EIN: 742892246
UEI: E96VGANM1FR3
Audited by: Sutton Frost Cary LLP
Oversight agency: 10 [Department of Agriculture]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 7, 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 July 7, 2026 (54 days ago).
What is a management decision? →During allowable cost and activities testing for the Child Nutrition Cluster, 3 out of 26 payroll transactions tested included employee time that was unrelated to approved grant activities. Cause: The School's internal controls related to employee time were not operating effectively and employee mistakes in coding did not get detected and corrected in a timely manner. Effect: Employee time was allocated to the Child Nutrition Cluster when the employee was not in a position that was related to grant activities. Questioned Costs: None Recommendation: Management should reassess their internal controls related to employee time approval to ensure it is sufficient to appropriately detect and correct any error in fund coding. Management’s Response: See corrective action plan.
Show full finding ▾Hide full finding ▴Finding No. 2025‐001: Allowable Costs and Activities - Significant deficiency in internal control over compliance and compliance finding. Child Nutrition Cluster Criteria: Section 200 of the Code of Federal Regulations requires recipients to implement robust internal controls to ensure compliance with cost principles for all activities allocated to the grant. Condition: During allowable cost and activities testing for the Child Nutrition Cluster, 3 out of 26 payroll transactions tested included employee time that was unrelated to approved grant activities. Cause: The School's internal controls related to employee time were not operating effectively and employee mistakes in coding did not get detected and corrected in a timely manner. Effect: Employee time was allocated to the Child Nutrition Cluster when the employee was not in a position that was related to grant activities. Questioned Costs: None Recommendation: Management should reassess their internal controls related to employee time approval to ensure it is sufficient to appropriately detect and correct any error in fund coding. Management’s Response: See corrective action plan.
No. 2025-001 Subject: Allowable Costs and Activities ‐ Significant deficiency in internal control over compliance and compliance finding. Name of Contact Person: Byron Jones, CFO Phone Number: (480) 270-5438 Anticipated Completion Date: June 30, 2026 Corrective Action: We will strengthen internal controls over employee time coding by implementing enhanced review procedures to ensure only allowable Child Nutrition activities are charged to the grant. Supervisors and the accounting team will review all payroll coding charged to the Child Nutrition Cluster to verify that the employee’s position and duties align with approved grant activities. These improved internal procedures will provide proper compliance over allowable costs. We will also conduct an annual audit of all grant-funded employee positions at the start of each school year, reviewed by the grants team, HR, and accounting, to verify the accuracy of all employee costing allocations to federal grants and to ensure any miscoding errors are identified and corrected in a timely manner.
FAC accepted this audit on December 10, 2024 — management decision was due June 10, 2025.
During allowable cost testing for federal grants, for 3 out of 17 payroll transactions tested, the amount charged to the grant did not agree to actual time and effort. Cause: Funding percentages in the accounting system did not match the actual time and effort per the semi‐annual time and effort certification logs. Effect: The School's reporting of grant time and effort was not fully documented, in accordance with internal control over compliance procedures. The cumulative effect of the exceptions noted during tested resulted in the grants being undercharged by the School. Questioned Costs: None Recommendation: Management should ensure amount charged to the grants agree to the approved percentage per the semi‐annual time and effort certification logs before the request for reimbursement is submitted.
Show full finding ▾Hide full finding ▴Finding 2024‐003: Allowable costs – Significant deficiency in internal control over compliance and compliance finding. Title I Grants to Local Educational Agencies ALN 84.010 Criteria: Section 200 of the Code of Federal Regulations requires recipients to implement robust internal controls to ensure compliance with cost principles for all transactions charged to the grant. Condition: During allowable cost testing for federal grants, for 3 out of 17 payroll transactions tested, the amount charged to the grant did not agree to actual time and effort. Cause: Funding percentages in the accounting system did not match the actual time and effort per the semi‐annual time and effort certification logs. Effect: The School's reporting of grant time and effort was not fully documented, in accordance with internal control over compliance procedures. The cumulative effect of the exceptions noted during tested resulted in the grants being undercharged by the School. Questioned Costs: None Recommendation: Management should ensure amount charged to the grants agree to the approved percentage per the semi‐annual time and effort certification logs before the request for reimbursement is submitted.
