NINNEKAH SCHOOL DISTRICT I-51Local Government

EIN: 731080375

UEI: EKXNLLKG28Z3

Audited by: BRITTON, KUYKENDALL & MILLER, CPA'S

Oversight agency: 84 [Department of Education]

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Data as of August 28, 2026

NINNEKAH SCHOOL DISTRICT I-515 audit years3 findings1 repeat
5
Audit Years
3
Total Findings
1
Repeat Findings
$1.1M
Federal Awards Expended (FY 2025)

FY 2025-06-30

NON-GAAP BASISMATERIAL NONCOMPLIANCE DISCLOSED$1,130,009 federal awards expendedNo findings recorded this year

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 30, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 30, 2026 (32 days from today).

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FY 2024-06-30

NON-GAAP BASISMATERIAL NONCOMPLIANCE DISCLOSED$1,157,695 federal awards expended

FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.

2024-003
Special Tests & Provisions
MATERIAL WEAKNESSOTHER MATTERS

Federal expenditures were not properly accounted for in the Oklahoma Cost Accounting System in the federal project. Due to errors, the District’s accounting records submitted to the Oklahoma Cost Accounting System for expenses in the federal project were overstated. Encumbrances were left open in accounts payable that were unused. Criteria: Public schools must follow the Oklahoma Cost Accounting System which ensures legal compliance by recording and summarizing financial transactions. Part of the coding ensures that federal expenditures are coded as such and reported to the Oklahoma State Department of Education which allows for tracking of federal expenditures. Cause: The District’s internal control procedure of reviewing the accounting records for completeness and accuracy by accounting personnel and management that were to provide effective oversight of the District’s financial reporting failed to detect proper reporting of federal expenditures in the accounting records. Effect: The issue resulted in incorrect reporting of expenditures submitted to the Oklahoma State Department of Education. Due to the error, the Districts expenses for the federal project were overstated. Encumbrances were set up in the amount of $153,030.96, but the District only claimed $100,808.10 on the final claim leaving $52,222.86 overstated. Therefore, the expenditures reported on the Schedule of Expenditures of Federal Awards will not match the numbers submitted to the Oklahoma State Department of Education. Recommendation: The District’s accounting personnel and management must continually monitor and review all expenses to verify coding. Controls should be put in place to compare federal program records with what is reported in the Oklahoma Cost Accounting System. Encumbrances should be reviewed at year end and closed if not accurate. Encumbrances should only be set up in a federal project code if they are completed and paid by September 30th and claimed in the federal program. Internal controls should be in place to provide effective oversight of the District’s financial reporting by accounting personnel and those charged with governance. District’s Response: The District will review all federal program coding and year end encumbrances. Questioned Costs: $ 0

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Full finding narrative

Material Weaknesses: 2024-003 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 ARP ESSER III Assistance Listing: 84.425U Grant Period: Year Ending June 30, 2024 Condition: Federal expenditures were not properly accounted for in the Oklahoma Cost Accounting System in the federal project. Due to errors, the District’s accounting records submitted to the Oklahoma Cost Accounting System for expenses in the federal project were overstated. Encumbrances were left open in accounts payable that were unused. Criteria: Public schools must follow the Oklahoma Cost Accounting System which ensures legal compliance by recording and summarizing financial transactions. Part of the coding ensures that federal expenditures are coded as such and reported to the Oklahoma State Department of Education which allows for tracking of federal expenditures. Cause: The District’s internal control procedure of reviewing the accounting records for completeness and accuracy by accounting personnel and management that were to provide effective oversight of the District’s financial reporting failed to detect proper reporting of federal expenditures in the accounting records. Effect: The issue resulted in incorrect reporting of expenditures submitted to the Oklahoma State Department of Education. Due to the error, the Districts expenses for the federal project were overstated. Encumbrances were set up in the amount of $153,030.96, but the District only claimed $100,808.10 on the final claim leaving $52,222.86 overstated. Therefore, the expenditures reported on the Schedule of Expenditures of Federal Awards will not match the numbers submitted to the Oklahoma State Department of Education. Recommendation: The District’s accounting personnel and management must continually monitor and review all expenses to verify coding. Controls should be put in place to compare federal program records with what is reported in the Oklahoma Cost Accounting System. Encumbrances should be reviewed at year end and closed if not accurate. Encumbrances should only be set up in a federal project code if they are completed and paid by September 30th and claimed in the federal program. Internal controls should be in place to provide effective oversight of the District’s financial reporting by accounting personnel and those charged with governance. District’s Response: The District will review all federal program coding and year end encumbrances. Questioned Costs: $ 0

