportedly substantiated by documentation. As stated in LPSB’s Response, a request was made by LPSB for KS&C to produce the referenced specific supporting documentation. However, KS&C declined to provide the documentation. Auditing standards stipulate: “Auditors should document supervisory review, before the report release date, of the evidence that supports the findings and conclusions contained in the audit report.”3 They further require: “Auditors should document any departures from the GAGAS requirements and the effect on the audit and on the auditors’ conclusions when the audit is not in compliance with applicable GAGAS requirements because of law, regulation, scope limitations, restrictions on access to records, or other issues affecting the audit.”4 Despite LPSB, in its Response and communications prior thereto pointing out erroneous references to the law and facts, KS&C refused to modify its findings. Instead, it introduced these two ambiguous Disclaimers of Opinion, alleging that LPSB failed to provide necessary information for KS&C to reach a conclusion. However, a cursory review of its original findings clearly reflect that KS&C did reach conclusions, which they assert were based upon conditions found during their investigation. Which is it? Are KS&C’s findings supported or not? KS&C’s ex post Disclaimers of Opinion not only misrepresent LPSB’s cooperation and full disclosure of information, but they are also predicated upon the unfounded assertion that LPSB’s “representations, including written representations required under auditing standards, could not be relied upon due to concerns regarding the reliability of management representations.” After 33 years of engagement with LPSB audits, KS&C has now made the unwarranted claim that LPSB’s representations are unreliable, without pointing to a specific instance of unreliability. Ironically, it is the auditor’s own representations that are demonstrated to be unreliable, as evidenced by the submission of these two vague and contradictory Disclaimers of Opinion. “[A] CPA cannot enter into the engagement with a pre-conceived notion that the local auditee is doing everything wrong. Going into an engagement with [this] attitude impairs the independence of the CPA firm.” The two findings, submitted after LPSB responded to its original findings, do not meet the standards set forth in the Louisiana Governmental Audit Guide. They contradict the original findings, misrepresent LPSB’s cooperation throughout the audit, insert slanderous statements as to the reliability of LPSB’s representations, and fail to provide a full explanation for the disclaimer of opinion. KS&C should remove these findings from its report. 1 LGAG 400-1160, Types of Auditor’s Opinions 2 LGAG 400-1160, Types of Auditor’s Opinions 3 GAO-24, Sections 6.31 (emphasis added) 4 GAO-24, Sections 6.32 B. CORRECTIVE ACTION Prior to the financial audit, Lafayette Parish School Board (LPSB) staff prepared reports and documentation for at least 185 requests that were made by the external auditors. These requests consisted of, but were not limited to, all General Ledger data and information on all Major and Non Major Funds (i.e. General Fund, Construction Funds, Debt Service Funds, and Special Revenue funds), worksheets, personnel records, copies of checks, copies of invoices, grant reimbursement requests, expenditure detail reports, capital asset data and reports, accounts payable data and reports, the type of computer equipment used (including the software and operating systems), construction related documents, copies of contracts, insurance invoices, schedules of judgments and agreements, check registers, calendars, securities pledged, accounts payable details, financial statements, schedule of construction contracts, retirement reports, listing of new hires, purchase orders, check requests, financial reconciliations, sales tax reports and documents, other insurance related documents, insurance policies, monitoring reports, AFR report, arbitrage documentation, copies of deposits receipts, copies of budgets, outstanding checks, revenue reports, expenditure reports, and balance sheet reports. Under the Department of Education agreed upon procedures audit, LPSB staff provided Class size data, PEP data and a user guide. Under the Statewide Agreed Upon procedure, LPSB staff provided proof of required trainings such as ethics, bond insurance policies, list of all bank accounts, a listing of employees, officials employed during the year, and a list of deposit and collection sites. Other requests from our external auditors may come via email throughout the audit process and responses are provided likewise. All of the items listed above, and other items that were not listed above, are routinely provided each year. For several decades this has been the standard and nothing has changed in terms of provided supporting documentation within this particular audit. Internal controls have been in place for many decades. The external auditors have been reviewing, studying and auditing our internal controls for three decades. Over the years, LPSB internal controls have been adjusted, strengthened or heighten to prevent operational deficiencies, fraud and/or non-compliance of which the auditors have contributed to its advancement. Substantially, there has been no change to internal controls as they are in place for a reason. Systematically, internal controls are planted and executed in various areas and departments for various functions and/or lawful requirements. The biggest threats to any organization are misappropriation or improper disbursement of funds. Neither have occurred, because internal controls such as the utilization of electronic requisitions and check request processes were in place to ensure goods and services were precured properly and vendor payments were substantiated. LPSB stands by its management representations that have been provided to the auditors. We acknowledge our responsibility for the design, implementation, and maintenance of internal controls relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error. In addition to supporting documentation, the external auditors had complete access to our financial software to ascertain the completeness and accuracy of our financial records. Auditor’s Response The School Board’s response to this finding contains statements and characterizations that are inconsistent with the audit evidence obtained and the procedures performed. The auditor stands by the condition, criteria, cause, and effect as presented in the finding, which are based on documentation, observations, interviews, and other information available during the audit. Management’s response has not resulted in any change to the finding or the auditor’s conclusions.

Condition The School Board did not submit its reporting package to the Federal Audit Clearinghouse within the required timeframe. Criteria In accordance with 2 CFR 200.512, auditees are required to submit the reporting package to the Federal Audit Clearinghouse the earlier of 30 calendar days after receipt of the auditor’s reports or nine months after the end of the audit period. Cause The reporting package was not submitted within the required timeframe due to delays in completion of the audit, which were impacted by the timing and availability of financial information and supporting documentation, including delays in receipt of necessary information and supporting documentation required to complete audit procedures. Effect The School Board was not in compliance with federal reporting requirements and submission of the reporting package was delayed beyond the required deadline. Recommendation Management should strengthen its financial reporting and year-end closing processes to ensure that all necessary information is prepared and available in a timely manner to facilitate completion of the audit within required reporting deadlines. Views of Responsible Officials and Planned Corrective Action Management will continue to submit documentation, data and other information in a timely manner. Obtaining the additional legal information requested by our external auditors through the confirmation process was delayed due to certain attorneys not being present in the office due to vacationing and/or handling other court cases. Although these things are not within the control of the Lafayette Parish School Board, management will be proactive in coordinating efforts between both parties; auditors and attorneys.

Condition The School Board was unable to provide sufficient documentation for certain grant-funded asset disposals. Four of the assets tested during the audit were missing, and no supporting disposal documentation could be provided. Criteria Federal regulations require that asset dispositions be reported to the grantor when the fair market value at the time of disposal is $5,000 or more, to determine if a portion of the value or proceeds must be reimbursed to the grantor. Additionally, asset disposals must comply with state law and be properly reflected in the property records. Cause The School Board’s internal control policies and procedures were not operating effectively to ensure that all assets were properly safeguarded and/or disposed of in accordance with federal and state requirements. Effect Failure to properly document and account for asset disposals increases the risk of misuse or misappropriation of assets and noncompliance with federal and state regulations. Context A non-statistical sample of two disposals from a population of two was tested. Both disposals lacked supporting documentation for the disposal process. Recommendation The School Board should strengthen and enforce policies and procedures to ensure that all grant-funded and other assets are properly accounted for and disposed of in accordance with federal and state requirements. Views of Responsible Officials and Planned Corrective Action During the recent audit, several assets were randomly selected for review by the auditors. Four of the assets selected were supposed to have been removed from the capital asset listing, but were not removed because the required documentation was not remitted to the Accounting Department. Going forward, accounting staff will visit all schools to conduct a capital asset audit to ensure the capital asset listing is accurate and to provide additional training to school based staff.

