Pointe Coupee Parish School BoardLocal Government

2025-002 Special Tests and Provision - School Improvement Plan U.S. DEPARTMENT OF EDUCATION passed through the Louisiana Department of Education 84.010A – Title I 2024-2025 Award Year Grant No. 28-25-T1-39 and 28-24-RD19-39 Criteria: The School Board must comply with federal statutes, regulations, and the terms and conditions of federal awards. Title I federal program requirements provide that students enrolled in a school that has earned a letter grade of “F” and designated academically unacceptable must be offered students school choice option in the school’s improvement action plan. Universe / Population: The universe / population is the testing of five school report cards. The auditors tested all five schools. One of the five schools tested was deemed noncompliant. Condition: During the review of the school improvement action plan for the one Title I school that earned a letter grade of “F,” it was noted that the improvement plan did not include procedures to offer school choice to students as required. Cause: Management did not have a documented process to ensure all required components are included in school improvement action plans when a school earns an “F” letter grade. Effect: Students were not formally offered school choice in accordance with applicable Title I requirements, and the School Board may be exposed to noncompliance with federal award requirements. Questioned Costs: None. Recommendation: The School Board should update its School Improvement Action Plan template and review procedures to ensure required school choice provisions are included when applicable and maintain documentation of timely notification and implementation. Repeat Finding: No. View of Responsible Official: Management will revise the School Improvement Action Plan for the applicable to include school choice procedures, implement a review and approval checklist to verify required components are included, and retain supporting documentation of notifications and any transfers, as applicable.

2025-003 Special Tests and Provision – Cohort Removal U.S. DEPARTMENT OF EDUCATION passed through the Louisiana Department of Education 84.010A – Title I 2024-2025 Award Year Grant No. 28-25-T1-39 and 28-24-RD19-39 Criteria: The School Board must report graduation rate data for all public high schools at the school level using the 4-year adjusted cohort rate under 34 CFR section 200.19(b)(1)(i)-(iv)). Only students who earn a regular high school diploma may be counted as a graduate for purposes of calculating the 4-year adjusted cohort graduation rate. To remove a student from the cohort, a school must confirm, in writing, that the student transferred out, emigrated to another country, or is deceased. The School Board is responsible for assigning exit codes to any student who leaves. Only specific exit codes are deemed legitimate reasons for leaving and will cause the leaver to not be included in the cohort’s graduation index calculations. These codes relate to death, transfers out of the state or country, transfers to nonpublic schools, transfers to home study/in-school private schooling, and transfers to Early College Admissions Programs. Specific documentation must be maintained for students to be considered legitimate leavers from the cohort. The School Board is also responsible for developing a system of internal controls to ensure the proper documentation is retained for all leavers of the cohort. Universe / Population: The sample of cohort removals was selected from a universe that includes all students that left the school due to transferring to a diploma awarding school or program, death, or emigration to another country. Based on these requirements, the total universe is 152 students who are considered leavers of the cohort. This is also considered the population size. Based on sampling guidance for audits performed under the Uniform Guidance, a non-statistical sample of 16 leavers was selected for testing. Condition: It was determined in the testing of internal controls and compliance with respect to 34 CFR §200.19(b), 2 of 16 leavers had exceptions to the required documentation set forth by the Louisiana Administrative Code Title 28, Part LXXXIII, Chapter 6, §611. Cause: The School Board has relied on the individual schools to acquire and retain all documentation related to the removal of students. Effect: Without proper internal controls over the graduation rate cohort reporting process, documentation may not be properly retained, and therefore the School Board may be noncompliant with the requirements of the Title I program. Questioned Costs: None. Recommendation: The School Board should establish procedures at the school and program administration levels to ensure appropriate documentation is obtained related to removal of students from a cohort in accordance with Louisiana Administrative Code Title 28, Part LXXXIII, Chapter 6, §611. Repeat Finding: No. View of Responsible Official: The School Board will establish and implement standardized procedures at both the school and central office levels to ensure required documentation is obtained and retained for all students removed from the graduation cohort. The School Board will provide guidance and training to school personnel on acceptable exit codes and documentation requirements and will implement periodic monitoring to verify compliance with applicable federal and state regulations.