Corrective Action Plan

The accounting staff and management responsible for coding within the District will consistently oversee and conduct monthly edit checks in the accounting software to assess all expenses and confirm their coding accuracy. These monthly checks will help identify any coding mistakes in the Oklahoma Cost Accounting System, ensuring that expenses are thoroughly reviewed and corrected as necessary. Any inquiries or issues regarding coding will be addressed in collaboration with the Oklahoma State Department of Education and/or school auditors to confirm the appropriate coding options. Monthly spreadsheets have been developed and will be submitted to the Superintendent for evaluation following the reconciliation of claims related to Federal expenditures. The Expenditures of Federal Awards will match the numbers submitted to the Oklahoma Cost Accounting System. Additionally, encumbrances will be examined at the end of the year and will be closed if found to be inaccurate. All actions will be corrected by June 30, 2025.

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2024-004
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT OF 2023-004OTHER MATTERS

Construction projects paid with federal monies did not meet the compliance requirements of the Davis-Bacon Act. Criteria: The Davis-Bacon Act requires that nonfederal entities shall meet certain requirements for the construction, alteration or repair of public buildings or public works in excess of $2,000.00. Any contract entered into must include the locally prevailing wage to be paid to workers including fringe benefits. The contractor is obliged to pay at least the prevailing wage listed in the contract. Contractors are required to pay covered workers weekly and submit weekly certified payrolls to the contracting entity. They are also required to post the applicable Davis-Bacon wage determination along with the Davis-Bacon poster at the job site. Cause: The District did not follow the requirements of the Davis-Bacon Act when expending federal monies. Effect: The District could be liable for paying any additional wages if the contractor did not pay prevailing wage rates to laborers working on the project, or the expenditures could be disallowed for the expenditures that were subject to the Davis-Bacon Act. Recommendation: We recommend the District develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an effective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. Also, ensuring that all items are posted at the work site to ensure compliance. District’s Response: The District will develop internal controls to ensure that in the future if federal awards are expended on construction that all requirements of the Davis-Bacon Act will be met. Questioned Costs: $ 0

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Full finding narrative

Material Weaknesses: 2024-004 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 ARP ESSER III Assistance Listing: 84.425U Grant Period: Year Ending June 30, 2024 Condition: Construction projects paid with federal monies did not meet the compliance requirements of the Davis-Bacon Act. Criteria: The Davis-Bacon Act requires that nonfederal entities shall meet certain requirements for the construction, alteration or repair of public buildings or public works in excess of $2,000.00. Any contract entered into must include the locally prevailing wage to be paid to workers including fringe benefits. The contractor is obliged to pay at least the prevailing wage listed in the contract. Contractors are required to pay covered workers weekly and submit weekly certified payrolls to the contracting entity. They are also required to post the applicable Davis-Bacon wage determination along with the Davis-Bacon poster at the job site. Cause: The District did not follow the requirements of the Davis-Bacon Act when expending federal monies. Effect: The District could be liable for paying any additional wages if the contractor did not pay prevailing wage rates to laborers working on the project, or the expenditures could be disallowed for the expenditures that were subject to the Davis-Bacon Act. Recommendation: We recommend the District develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an effective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. Also, ensuring that all items are posted at the work site to ensure compliance. District’s Response: The District will develop internal controls to ensure that in the future if federal awards are expended on construction that all requirements of the Davis-Bacon Act will be met. Questioned Costs: $ 0

Corrective Action Plan

The District has undergone training regarding the Davis-Bacon Act and will now adhere to its requirements when federal funds are utilized for construction projects. This includes compliance with contracts, specifically incorporating prevailing wage clauses and ensuring that federal wage rates and fringe benefits are met through a diligent monitoring process. This process involves the collection and review of weekly certified payroll reports from contractors or subcontractors. The District will also ensure that all information pertaining to the Davis-Bacon Act is displayed at the job site to maintain compliance. Furthermore, all accounting and management personnel will participate in annual training to remain informed about the Davis-Bacon Act's requirements. All actions are scheduled to be completed by June 30, 2025.