Condition During our audit of the School Board’s financial statements for the year ended June 30, 2025, we encountered circumstances that imposed pervasive limitations on the scope of our audit. Specifically: • We were unable to obtain sufficient appropriate audit evidence regarding significant financial statement balances, transactions, and disclosures. • Accounting records and supporting documentation necessary to perform audit procedures were incomplete, unavailable, or unreliable. • Management representations, including written representations required under auditing standards, could not be relied upon due to concerns regarding the reliability of management representations. • These conditions, combined with the risk that management could override internal controls, further limited our ability to obtain evidence that financial reporting was complete and accurate. In addition, these same conditions prevented us from performing required audit procedures over the School Board’s federal programs, including testing of internal control over compliance and compliance with applicable federal statutes, regulations, and terms and conditions of federal awards. As a result, we were unable to obtain sufficient appropriate audit evidence to support an opinion on compliance for each major federal program. Criteria Uniform Guidance (2 CFR §200.303 and §200.514) requires non-federal entities to establish and maintain effective internal control over federal programs and to provide auditors with access to records and personnel necessary to perform a Single Audit. Uniform Guidance §200.516 requires auditors to report material weaknesses and noncompliance when identified. Cause The conditions described above resulted from inadequate recordkeeping and documentation practices, deficiencies in internal control over financial reporting, and management actions and behaviors that restricted the auditor’s ability to obtain reliable audit evidence and representations. These conditions directly impaired the auditor’s ability to perform planned audit procedures and obtain sufficient appropriate audit evidence. These conditions affected both financial reporting and compliance with federal program requirements. Effect Because of these pervasive limitations and the risk of management override, we were unable to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion. The potential effects on the financial statements are both material and pervasive, and therefore we issued a disclaimer of opinion on the School Board’s financial statements for the year ended June 30, 2025. For the same reasons, we were also unable to obtain sufficient appropriate audit evidence to support an opinion on compliance for each of the School Board’s major federal programs and on internal control over compliance. Accordingly, we disclaimed an opinion on compliance for each major federal program under the Single Audit. Context Questioned costs could not be determined due to the disclaimer of opinion. Recommendation We recommend that the School Board take immediate action to strengthen its internal control environment. Specifically, management should: • Ensure that all accounting records and supporting documentation are complete, accurate, and readily available. • Enforce oversight of financial reporting and internal control procedures. • Promote transparency, accountability, and cooperation with auditors to facilitate future audits. • Implement measures to mitigate the risk of management override, including additional supervisory review, approval requirements, and segregation of duties. • Ensure compliance documentation for federal programs is complete, accurate, and available for audit. Views of Responsible Officials and Planned Corrective Action A. OBJECTION On December 29, 2025, following LPSB’s submission of its Response to the Draft Findings of Kolder, Slaven, and Company, LLC (“KS&C”) relating to its 2024-2025 Annual Audit, LPSB received two additional findings characterized as Disclaimers of Opinion. The issuance of these post-response Disclaimers of Opinion regarding the findings highlights KS&C’s apparent lack of objectivity and its failure to adhere to generally accepted government auditing standards in conducting the 24-25 audit. A Disclaimer of Opinion “is expressed when the auditor is unable to obtain sufficient appropriate audit evidence on which to base the opinion, and the auditor concludes that the possible effects on the financial statements of undetected misstatements, if any, could be both material and pervasive.”1 According to LLA, “a local auditee that provides for an audit report with a disclaimer of opinion” is regarded as being in noncompliance with its reporting requirements to LLA under the audit law (Louisiana Revised Statute 24:513). LLA further expects the CPA to include in such a report a finding that provides a full explanation for the disclaimer of opinion.2 The two supplemental responses provided are, however, substantially lacking the “full explanation” mandated by the Legislative Auditors for the serious allegations being presented by KS&C. As with its other findings, these recent findings fail to cite any specific conditions present during the audit period that would have precluded KS&C from forming a conclusion. Therefore, as with the original findings, LPSB, on January 6, 2026, again requested that KS&C provide supporting evidence for its claim that it was unable to obtain “evidence regarding significant financial statement balances, transactions, and disclosures.” KS&C responded by stating that these new findings were based on Finding 16 - Invoices Paid Without Sufficient Supporting Detail (IC & C), Finding 26 - Management Override of Established Internal Controls (IC), Finding 31 - Unsupported Experience-Based Pay Increases (IC), and other undisclosed matters. Notably, none of these specific findings are instances where KS&C was prevented from forming a conclusion. To the contrary, the original findings identified by KS&C reflect otherwise. For instance, in Finding 16, KS&C notes it “tested 539 and identified 213 in which invoices were paid without sufficient documentation.” Despite KS&C’s assertions, LPSB has at no point failed to provide information to KS&C upon request (see Corrective Action sections below). In fact, KS&C issued 33 Findings, each purportedly substantiated by documentation. As stated in LPSB’s Response, a request was made by LPSB for KS&C to produce the referenced specific supporting documentation. However, KS&C declined to provide the documentation. Auditing standards stipulate: “Auditors should document supervisory review, before the report release date, of the evidence that supports the findings and conclusions contained in the audit report.”3 They further require: “Auditors should document any departures from the GAGAS requirements and the effect on the audit and on the auditors’ conclusions when the audit is not in compliance with applicable GAGAS requirements because of law, regulation, scope limitations, restrictions on access to records, or other issues affecting the audit.”4 Despite LPSB, in its Response and communications prior thereto pointing out erroneous references to the law and facts, KS&C refused to modify its findings. Instead, it introduced these two ambiguous Disclaimers of Opinion, alleging that LPSB failed to provide necessary information for KS&C to reach a conclusion. However, a cursory review of its original findings clearly reflect that KS&C did reach conclusions, which they assert were based upon conditions found during their investigation. Which is it? Are KS&C’s findings supported or not? KS&C’s ex post Disclaimers of Opinion not only misrepresent LPSB’s cooperation and full disclosure of information, but they are also predicated upon the unfounded assertion that LPSB’s “representations, including written representations required under auditing standards, could not be relied upon due to concerns regarding the reliability of management representations.” After 33 years of engagement with LPSB audits, KS&C has now made the unwarranted claim that LPSB’s representations are unreliable, without pointing to a specific instance of unreliability. Ironically, it is the auditor’s own representations that are demonstrated to be unreliable, as evidenced by the submission of these two vague and contradictory Disclaimers of Opinion. “[A] CPA cannot enter into the engagement with a pre-conceived notion that the local auditee is doing everything wrong. Going into an engagement with [this] attitude impairs the independence of the CPA firm.” The two findings, submitted after LPSB responded to its original findings, do not meet the standards set forth in the Louisiana Governmental Audit Guide. They contradict the original findings, misrepresent LPSB’s cooperation throughout the audit, insert slanderous statements as to the reliability of LPSB’s representations, and fail to provide a full explanation for the disclaimer of opinion. KS&C should remove these findings from its report. 1 LGAG 400-1160, Types of Auditor’s Opinions 2 LGAG 400-1160, Types of Auditor’s Opinions 3 GAO-24, Sections 6.31 (emphasis added) 4 GAO-24, Sections 6.32 B. CORRECTIVE ACTION Prior to the financial audit, Lafayette Parish School Board (LPSB) staff prepared reports and documentation for at least 185 requests that were made by the external auditors. These requests consisted of, but were not limited to, all General Ledger data and information on all Major and Non Major Funds (i.e. General Fund, Construction Funds, Debt Service Funds, and Special Revenue funds), worksheets, personnel records, copies of checks, copies of invoices, grant reimbursement requests, expenditure detail reports, capital asset data and reports, accounts payable data and reports, the type of computer equipment used (including the software and operating systems), construction related documents, copies of contracts, insurance invoices, schedules of judgments and agreements, check registers, calendars, securities pledged, accounts payable details, financial statements, schedule of construction contracts, retirement reports, listing of new hires, purchase orders, check requests, financial reconciliations, sales tax reports and documents, other insurance related documents, insurance policies, monitoring reports, AFR report, arbitrage documentation, copies of deposits receipts, copies of budgets, outstanding checks, revenue reports, expenditure reports, and balance sheet reports. Under the Department of Education agreed upon procedures audit, LPSB staff provided Class size data, PEP data and a user guide. Under the Statewide Agreed Upon procedure, LPSB staff provided proof of required trainings such as ethics, bond insurance policies, list of all bank accounts, a listing of employees, officials employed during the year, and a list of deposit and collection sites. Other requests from our external auditors may come via email throughout the audit process and responses are provided likewise. All of the items listed above, and other items that were not listed above, are routinely provided each year. For several decades this has been the standard and nothing has changed in terms of provided supporting documentation within this particular audit. Internal controls have been in place for many decades. The external auditors have been reviewing, studying and auditing our internal controls for three decades. Over the years, LPSB internal controls have been adjusted, strengthened or heighten to prevent operational deficiencies, fraud and/or non-compliance of which the auditors have contributed to its advancement. Substantially, there has been no change to internal controls as they are in place for a reason. Systematically, internal controls are planted and executed in various areas and departments for various functions and/or lawful requirements. The biggest threats to any organization are misappropriation or improper disbursement of funds. Neither have occurred, because internal controls such as the utilization of electronic requisitions and check request processes were in place to ensure goods and services were precured properly and vendor payments were substantiated. LPSB stands by its management representations that have been provided to the auditors. We acknowledge our responsibility for the design, implementation, and maintenance of internal controls relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error. In addition to supporting documentation, the external auditors had complete access to our financial software to ascertain the completeness and accuracy of our financial records. Auditor’s Response The School Board’s response to this finding contains statements and characterizations that are inconsistent with the audit evidence obtained and the procedures performed. The auditor stands by the condition, criteria, cause, and effect as presented in the finding, which are based on documentation, observations, interviews, and other information available during the audit. Management’s response has not resulted in any change to the finding or the auditor’s conclusions.