2023-002 Procurement U.S. DEPARTMENT OF EDUCATION passed through the Louisiana Department of Education 84.027A, 84.173A Special Education Cluster 2022-2023 Award Year Grant No. 28-22-2C-39 Criteria: The Uniform Guidance federal regulations (200.320) require, among other things, that procedure for small purchases of goods and services in an amount between $10,000 to $250,000 follow the small purchase procedures and obtain an adequate number of prices/quotes. The Uniform Guidance federal regulations require when a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.955, is not suspended or debarred or otherwise excluded from participating in covered transactions. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS), (2) collecting certification from entity, (3) adding a clause or condition within the contract with the entity. In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal award entity must contain provisions that are outlined in Appendix II to Part 200, namely: A.) All contracts > $10,000 must address termination for cause and convenience by the nonfederal entity including the manner by which it will be affected and the basis for settlement. B.) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet the definition of "federally assisted construction contract" in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1.4(b ), in accordance with Executive Order 11246, "Equal Employment Opportunity" (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive Order 11375, "'Amending Executive Order 11246 Relating to Equal Employment Opportunity," and implementing regulations at 41 CFR part 60, '"Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor." C.) Debarment and Suspension (Executive Orders 12549 and 12689)-A contract award (see 2 CFR 180.220) must not be made to parties listed on the government wide Excluded Parties List System in the System for Award Management (SAM), in accordance with the 0MB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR Part 1986 Comp., p. 189) and 12689 (3 CFR Part 1989 Comp., p. 235), "Debarment and Suspension." The Excluded Parties List System in SAM contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: While testing compliance with the federal procurement regulations, 3 vendors were identified with expenditures greater than $10,000 and less than $250,000 and testing was performed relating to the documentation to support the procurement process. Of the 3 vendors, 1 provided professional services and 2 provided equipment and materials and supplies during the year ended June 30, 2023. Compliance testing focused on the proper renewing and awarding of the contracts to determine compliance with the procurement regulations. The 3 contracts totaled $62,620. There was no evidence provided to demonstrate that quotes and prices were obtained for 1 of the 3 vendors or providers as required by Federal procurement regulations. Also, no evidence was provided to demonstrate that 3 of the 3 vendors were appropriately checked for suspension and debarment. Lastly, provisions of Appendix II of the Uniform Guidance were not included in 3 of the 3 contracts with federal dollars. Cause: Personnel administering the grants and those in the School Board purchasing department did not execute and enforce the revised purchasing policy containing the Uniform Guidance requirements. Effect: The School Board is not in compliance with the requirements of the Uniform Guidance Procurement regulations with respect to these purchases. Questioned Costs: None. Recommendation: We recommend for the School Board to more fully implement and follow its revised policies and procedures for purchases made with federal awards so that these required federal procurement regulations are followed. We recommend that the School Board include Appendix II to Part II Summary as applicable in their future contracts. Repeat Finding: No.

2022-001 Program Income U.S. DEPARTMENT OF AGRICULTURE passed through the Louisiana Department of Education 10.553, 10.555, 10.559 Child Nutrition Cluster COVID-19 ? National School Lunch Program (10.555) 2021-2022 Award Year Grant No. 2004-023790207 Criteria: The Net Cash Resources should be below the 3 Months? Average Expenses for the federal program. Condition: The School Board maintained Net Cash Resources in excess of the 3 Months? Average Expenses at June 30, 2022. Cause: The School Board did not properly monitor and make adjustments to its Net Cash Resources and expenses. Effect: The School Board is not in compliance with the requirement to maintain Net Cash Resources below the 3 Months? Average of expenses. Questioned Costs: None. Recommendation: The School Board should take corrective steps to reduce its Net Cash Resources to no more than the 3 Months? Average Expenses and develop a timeframe for making such reduction. Repeat Finding: Yes. View of Responsible Official: We have been and are budgeting to spend more money in 2023 than we have collected or will collect in revenues. We are anticipating a deficit in 2023 for the Child Nutrition Program. This will cause our Net Cash Resources to decrease.

2021-002 Program Income U.S. DEPARTMENT OF AGRICULTURE passed through the Louisiana Department of Education 10.553, 10.555, 10.559 Child Nutrition Cluster COVID-19 ? National School Lunch Program (10.555) 2020-2021 Award Year Grant No. 2004-023790207 Criteria: The Net Cash Resources should be below the 3 Months? Average Expenses for the federal program. Condition: The School Board maintained Net Cash Resources in excess of the 3 Months? Average Expenses at June 30, 2021. Cause: The School Board did not properly monitor and make adjustments to its Net Cash Resources and expenses. Effect: The School Board is not in compliance with the requirement to maintain Net Cash Resources below the 3 Months? Average of expenses. Questioned Costs: None. Recommendation: The School Board should take corrective steps to reduce its Net Cash Resources to no more than the 3 Months? Average Expenses and develop a timeframe for making such reduction. Repeat Finding: Yes. View of Responsible Official: We have been and are budgeting to spend more money in 2022 than we have collected or will collect in revenues. We are anticipating a deficit in 2022 for the Child Nutrition Program. This will cause our Net Cash Resources to decrease. Also, we are planning an accelerated summer school program in June 2022. We are anticipating a higher student attendance than usual, which will require us to purchase more supplies to prepare for it.