Prior Finding References

2023-004

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FY 2023-06-30

NON-GAAP BASISMATERIAL NONCOMPLIANCE DISCLOSED$1,396,477 federal awards expended

FAC accepted this audit on April 1, 2024 — management decision was due October 1, 2024.

2023-004
Special Tests & Provisions
MATERIAL WEAKNESSOTHER MATTERS

Construction projects paid with federal monies did not meet the compliance requirements of the Davis-Bacon Act. Criteria: The Davis-Bacon Act requires that nonfederal entities shall meet certain requirements for the construction, alteration or repair of public buildings or public works in excess of $2,000.00. Any contract entered into must include the locally prevailing wage to be paid to workers including fringe benefits. The contractor is obliged to pay at least the prevailing wage listed in the contract. Contractors are required to pay covered workers weekly and submit weekly certified payrolls to the contracting entity. They are also required to post the applicable Davis-Bacon wage determination along with the Davis-Bacon poster at the job site. Cause: The District was unaware of the need to follow the requirements of the Davis-Bacon Act when expending federal monies on the purchase and installation of HVAC units. Effect: The District could be liable for paying any additional wages if the contractor did not pay prevailing wage rates to laborers working on the project, or the expenditures could be disallowed for the expenditures that were subject to the Davis-Bacon Act. Recommendation: We recommend the District develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an effective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. Also, ensuring that all items are posted at the work site to ensure compliance. District’s Response: The District will develop internal controls to ensure that in the future if federal awards are expended on construction that all requirements of the Davis-Bacon Act will be met. Questioned Costs: $ 0

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Full finding narrative

Material Weaknesses: 2023-004 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 ARP ESSER III Assistance Listing: 84.425U Grant Period: Year Ending June 30, 2023 Condition: Construction projects paid with federal monies did not meet the compliance requirements of the Davis-Bacon Act. Criteria: The Davis-Bacon Act requires that nonfederal entities shall meet certain requirements for the construction, alteration or repair of public buildings or public works in excess of $2,000.00. Any contract entered into must include the locally prevailing wage to be paid to workers including fringe benefits. The contractor is obliged to pay at least the prevailing wage listed in the contract. Contractors are required to pay covered workers weekly and submit weekly certified payrolls to the contracting entity. They are also required to post the applicable Davis-Bacon wage determination along with the Davis-Bacon poster at the job site. Cause: The District was unaware of the need to follow the requirements of the Davis-Bacon Act when expending federal monies on the purchase and installation of HVAC units. Effect: The District could be liable for paying any additional wages if the contractor did not pay prevailing wage rates to laborers working on the project, or the expenditures could be disallowed for the expenditures that were subject to the Davis-Bacon Act. Recommendation: We recommend the District develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an effective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. Also, ensuring that all items are posted at the work site to ensure compliance. District’s Response: The District will develop internal controls to ensure that in the future if federal awards are expended on construction that all requirements of the Davis-Bacon Act will be met. Questioned Costs: $ 0

Corrective Action Plan

Air conditioners were purchased by the district as part of the remodeling of the high school to go along with the bond issue. The purchase was made in good faith and the superintendent believed it to be within compliance of the bond issue. The district accepts that the actions were not in compliance and will review policy and seek training opportunities to not make the same mistake in the future. All actions will be corrected by June 30, 2024.

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FY 2022-06-30

NON-GAAP BASIS$977,594 federal awards expendedNo findings recorded this year

FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.

FY 2021-06-30

NON-GAAP BASIS$810,266 federal awards expendedNo findings recorded this year

FAC accepted this audit on May 30, 2022 — management decision was due November 30, 2022.

Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.

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