Condition The School Board was unable to provide sufficient documentation for certain grant-funded asset disposals. Four of the assets tested during the audit were missing, and no supporting disposal documentation could be provided. Criteria Federal regulations require that asset dispositions be reported to the grantor when the fair market value at the time of disposal is $5,000 or more, to determine if a portion of the value or proceeds must be reimbursed to the grantor. Additionally, asset disposals must comply with state law and be properly reflected in the property records. Cause The School Board’s internal control policies and procedures were not operating effectively to ensure that all assets were properly safeguarded and/or disposed of in accordance with federal and state requirements. Effect Failure to properly document and account for asset disposals increases the risk of misuse or misappropriation of assets and noncompliance with federal and state regulations. Context A non-statistical sample of two disposals from a population of two was tested. Both disposals lacked supporting documentation for the disposal process. Recommendation The School Board should strengthen and enforce policies and procedures to ensure that all grant-funded and other assets are properly accounted for and disposed of in accordance with federal and state requirements. Views of Responsible Officials and Planned Corrective Action During the recent audit, several assets were randomly selected for review by the auditors. Four of the assets selected were supposed to have been removed from the capital asset listing, but were not removed because the required documentation was not remitted to the Accounting Department. Going forward, accounting staff will visit all schools to conduct a capital asset audit to ensure the capital asset listing is accurate and to provide additional training to school based staff.

Condition There were inadequate controls over documentation of the number of students receiving snacks that are claimed for reimbursement. Criteria The School Board should implement policies and procedures to ensure that documentation is maintained to support all snacks claimed for reimbursement. Cause The School Board did not have internal control policies and procedures in place to ensure that all documentation supporting snack reimbursements was properly maintained. Effect Supporting documentation relating to snacks is not being properly maintained. Context A sample of nine months for seven schools was selected for audit from a population of 43 schools. The test found that the support did not agree to the amount claimed for four of the months. Two of the schools requested one snack more than the support, while the other two schools requested a total of five snacks less than the support. Our sample was a non-statistical sample. Recommendation The School Board should implement policies and procedures to ensure that supporting documentation is maintained for all snacks served. Views of Responsible Officials and Planned Corrective Action The child nutrition department will attempt to remedy this type of issue by recording the snack meals electronically by utilizing our existing system. The supervisor of child nutrition will determine how to implement this function.

Condition The School Board failed to verify applicable vendors were not suspended, debarred or otherwise excluded from doing business with the federal government prior to the School Board doing business with them. Criteria Federal regulations require the School Board to verify vendors are not suspended, debarred or otherwise excluded from doing business with the federal government prior to the School Board doing business with them. Cause The School Board did not have internal control policies and procedures in place to ensure that all vendors were verified prior to doing business with them. Effect Failure to verify vendors are allowed to do business with the School Board could lead to non-compliance. Context A sample of six vendors were selected for audit from a population of eight vendors. The test found that four of the vendors tested had not been verified by the School Board prior to the School Board doing business with them. Our sample was a non-statistical sample. Recommendation The School Board should implement policies and procedures to ensure that the verification of vendors is done prior to doing business with them. View of Responsible Officials and Planned Corrective Action The Lafayette Parish School Board has a defined process in place to ensure debarment checks are being performed. As new vendors are setup, a debarment check is performed when federal funds are to be associated with a vendor. In addition, many vendors are utilized year after year, which is after an initial debarment check is performed. With respect to this audit, staff will ensure adequate records are maintained and stored to show proof of performance of this requirement.

Condition The School Board failed to verify applicable vendors were not suspended, debarred or otherwise excluded from doing business with the federal government prior to doing business with them. Criteria Federal regulations require the School Board to verify vendors are not suspended, debarred or otherwise excluded from doing business with the federal government prior to doing business with them. Cause The School Board did not have internal control policies and procedures in place to ensure that all vendors were verified prior to doing business with them. Effect Failure to verify vendors are allowed to do business with the School Board could lead to non-compliance. Context A sample of six vendors were selected for audit from a population of 14 vendors. The test found that four of the vendors tested had not been verified by the School Board prior to the School Board doing business with them. Our sample was a non-statistical sample. Recommendation The School Board should implement policies and procedures to ensure that the verification of vendors is done prior to doing business with them. View of Responsible Officials and Planned Corrective Action The Lafayette Parish School Board has a defined process in place to ensure debarment checks are being performed. As new vendors are setup, a debarment check is performed when federal funds are to be associated with a vendor. In addition, many vendors are utilized year after year, which is after an initial debarment check is performed. With respect to this audit, staff will ensure adequate records are maintained and stored to show proof of performance of this requirement.