2020-001 Program Income U.S. DEPARTMENT OF AGRICULTURE passed through the Louisiana Department of Education 10.553, 10.555 Child Nutrition Cluster 2019-2020 Award Year Grant No. 2004-023790207 Criteria: The Net Cash Resources should be below the 3 Months? Average Expenses for the federal program. Condition: The School Board maintained Net Cash Resources in excess of the 3 Months? Average Expenses at June 30, 2020. Cause: The School Board did not properly monitor and make adjustments to its Net Cash Resources and expenses. Effect: The School Board is not in compliance with the requirement to maintain Net Cash Resources below the 3 Months? Average of expenses. Questioned Costs: None. Universe/ Population Size: N/A Sample Size: N/A Recommendation: The School Board should take corrective steps to reduce its Net Cash Resources to no more than the 3 Months? Average Expenses and develop a timeframe for making such reduction. Repeat Finding: No. View of Responsible Official: We have been and are budgeting to spend more money in 2021 than we have collected or will collect in revenues. We are anticipating a deficit in 2021 for the Child Nutrition Program. This will cause our Net Cash Resources to decrease. Also, we are planning an accelerated summer school program in June 2021. We are anticipating a higher student attendance than usual, which will require us to purchase more supplies to prepare for it. We did not have a summer school program in 2020.

2020-002 Procurement U.S. DEPARTMENT OF EDUCATION passed through the Louisiana Department of Education 84.027A, 84.173A Special Education Cluster 2019-2020 Award Year Grant No. 28-20-B1-39 Criteria: The Uniform Guidance federal regulations were fully effective as of December 26, 2017. The regulations (200.320) require, among other things, that procurement for small purchases of goods and services in an amount between the $10,000 to $250,000, follow the small purchase procedures and obtain an adequate number of prices\quotes be obtained. The Uniform Guidance federal regulations require when a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995, is not suspended or debarred or otherwise excluded from participating in covered transactions. This verification may be accomplished by (1) by checking the Excluded Parties List System (EPLS), (2) collecting certification from entity, (3) adding a clause or condition within the contract with the entity. In addition to other provisions required by the Federal agency or non- Federal entity, all contracts made by the non-Federal award entity Federal award must contain provisions that are outlined in Appendix II to Part 200, namely: A.) All contracts > $10,000 must address termination for cause and convenience by the non-federal entity including the manner by which it will be effected and the basis for settlement. B.) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet the definition of ''federally assisted construction contract'' in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1.4(b), in accordance with Executive Order 11246, ''Equal Employment Opportunity'' (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive Order 11375, ?'Amending Executive Order 11246 Relating to Equal Employment Opportunity,? and implementing regulations at 41 CFR part 60, '?Office of Federal Contract Compliance Programs, Equal Employment Opportunity, Department of Labor.? C.) Debarment and Suspension (Executive Orders 12549 and 12689)?A contract award (see 2 CFR 180.220) must not be made to parties listed on the government wide Excluded Parties List System in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR Part 1986 Comp., p. 189) and 12689 (3 CFR Part 1989 Comp., p. 235), ``Debarment and Suspension.?? The Excluded Parties List System in SAM contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549. Condition: While testing compliance with the federal procurement regulations, 4 vendors were identified with expenditures greater than $10,000 and less than $250,000 and testing was performed relating to the documentation to support the procurement process. These 4 vendors provided professional services during year ended June 30, 2020. Compliance testing focused on the proper renewing and awarding of the contracts to determine compliance with the procurement regulations. The 4 contracts totaled $67,315. There was no evidence provided to demonstrate that quotes and prices were obtained for 3 of the 4 vendors or providers as required by Federal procurement regulations. Also, no evidence was provided to demonstrate that 3 of the 4 vendors were appropriately checked for suspension and debarment. And finally, the identified 3 contracts did not contain the provisions required by Appendix II to Part 200. Cause: Personnel administering the grants and those in the School Board purchasing department did not execute and enforce the revised purchasing policy containing the new Uniform Guidance requirements. Effect: The School Board is not in compliance with the requirements of the Uniform Guidance Procurement regulations. Questioned Costs: None. Universe/ Population Size: The total universe considered to be all vendors of the Special Education Cluster whose transactions for the year ended June 30, 2020 exceeded the micro-purchase threshold of $10,000. Payroll and benefit-related transactions were excluded from the universe. Based on these requirements, the total universe is 4 vendors totaling $67,315. This is also considered the population size. Sample Size: The total universe/population size of 4 vendors was selected for testing. Recommendation: We recommend for the School Board to more fully implement and follow its revised policies and procedures for purchases made with federal awards so that these newly required federal procurement regulations are followed. We recommend that the School Board include Appendix II to Part II Summary as applicable in their future contracts. Repeat Finding: No. View of Responsible Official: We will revise our policies and procedures on purchases with federal awards so that we will meet these newly required federal procurement regulations. We will begin including Appendix II to Part II Summary where applicable in future contracts.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION