Francis Tuttle Technology Center School District No. 21Higher Education

2021-001 Suspension and Debarment Control Higher Education Emergency Relief Fund (HEERF); CFDA 84.425F Compliance Requirement: Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov/ (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the fiscal year ended June 30, 2021, it does not appear that the expenditures under the HEERF grants have a consistent control in place to check applicable vendors for potential suspension and/or debarment for covered transactions. No vendors selected in our testwork were listed as suspended or debarred. Cause: The District does not appear to have a consistent process in place to check vendors under covered transactions ($25,000 or more) in accordance with federal regulations. Effect: The District could be out of compliance with federal requirements regarding suspension and debarment controls by potentially contracting with a suspended or debarred vendor. Context/Sampling: No covered transactions in our nonstatistical sample appeared to have a verifiable control in place to identify the vendor as suspended or debarred prior to transacting with that vendor. Repeat Finding From Prior Year: No Questioned costs: None, no vendors in our samples were listed as suspended or debarred. Recommendation: Control procedures should be implemented to ensure that all vendors under covered transactions are checked against the federal website for vendors that could be suspended or debarred prior to transacting with such vendors or another process as allowed by the federal regulations discussed above. Views of Responsible Officials: We agree with the finding and we will make appropriate changes to our processes by recommending that Purchasing add a phrase to Purchase Orders to address the debarment and suspension issue. In addition, we will document our review the status of vendors in our accounting system.

2021-002 Calculation of Lost Revenue Control Higher Education Emergency Relief Fund (HEERF), CFDA 84.425F Compliance Requirement: Allowable Costs Significant Deficiency in Internal Control over Compliance; Significant Deficiency in Internal Control over Financial Reporting Criteria: Reimbursement for lost revenue is allowable for the Institutional Portion program for HEERF grant funds. Generally, lost revenue refers to those revenues an institution otherwise expected but were reduced or eliminated as a result of the novel coronavirus 2019 (COVID-19) pandemic. As such, lost revenues can only be estimated. Due to the difficulty of estimating precisely when an institution should have received revenue that it otherwise did not as a result of the COVID-19 pandemic, an institution may estimate its lost revenue for the period from the declaration of the national emergency due to the COVID-19 pandemic, on March 13, 2020, through the end of its HEERF grant performance period. As a condition of receiving federal awards, nonfederal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to also maintain internal control to provide reasonable assurance of compliance with these requirements. Condition: The District did proper calculation of the lost revenue estimate. However, there was no formal review of the calculation and we detected an error to understate reimbursed lost revenues as of June 30, 2021. Cause: A formal review was not performed on the lost revenue calculation. Effect: The estimated lost revenue was calculated as a lower amount than the District was allowed using approved methodologies. Note that a lack of review does pose a risk of overstating such estimates which may lead to potential questioned costs. Context/Sampling: No sampling was used. Repeat Finding From Prior Year: No Questioned costs: None. Recommendation: We recommend a formal review of the lost revenue be performed in future years, including a review of inputs, to determine the best estimate of the District?s lost revenues. Views of Responsible Officials: We agree with the finding and will implement process to review critical calculations for grant filings.

CARES Act Student Assistance - CFDA 84.425E - Reporting U.S. Department of Education Criteria: The Coronavirus Aid, Relief, and Economic Security (CARES) Act requires public reporting of specific information pertaining to the Student Aid Portion of funds received pursuant to the Higher Education Emergency Relief Fund (HEERF) provisions of the CARES Act. The HEERF provisions identified as a critical element of that reporting requirement the estimated total number of students at the District eligible to participate in programs under Section 484 I Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to Students under Section 18004(a)(1) of the CARES Act. Condition: The District's required public report posted June 15, 2020 did not include the required information regarding the estimated total number of students at the District eligible to participate. Cause: This was a new Federal program with new and evolving compliance requirements and District management did not fully understand all of the required elements of compliance at the time this report was posted to the District's website. Effect or Potential Effect: The potential effect of failing to meet the reporting requirements is loss of funding. Questioned Costs: None. Recommendation: When receiving funding under new Federal programs, District management, consisting of the CFO and the Program director, and others considered necessary, should carefully document all of the required elements of the Federal programs, including updating those requirements as they change. Management view: Management agrees with the finding.