Condition The School Board was unable to provide sufficient documentation for grant asset disposals. Four of the assets tested in the audit were missing and no disposal documentation could be provided. Criteria Federal regulations require asset dispositions to be reported to the grantor if the fair market value at the time of disposal is $5,000 or more to determine if a portion of the fair market value or sales proceeds needs to be reimbursed to the grantor. In addition, the disposal is required to comply with state law and properly reflected in the property records. Cause The School Board internal control policies and procedures were not operating effectively to ensure that all assets are properly safeguarded and/or properly disposed of in accordance with the Federal grant regulations. Effect Failure to properly document disposals and account for them properly could lead to a risk of misuse of assets. Context A sample of four disposals was selected for audit from a population of nine disposals. The test found that all four of the disposals tested did not have supporting documentation for the disposal. Our sample was a non-statistical sample. Recommendation The School Board should comply with the policies and procedures concerning asset disposals to ensure that all assets are properly accounted for and are disposed of properly. Views of Responsible Officials and Planned Corrective Action As assets become broken or obsolete, they are transferred to the warehouse for sale. This is evidenced by completing transfer forms which are signed by the principal or supervisor releasing the asset(s). Once an asset reaches the warehouse, it is segregated either by size or type. Large assets are normally itemized separately, while smaller items or computer related items are bundled together into a large gaylord box and sold as is. In this case, our auditors possessed signed transfer forms, but concluded during their review of disposals that the eventual asset itemizations were not sufficient or non-existent. Going forward, warehouse staff will commence their online auctions with full itemizations to show proof of disposal.

Condition There were inadequate controls over documentation of the number of students receiving snacks that are claimed for reimbursement. Criteria The School Board should implement policies and procedures to ensure that documentation is maintained to support all snacks claimed for reimbursement. Cause The School Board did not have internal control policies and procedures in place to ensure that all documentation supporting snack reimbursements was properly maintained. Effect Supporting documentation relating to snacks is not being properly maintained. Context A sample of nine months for seven schools was selected for audit from a population of 43 schools. The test found that the support did not agree to the amount claimed for four of the months. Two of the schools requested one snack more than the support, while the other two schools requested a total of five snacks less than the support. Our sample was a non-statistical sample. Recommendation The School Board should implement policies and procedures to ensure that supporting documentation is maintained for all snacks served. Views of Responsible Officials and Planned Corrective Action The child nutrition department will attempt to remedy this type of issue by recording the snack meals electronically by utilizing our existing system. The supervisor of child nutrition will determine how to implement this function.

Condition The School Board was unable to provide sufficient documentation for grant asset disposals. Four of the assets tested in the audit were missing and no disposal documentation could be provided. Criteria Federal regulations require asset dispositions to be reported to the grantor if the fair market value at the time of disposal is $5,000 or more to determine if a portion of the fair market value or sales proceeds needs to be reimbursed to the grantor. In addition, the disposal is required to comply with state law and properly reflected in the property records. Cause The School Board internal control policies and procedures were not operating effectively to ensure that all assets are properly safeguarded and/or properly disposed of in accordance with the Federal grant regulations. Effect Failure to properly document disposals and account for them properly could lead to a risk of misuse of assets. Context A sample of four disposals was selected for audit from a population of nine disposals. The test found that all four of the disposals tested did not have supporting documentation for the disposal. Our sample was a non-statistical sample. Recommendation The School Board should comply with the policies and procedures concerning asset disposals to ensure that all assets are properly accounted for and are disposed of properly. Views of Responsible Officials and Planned Corrective Action As assets become broken or obsolete, they are transferred to the warehouse for sale. This is evidenced by completing transfer forms which are signed by the principal or supervisor releasing the asset(s). Once an asset reaches the warehouse, it is segregated either by size or type. Large assets are normally itemized separately, while smaller items or computer related items are bundled together into a large gaylord box and sold as is. In this case, our auditors possessed signed transfer forms, but concluded during their review of disposals that the eventual asset itemizations were not sufficient or non-existent. Going forward, warehouse staff will commence their online auctions with full itemizations to show proof of disposal.

Condition There were inadequate controls over documentation of the number of students receiving snacks that are claimed for reimbursement. Criteria The School Board should implement policies and procedures to ensure that documentation is maintained to support all snacks claimed for reimbursement. Cause The School Board did not have internal control policies and procedures in place to ensure that all documentation supporting snack reimbursements was properly maintained. Effect Supporting documentation relating to snacks is not being properly maintained. Context A sample of three months for three schools was selected for audit from a population of 43 schools. The test found that support was not maintained for eight snacks served. Our sample was a non-statistical sample. Recommendation The School Board should implement policies and procedures to ensure that supporting documentation is maintained for all snacks served. Views of Responsible Officials and Planned Corrective Action While testing one school’s snack counts for one month, two of the days’ snack counts were not properly documented. This particular instance has been addressed with the related staff. Proper documentation will be maintained by all schools that serve Snacks under the respective program. Student counts will be recorded to substantiate subsequent reimbursements. On a monthly basis, these records will be monitored by an Area Supervisor. Prior to a reimbursement claim being submitted, the daily record will be reviewed and total meals will be verified for accuracy.

Condition There were inadequate controls over documentation in personnel files. Criteria The School Board should adhere to its policies and procedures to ensure that all required documentation is maintained in the personnel files. Cause The School Board did not adhere to its policies and procedures regarding personnel file documentation. Effect Supporting documentation relating to employee experience is not being properly maintained in the personnel files. Context A sample of 40 employees were selected for audit from a population of 263 employees. The test found that two employees did not have the proper documentation to support the years of experience for salary determination. Our sample was a non-statistical sample. Recommendation The School Board should adhere to their policies and procedures and ensure that all required documentation is maintained. Views of Responsible Officials and Planned Corrective Action Personnel files were internally audited by LPSS to ascertain whether we possessed relevant documents and to determine whether proper years of experience were granted. During the fiscal year under audit, Employee Services identified minimal errors regarding years of experience and made applicable corrections during the year. The outstanding minimal errors were tied to 2 out of 4400 plus employees. The minimal errors that were identified stemmed from the work of prior administrations ranging from 25 to 29 years ago.

Condition There were inadequate controls over payments for goods and services. Criteria The School Board should adhere to its policies and procedures to ensure that all payments are made after services are performed and based on actual costs. Cause The School Board did not adhere to their policies and procedures regarding purchasing documentation. Effect Payments were made in advance of the services being performed and were based on estimates. Context A sample of 58 disbursements were selected for audit from a population of 491 disbursements. The test found that 16 disbursements were paid in advance of services being performed. These payments were based on estimates. After obtaining the actual cost of the services performed it was determined that there was an excess paid of $99,284, which is questioned costs. Our sample was a non-statistical sample. Recommendation The School Board should adhere to their policies and procedures to ensure that all payments are made after services are performed and based on actual costs. Views of Responsible Officials and Planned Corrective Action LPSS followed guidance provided by the Louisiana Department of Education (LDOE) on a conference call that occurred on February 17, 2023, to issue final payments based on enrollment counts of children in April 2023 for the months of April, May and June 2023. This recommendation was provided to encourage LPSS to quickly request funds from their department. During the financial audit, the external auditors cited LPSS for not having documentation to substantiate certain payments that were based on LDOE’s guidance. Since then, additional training has already occurred on how to interact with unfounded guidance and how to review and interpret certain documents for payment processing. Regardless of LDOE recommendations in relation to this program, payments will not be made in advance of services rendered, and payments will not be based on estimates. Staff will strictly adhere to contractual guidelines and stipulations, purchasing policies and procedures.

Condition There were inadequate controls over documentation of the number of students receiving snacks that are claimed for reimbursement. Criteria The School Board should implement policies and procedures to ensure that documentation is maintained to support all snacks claimed for reimbursement. Cause The School Board did not have internal control policies and procedures in place to ensure that all documentation supporting snack reimbursements was properly maintained. Effect Supporting documentation relating to snacks is not being properly maintained. Context A sample of three months for three schools was selected for audit from a population of 43 schools. The test found that support was not maintained for eight snacks served. Our sample was a non-statistical sample. Recommendation The School Board should implement policies and procedures to ensure that supporting documentation is maintained for all snacks served. Views of Responsible Officials and Planned Corrective Action While testing one school’s snack counts for one month, two of the days’ snack counts were not properly documented. This particular instance has been addressed with the related staff. Proper documentation will be maintained by all schools that serve Snacks under the respective program. Student counts will be recorded to substantiate subsequent reimbursements. On a monthly basis, these records will be monitored by an Area Supervisor. Prior to a reimbursement claim being submitted, the daily record will be reviewed and total meals will be verified for accuracy.

Condition There were inadequate controls over documentation in personnel files. Criteria The School Board should adhere to its policies and procedures to ensure that all required documentation is maintained in the personnel files. Cause The School Board did not adhere to its policies and procedures regarding personnel file documentation. Effect Supporting documentation relating to employee experience is not being properly maintained in the personnel files. Context A sample of 40 employees were selected for audit from a population of 263 employees. The test found that two employees did not have the proper documentation to support the years of experience for salary determination. Our sample was a non-statistical sample. Recommendation The School Board should adhere to their policies and procedures and ensure that all required documentation is maintained. Views of Responsible Officials and Planned Corrective Action Personnel files were internally audited by LPSS to ascertain whether we possessed relevant documents and to determine whether proper years of experience were granted. During the fiscal year under audit, Employee Services identified minimal errors regarding years of experience and made applicable corrections during the year. The outstanding minimal errors were tied to 2 out of 4400 plus employees. The minimal errors that were identified stemmed from the work of prior administrations ranging from 25 to 29 years ago.

Condition There were inadequate controls over payments for goods and services. Criteria The School Board should adhere to its policies and procedures to ensure that all payments are made after services are performed and based on actual costs. Cause The School Board did not adhere to their policies and procedures regarding purchasing documentation. Effect Payments were made in advance of the services being performed and were based on estimates. Context A sample of 58 disbursements were selected for audit from a population of 491 disbursements. The test found that 16 disbursements were paid in advance of services being performed. These payments were based on estimates. After obtaining the actual cost of the services performed it was determined that there was an excess paid of $99,284, which is questioned costs. Our sample was a non-statistical sample. Recommendation The School Board should adhere to their policies and procedures to ensure that all payments are made after services are performed and based on actual costs. Views of Responsible Officials and Planned Corrective Action LPSS followed guidance provided by the Louisiana Department of Education (LDOE) on a conference call that occurred on February 17, 2023, to issue final payments based on enrollment counts of children in April 2023 for the months of April, May and June 2023. This recommendation was provided to encourage LPSS to quickly request funds from their department. During the financial audit, the external auditors cited LPSS for not having documentation to substantiate certain payments that were based on LDOE’s guidance. Since then, additional training has already occurred on how to interact with unfounded guidance and how to review and interpret certain documents for payment processing. Regardless of LDOE recommendations in relation to this program, payments will not be made in advance of services rendered, and payments will not be based on estimates. Staff will strictly adhere to contractual guidelines and stipulations, purchasing policies and procedures.

Condition There were inadequate controls over documentation in personnel files. Criteria The School Board should adhere to its policies and procedures to ensure that all required documentation is maintained in the personnel files. Cause The School Board did not adhere to its policies and procedures regarding personnel file documentation. Effect Supporting documentation relating to employee experience is not being properly maintained in the personnel files. Context A sample of 40 employees was selected for audit from a population of 268 employees. The test found that 8 employees did not have the proper documentation to support the years of experience for salary determination. There are $31,610 of questioned costs as a result of inadequate personnel documentation. Our sample was a non-statistical sample. Recommendation The School Board should adhere to their policies and procedures and ensure that all required documentation is maintained. Views of Responsible Officials and Planned Corrective Action Moving forward, Pam Belmore has been assigned the task of auditing personnel files to ensure the correct experience and education information is in the files. She is starting with the grant-funded positions first, per Anthony Mouton?s suggestion. Also, Madeline Guilbeau, Employee Services data Technician, has been given the role of checking certification requirements for non-teaching/non-instructional personnel. Some employees are given a grace period of 60 to 90 days to pass different certification/licensure exams. Ms. Guilbeau will be responsible for ensuring that these employees meet said requirements. She will begin with ensuring that all grant-funded employees are up to date and then move on to other employees.

Condition There were inadequate controls over payments for goods and services. Criteria The School Board should adhere to its policies and procedures to ensure that receipt of goods is properly documented prior to invoice payment. Cause The School Board did not adhere to its policies and procedures regarding purchasing documentation. Effect Supporting documentation relating to receipt of goods was not present for some disbursements. Context A sample of 40 disbursements was selected for audit from a population of 331 disbursements. The test found that 1 disbursement did not have documentation supporting the receipt of goods. There are $42,515 of questioned costs as a result of inadequate documentation for receipt of goods. Our sample was a non-statistical sample. Recommendation The School Board should adhere to their policies and procedures and ensure that all required documentation is maintained. Views of Responsible Officials and Planned Corrective Action To ensure that receipt of goods is properly documented prior to invoice payment, the following process will be implemented effective immediately: (1) As of 7/1/2022, inventory received by each school site will be verified for documentation of receipt (signature) by CNS Office Coordinator/ Accounts Payable, (2) Inventory received without documentation of receipt will be verified with computer entry of inventory received by Area Supervisor assigned to that school; receiving date, quantity received, and price will be verified and signature will be obtained, (3) Documentation of receipt for inventory received that has not been processed for payment will be reviewed by Area Supervisor prior to submission to CNS Office Coordinator for payment, (4) School Site Cafeteria Managers and Technicians have received notification of and training on this requirement, (5) Area Supervisors will review all inventory receipts when conducting routine monitoring, and (6) The CNS Office Coordinator will be the final check to ensure that receipt of goods is properly documented.

Condition The School Board did not report expenditures in the amount of $1,403,046 for the ESSERF II Formula grant on its Schedule of Expenditures of Federal Awards for the year ending June 30, 2021. Criteria OMB Circular A-133, section 205(a) states that ?determination of when a Federal award is expended should be based on when the activity related to the award occurs.? Additionally, OMB Circular A-133, section 300(d) states that ?the auditee shall prepare appropriate financial statements, including the schedule of expenditures in Federal awards.? Cause The School Board did not have internal control policies and procedures in place to properly track reimbursable expenditures in order to recognize them as federal expenditures in the year in which they were incurred. Effect The School Board did not properly report expenditures on the Schedule of Expenditures of Federal Awards. Context The School Board did not properly identify all federal expenditures in the year incurred. Recommendation The School Board should implement policies and procedures to ensure that all expenditures under grant programs are accurately tracked and captured for proper presentation within the Schedule of Expenditures of Federal Awards. Views of Responsible Officials and Planned Corrective Action Accountants shall receive training to ensure all related expenditures are reported on the Schedule of Expenditures of Federal Awards (SEFA) in each respective year. Each Accountant will review their respective grant expenditures and ensure that all applicable expenditures are recorded properly for accuracy and completeness. A second reviewer will ascertain the accuracy of the recorded expenditures on the SEFA.

Condition The School Board requested grant reimbursement for amounts paid by the self-insurance fund to cover claims for COVID-19 hospitalizations. Criteria In accordance with grant guidelines, the funds may be used to implement public health protocols, such as COVID-19 testing and vaccination, meant to decrease the spread of COVID-19. Payment for hospitalizations to treat infections does not appear to be allowable within the grant guidelines of implementing public health protocols. Cause The School Board did not have internal control policies and procedures in place to ensure that funds were spent in accordance with grant guidelines. Effect The School Board expended grant funds for an activity that does not appear to be allowable under the grant guidelines. Context A sample of 65 disbursements was selected for audit from a population of 233 disbursements. The test found that 1 disbursement was a payment made to reimburse the self-insurance fund for amounts paid for claims related to COVID-19 hospitalization. There are $756,609 of questioned costs as a result of this reimbursement. Our sample was a non-statistical sample. Recommendation The School Board should implement policies and procedures to ensure that all expenditures under grant programs are allowable under grant guidelines. Views of Responsible Officials and Planned Corrective Action The Lafayette Parish School System (LPSS) Self-Funded Group Health Insurance fund paid $756,609 in hospitalization claims that were directly caused by Covid-19 according to the hospitals that provided hospitalization services to our employees. Had the Covid-19 pandemic not occurred, LPSS would not have experienced an increase in claim expenses that were directly caused by Covid-19 which is categorically tracked by hospitals. During the covid pandemic, LPSS had several conference calls with Louisiana Department of Education (LDOE) representatives concerning the allowability of Covid Testing, Vaccinations and Covid Hospitalizations. The objective was to remain compliant with all federal guidelines concerning these special funds. After many hours of conference calls and consultations with LDOE staff, we were informed these expenditures were allowed in addition to a written response. In anticipation of these charges, LPSS submitted an ESSER II budget to the LDOE, which included Covid Hospitalization claims, and the budget was approved. Based on LDOE?s budget approval and prior verbal and written responses, LPSS staff believed they were clear to proceed and recover from these unplanned Covid-19 hospitalization expenditures. As a result of this audit finding, LPSS will appeal to the LDOE and the Federal Government for relief and an eventual inclusion of guidelines for self-funded entities such as LPSS. Unlike other school districts, LPSS is self-insured and assumes the financial risks and obligation of each employee?s medical and prescription claims. We believe the writers of the federal guidelines / FAQs may not have been privy to the operational affairs of school districts that are self-insured to carve out language specific to our operations. On December 13, 2022, a request for review was sent to LDOE in response to this audit finding. The LDOE plans to utilize their resources and contacts while enlisting the help of their contracted attorneys who specialize in federal grants to provide an initial opinion on the allowability of Covid Hospitalization expenditures. It may take several months before an official response is provided by the Federal Government.

Condition There were inadequate controls over documentation in personnel files. Criteria The School Board should adhere to its policies and procedures to ensure that all required documentation is maintained in the personnel files. Cause The School Board did not adhere to its policies and procedures regarding personnel file documentation. Effect Supporting documentation relating to education necessary to meet minimum job requirements and employee experience is not being properly maintained in the personnel files. Context A sample of 55 employees was selected for audit from a population of 55 employees. The test found that 4 employees did not have the proper documentation to support the years of experience for salary determination or minimum education to meet job requirements. There are $37,691 of questioned costs as a result of inadequate personnel documentation. Our sample was a non-statistical sample. Recommendation The School Board should adhere to their policies and procedures and ensure that all required documentation is maintained. Views of Responsible Officials and Planned Corrective Action Moving forward, Pam Belmore has been assigned the task of auditing personnel files to ensure the correct experience and education information is in the files. She is starting with the grant-funded positions first, per Anthony Mouton?s suggestion. Also, Madeline Guilbeau, Employee Services data Technician, has been given the role of checking certification requirements for non-teaching/non-instructional personnel. Some employees are given a grace period of 60 to 90 days to pass different certification/licensure exams. Ms. Guilbeau will be responsible for ensuring that these employees meet said requirements. She will begin with ensuring that all grant-funded employees are up to date and then move on to other employees.

Condition Salary increases approved by the Board were incorrectly calculated and paid. Criteria The Board approved a $750 teacher pay increase effective November 1, 2021, and a $750 instructional employee pay increase effective February 1, 2022. Cause The pay increases became effective during the fiscal year and the calculation to prorate the increase was incorrectly performed. Effect The School Board incorrectly calculated and paid the salary increase to employees. Context A sample of 55 employees was selected for audit from a population of 55 employees. The test found that 43 employees were paid incorrectly. There are $6,403 of questioned costs as a result of incorrect salary calculations. Our sample was a non-statistical sample. Recommendation The School Board should ensure that salary increases given during the fiscal year are correctly calculated and paid. Views of Responsible Officials and Planned Corrective Action The Employee Services Department will have all salaries reviewed after they are set up in the accounting system. Connie Morvant, HR Generalist, will complete this function moving forward. All 2022-2023 hires have been audited and corrected. John Mouton, Director of Employee Services, and Eryn Hollier, Coordinator of Employee Services will review the salary schedule when updates are made. Also, when having to calculate salary increases or raises for a specific group of people during the year, the raise will be calculated according to the individual employees? number of working days remaining on their contract for the year. Employee Services will also consult Business Services as we have done in the past to ensure the raises and salaries are calculated correctly.

Condition There were inadequate controls over documentation in personnel files. Criteria The School Board should adhere to its policies and procedures to ensure that all required documentation is maintained in the personnel files. Cause The School Board did not adhere to its policies and procedures regarding personnel file documentation. Effect Supporting documentation relating to employee experience is not being properly maintained in the personnel files. Context A sample of 40 employees was selected for audit from a population of 268 employees. The test found that 8 employees did not have the proper documentation to support the years of experience for salary determination. There are $31,610 of questioned costs as a result of inadequate personnel documentation. Our sample was a non-statistical sample. Recommendation The School Board should adhere to their policies and procedures and ensure that all required documentation is maintained. Views of Responsible Officials and Planned Corrective Action Moving forward, Pam Belmore has been assigned the task of auditing personnel files to ensure the correct experience and education information is in the files. She is starting with the grant-funded positions first, per Anthony Mouton?s suggestion. Also, Madeline Guilbeau, Employee Services data Technician, has been given the role of checking certification requirements for non-teaching/non-instructional personnel. Some employees are given a grace period of 60 to 90 days to pass different certification/licensure exams. Ms. Guilbeau will be responsible for ensuring that these employees meet said requirements. She will begin with ensuring that all grant-funded employees are up to date and then move on to other employees.

Condition There were inadequate controls over payments for goods and services. Criteria The School Board should adhere to its policies and procedures to ensure that receipt of goods is properly documented prior to invoice payment. Cause The School Board did not adhere to its policies and procedures regarding purchasing documentation. Effect Supporting documentation relating to receipt of goods was not present for some disbursements. Context A sample of 40 disbursements was selected for audit from a population of 331 disbursements. The test found that 1 disbursement did not have documentation supporting the receipt of goods. There are $42,515 of questioned costs as a result of inadequate documentation for receipt of goods. Our sample was a non-statistical sample. Recommendation The School Board should adhere to their policies and procedures and ensure that all required documentation is maintained. Views of Responsible Officials and Planned Corrective Action To ensure that receipt of goods is properly documented prior to invoice payment, the following process will be implemented effective immediately: (1) As of 7/1/2022, inventory received by each school site will be verified for documentation of receipt (signature) by CNS Office Coordinator/ Accounts Payable, (2) Inventory received without documentation of receipt will be verified with computer entry of inventory received by Area Supervisor assigned to that school; receiving date, quantity received, and price will be verified and signature will be obtained, (3) Documentation of receipt for inventory received that has not been processed for payment will be reviewed by Area Supervisor prior to submission to CNS Office Coordinator for payment, (4) School Site Cafeteria Managers and Technicians have received notification of and training on this requirement, (5) Area Supervisors will review all inventory receipts when conducting routine monitoring, and (6) The CNS Office Coordinator will be the final check to ensure that receipt of goods is properly documented.

Condition The School Board did not report expenditures in the amount of $1,403,046 for the ESSERF II Formula grant on its Schedule of Expenditures of Federal Awards for the year ending June 30, 2021. Criteria OMB Circular A-133, section 205(a) states that ?determination of when a Federal award is expended should be based on when the activity related to the award occurs.? Additionally, OMB Circular A-133, section 300(d) states that ?the auditee shall prepare appropriate financial statements, including the schedule of expenditures in Federal awards.? Cause The School Board did not have internal control policies and procedures in place to properly track reimbursable expenditures in order to recognize them as federal expenditures in the year in which they were incurred. Effect The School Board did not properly report expenditures on the Schedule of Expenditures of Federal Awards. Context The School Board did not properly identify all federal expenditures in the year incurred. Recommendation The School Board should implement policies and procedures to ensure that all expenditures under grant programs are accurately tracked and captured for proper presentation within the Schedule of Expenditures of Federal Awards. Views of Responsible Officials and Planned Corrective Action Accountants shall receive training to ensure all related expenditures are reported on the Schedule of Expenditures of Federal Awards (SEFA) in each respective year. Each Accountant will review their respective grant expenditures and ensure that all applicable expenditures are recorded properly for accuracy and completeness. A second reviewer will ascertain the accuracy of the recorded expenditures on the SEFA.

Condition The School Board requested grant reimbursement for amounts paid by the self-insurance fund to cover claims for COVID-19 hospitalizations. Criteria In accordance with grant guidelines, the funds may be used to implement public health protocols, such as COVID-19 testing and vaccination, meant to decrease the spread of COVID-19. Payment for hospitalizations to treat infections does not appear to be allowable within the grant guidelines of implementing public health protocols. Cause The School Board did not have internal control policies and procedures in place to ensure that funds were spent in accordance with grant guidelines. Effect The School Board expended grant funds for an activity that does not appear to be allowable under the grant guidelines. Context A sample of 65 disbursements was selected for audit from a population of 233 disbursements. The test found that 1 disbursement was a payment made to reimburse the self-insurance fund for amounts paid for claims related to COVID-19 hospitalization. There are $756,609 of questioned costs as a result of this reimbursement. Our sample was a non-statistical sample. Recommendation The School Board should implement policies and procedures to ensure that all expenditures under grant programs are allowable under grant guidelines. Views of Responsible Officials and Planned Corrective Action The Lafayette Parish School System (LPSS) Self-Funded Group Health Insurance fund paid $756,609 in hospitalization claims that were directly caused by Covid-19 according to the hospitals that provided hospitalization services to our employees. Had the Covid-19 pandemic not occurred, LPSS would not have experienced an increase in claim expenses that were directly caused by Covid-19 which is categorically tracked by hospitals. During the covid pandemic, LPSS had several conference calls with Louisiana Department of Education (LDOE) representatives concerning the allowability of Covid Testing, Vaccinations and Covid Hospitalizations. The objective was to remain compliant with all federal guidelines concerning these special funds. After many hours of conference calls and consultations with LDOE staff, we were informed these expenditures were allowed in addition to a written response. In anticipation of these charges, LPSS submitted an ESSER II budget to the LDOE, which included Covid Hospitalization claims, and the budget was approved. Based on LDOE?s budget approval and prior verbal and written responses, LPSS staff believed they were clear to proceed and recover from these unplanned Covid-19 hospitalization expenditures. As a result of this audit finding, LPSS will appeal to the LDOE and the Federal Government for relief and an eventual inclusion of guidelines for self-funded entities such as LPSS. Unlike other school districts, LPSS is self-insured and assumes the financial risks and obligation of each employee?s medical and prescription claims. We believe the writers of the federal guidelines / FAQs may not have been privy to the operational affairs of school districts that are self-insured to carve out language specific to our operations. On December 13, 2022, a request for review was sent to LDOE in response to this audit finding. The LDOE plans to utilize their resources and contacts while enlisting the help of their contracted attorneys who specialize in federal grants to provide an initial opinion on the allowability of Covid Hospitalization expenditures. It may take several months before an official response is provided by the Federal Government.

Condition There were inadequate controls over documentation in personnel files. Criteria The School Board should adhere to its policies and procedures to ensure that all required documentation is maintained in the personnel files. Cause The School Board did not adhere to its policies and procedures regarding personnel file documentation. Effect Supporting documentation relating to education necessary to meet minimum job requirements and employee experience is not being properly maintained in the personnel files. Context A sample of 55 employees was selected for audit from a population of 55 employees. The test found that 4 employees did not have the proper documentation to support the years of experience for salary determination or minimum education to meet job requirements. There are $37,691 of questioned costs as a result of inadequate personnel documentation. Our sample was a non-statistical sample. Recommendation The School Board should adhere to their policies and procedures and ensure that all required documentation is maintained. Views of Responsible Officials and Planned Corrective Action Moving forward, Pam Belmore has been assigned the task of auditing personnel files to ensure the correct experience and education information is in the files. She is starting with the grant-funded positions first, per Anthony Mouton?s suggestion. Also, Madeline Guilbeau, Employee Services data Technician, has been given the role of checking certification requirements for non-teaching/non-instructional personnel. Some employees are given a grace period of 60 to 90 days to pass different certification/licensure exams. Ms. Guilbeau will be responsible for ensuring that these employees meet said requirements. She will begin with ensuring that all grant-funded employees are up to date and then move on to other employees.

Condition Salary increases approved by the Board were incorrectly calculated and paid. Criteria The Board approved a $750 teacher pay increase effective November 1, 2021, and a $750 instructional employee pay increase effective February 1, 2022. Cause The pay increases became effective during the fiscal year and the calculation to prorate the increase was incorrectly performed. Effect The School Board incorrectly calculated and paid the salary increase to employees. Context A sample of 55 employees was selected for audit from a population of 55 employees. The test found that 43 employees were paid incorrectly. There are $6,403 of questioned costs as a result of incorrect salary calculations. Our sample was a non-statistical sample. Recommendation The School Board should ensure that salary increases given during the fiscal year are correctly calculated and paid. Views of Responsible Officials and Planned Corrective Action The Employee Services Department will have all salaries reviewed after they are set up in the accounting system. Connie Morvant, HR Generalist, will complete this function moving forward. All 2022-2023 hires have been audited and corrected. John Mouton, Director of Employee Services, and Eryn Hollier, Coordinator of Employee Services will review the salary schedule when updates are made. Also, when having to calculate salary increases or raises for a specific group of people during the year, the raise will be calculated according to the individual employees? number of working days remaining on their contract for the year. Employee Services will also consult Business Services as we have done in the past to ensure the raises and salaries are calculated correctly.

2021-004 Fiscal year finding initially occurred: 2021 Child Nutrition Cluster (10.555 and 10.559) Condition There were inadequate controls over documentation in personnel files. Criteria The School Board should adhere to its policies and procedures to ensure that all required documentation is maintained in the personnel files. Cause The School Board did not adhere to its policies and procedures regarding personnel file documentation. Effect Supporting documentation relating to education necessary to meet minimum job requirements and the prior experience granted to the applicant upon hiring are not being properly maintained in the personnel files. Context A sample of 40 employees was selected for audit from a population of 280 employees. The test found that 6 employees did not have the proper documentation to support experience granted to the applicant upon hiring or minimum job requirement eligibility. There are $126,093 of questioned costs as a result of inadequate personnel documentation. Our sample was a non-statistical sample. Recommendation The School Board should adhere to their policies and procedures and ensure that all required documentation is maintained. Views of Responsible Officials and Planned Corrective Action Employee Services will be requesting a part time project clerical assistant position to assist in the audit of employee years of experience. Verifications will be performed to ensure that the years of experience in the personnel files matches the employee pay file. Employee Services will review the active job descriptions to ensure that the education requirements are adequate for each position. The job descriptions for cafeteria technicians and custodians will be updated. By updating the job descriptions technicians and custodians will be able to take a reading test and satisfy the education requirements.

2021-005 Fiscal year finding initially occurred: 2021 Child Nutrition Cluster (10.555 and 10.559) Condition There were inadequate internal control policies and procedures over the setup of retirement rates to be charged. Criteria The School Board should implement policies and procedures to ensure that errors in rates being charged are detected and corrected timely. Cause Internal control policies and procedures were not implemented to detect and correct errors related to retirement rates being charged. Effect The incorrect rate was paid for the employer portion of retirement for the School Employee Retirement System and not detected and corrected timely. Recommendation The School Board should implement control policies and procedures to ensure that any changes in retirement rates are setup timely and accurately. Views of Responsible Officials and Planned Corrective Action The payroll department will assume the responsibility of updating retirement rate changes at the beginning of each fiscal year.

2021-006 Fiscal year finding initially occurred: 2021 Education Stabilization Fund (84.425B, 84.425C, 84.425D and 84.425U) Condition There were inadequate internal control policies and procedures over the setup of retirement rates to be charged. Criteria The School Board should implement policies and procedures to ensure that errors in rates being charged are detected and corrected timely. Cause Internal control policies and procedures were not implemented to detect and correct errors related to retirement rates being charged. Effect The incorrect rate was paid for the employer portion of retirement for the School Employee Retirement System and not detected and corrected timely. Recommendation The School Board should implement control policies and procedures to ensure that any changes in retirement rates are setup timely and accurately. Views of Responsible Officials and Planned Corrective Action The payroll department will assume the responsibility of updating retirement rate changes at the beginning of each fiscal year.

2021-007 Fiscal year finding initially occurred: 2021 Child Nutrition Cluster (10.555 and 10.559) Condition There were inadequate controls over documentation in personnel files. Criteria The School Board should adhere to its policies and procedures to ensure that all required documentation is maintained in the personnel files. Cause The School Board did not adhere to its policies and procedures regarding personnel file documentation. Effect Supporting documentation relating to education necessary to meet minimum job requirements and the prior experience granted to the applicant upon hiring are not being properly maintained in the personnel files. Context A sample of 40 employees was selected for audit from a population of 280 employees. The test found that 6 employees did not have the proper documentation to support experience granted to the applicant upon hiring or minimum job requirement eligibility. There are $126,093 of questioned costs as a result of inadequate personnel documentation. Our sample was a non-statistical sample. Recommendation The School Board should adhere to their policies and procedures and ensure that all required documentation is maintained. Views of Responsible Officials and Planned Corrective Action Employee Services will be requesting a part time project clerical assistant position to assist in the audit of employee years of experience. Verifications will be performed to ensure that the years of experience in the personnel files matches the employee pay file. Employee Services will review the active job descriptions to ensure that the education requirements are adequate for each position. The job descriptions for cafeteria technicians and custodians will be updated. By updating the job descriptions technicians and custodians will be able to take a reading test and satisfy the education requirements.

2021-008 Fiscal year finding initially occurred: 2021 Child Nutrition Cluster (10.555 and 10.559) Condition There were inadequate internal control policies and procedures over the setup of retirement rates to be charged. Criteria The School Board should implement policies and procedures to ensure that errors in rates being charged are detected and corrected timely. Cause Internal control policies and procedures were not implemented to detect and correct errors related to retirement rates being charged. Effect The incorrect rate was paid for the employer portion of retirement for the School Employee Retirement System and not detected and corrected timely. Recommendation The School Board should implement control policies and procedures to ensure that any changes in retirement rates are setup timely and accurately. Views of Responsible Officials and Planned Corrective Action The payroll department will assume the responsibility of updating retirement rate changes at the beginning of each fiscal year.

2021-009 Fiscal year finding initially occurred: 2021 Education Stabilization Fund (84.425B, 84.425C, 84.425D and 84.425U) Condition There were inadequate internal control policies and procedures over the setup of retirement rates to be charged. Criteria The School Board should implement policies and procedures to ensure that errors in rates being charged are detected and corrected timely. Cause Internal control policies and procedures were not implemented to detect and correct errors related to retirement rates being charged. Effect The incorrect rate was paid for the employer portion of retirement for the School Employee Retirement System and not detected and corrected timely. Recommendation The School Board should implement control policies and procedures to ensure that any changes in retirement rates are setup timely and accurately. Views of Responsible Officials and Planned Corrective Action The payroll department will assume the responsibility of updating retirement rate changes at the beginning of each fiscal year.

DEPARTMENT OF HEALTH AND HUMAN SERVICES Temporary Assistance for Needy Families (TANF) (93.558) See compliance finding 2019-004.

DEPARTMENT OF HEALTH AND HUMAN SERVICES: Temporary Assistance for Needy Families (TANF) (93.558) Condition Enrollment reports required by the grantor were not accurately prepared. This finding was reported in the June 30, 2018 financial report. Criteria The reporting guidelines of the TANF LA4 Early Childhood Program require enrollment information to be reported to the grantor on a monthly basis. Cause There were inadequate policies and procedures in place to ensure that the required reporting was accurately prepared. Effect The School Board may have improperly reported the number of students who obtained the required attendance to the grantor. Recommendation Adequate policies and procedures should be established and adhered to in order to ensure compliance with the enrollment reporting guidelines of the program. Views of Responsible Officials and Planned Corrective Action The School Board agrees with the finding and have adopted a new attendance reporting process. This new process will assist the district in reporting attendance with 100% accuracy.

DEPARTMENT OF HEALTH AND HUMAN SERVICES: Temporary Assistance for Needy Families (TANF) (93.558) Condition Information necessary for eligibility determination was not properly obtained, analyzed, and/or documented in the student eligibility files. This finding was reported in the June 30, 2018 financial report. Criteria Code of Federal Regulation Title 45 Section 260.31 requires that only financially needy families receive TANF assistance. Cause There were inadequate policies and procedures in place to ensure that all information necessary for eligibility determination was properly obtained, analyzed, and/or documented in the student eligibility files. Effect The School Board may have improperly allowed benefits for families that were not eligible for the program. Context A sample of 138 students was selected for audit from a population of 821 students. The test found that 23 student files did not have the required eligibility documentation maintained. There are $58,125 of questioned costs as a result of inadequate eligibility documentation. Our sample was a non-statistical sample. Recommendation Adequate policies and procedures should be established and adhered to in order to ensure compliance with the eligibility guidelines of the program. Views of Responsible Officials and Planned Corrective Action The School Board agrees with this finding and will make adjustments to the online application system which should resolve this issue.

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