No. 2024-003 Subject: Allowable costs - Significant deficiency in internal control over compliance and compliance finding. Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: We will review the funding percentage in the accounting system to the approved percentages in the semi-annual time and effort logs to verify accuracy. These improved internal procedures will provide proper compliance over allowable costs. Annual audit of all grant-funded employee positions at the start of each school year, reviewed by grants team, HR, and accounting to verify accuracy of all employee costing allocations to grants.
During allowable cost testing for federal grants, for 3 out of 17 payroll transactions tested, the amount charged to the grant did not agree to actual time and effort. Cause: Funding percentages in the accounting system did not match the actual time and effort per the semi‐annual time and effort certification logs. Effect: The School's reporting of grant time and effort was not fully documented, in accordance with internal control over compliance procedures. The cumulative effect of the exceptions noted during tested resulted in the grants being undercharged by the School. Questioned Costs: None Recommendation: Management should ensure amount charged to the grants agree to the approved percentage per the semi‐annual time and effort certification logs before the request for reimbursement is submitted.
Show full finding ▾Hide full finding ▴Finding 2024‐003: Allowable costs – Significant deficiency in internal control over compliance and compliance finding. Title I Grants to Local Educational Agencies ALN 84.010 Criteria: Section 200 of the Code of Federal Regulations requires recipients to implement robust internal controls to ensure compliance with cost principles for all transactions charged to the grant. Condition: During allowable cost testing for federal grants, for 3 out of 17 payroll transactions tested, the amount charged to the grant did not agree to actual time and effort. Cause: Funding percentages in the accounting system did not match the actual time and effort per the semi‐annual time and effort certification logs. Effect: The School's reporting of grant time and effort was not fully documented, in accordance with internal control over compliance procedures. The cumulative effect of the exceptions noted during tested resulted in the grants being undercharged by the School. Questioned Costs: None Recommendation: Management should ensure amount charged to the grants agree to the approved percentage per the semi‐annual time and effort certification logs before the request for reimbursement is submitted.
No. 2024-003 Subject: Allowable costs - Significant deficiency in internal control over compliance and compliance finding. Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: We will review the funding percentage in the accounting system to the approved percentages in the semi-annual time and effort logs to verify accuracy. These improved internal procedures will provide proper compliance over allowable costs. Annual audit of all grant-funded employee positions at the start of each school year, reviewed by grants team, HR, and accounting to verify accuracy of all employee costing allocations to grants.
During reporting testing for federal grants, 1 out of 4 monthly claims for reimbursements did not have documented support of review and approval prior to the claim being submitted. Cause: The School did not have a standard procedure in place to document management’s review and approval for monthly claims for reimbursements. Effect: The Organization’s reporting of monthly claims for reimbursement are not fully documented in accordance with internal control procedures over compliance. Questioned Costs: None Recommendation: Management should implement controls to ensure related documentation of approval for all monthly claims for reimbursement prior to submission.
Show full finding ▾Hide full finding ▴Finding 2024‐004: Reporting – Significant deficiency in internal control over compliance. Child Nutrition Cluster Criteria: Section 200 of the Code of Federal Regulations requires recipients to implement robust internal controls to ensure compliance for all required reporting submissions. Condition: During reporting testing for federal grants, 1 out of 4 monthly claims for reimbursements did not have documented support of review and approval prior to the claim being submitted. Cause: The School did not have a standard procedure in place to document management’s review and approval for monthly claims for reimbursements. Effect: The Organization’s reporting of monthly claims for reimbursement are not fully documented in accordance with internal control procedures over compliance. Questioned Costs: None Recommendation: Management should implement controls to ensure related documentation of approval for all monthly claims for reimbursement prior to submission.
No. 2024-004 Subject: Reporting - Significant deficiency in internal control over compliance Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: Management will implement internal controls related to documentation of approval for all monthly NSLP claims for reimbursement prior to submission. We will establish a formalized procedure to ensure that all monthly claims for reimbursement undergo documented management review and approval before submission. This procedure will clearly define the review process and designate responsible personnel for each step to maintain accountability. All reviewed and approved claims will be accompanied by signed documentation as evidence of compliance. All Food Service personnel involved in the reimbursement submission process will receive training on the new procedure to ensure understanding and adherence to the documentation requirements.
During reporting testing for federal grants, 1 out of 4 monthly claims for reimbursements did not have documented support of review and approval prior to the claim being submitted. Cause: The School did not have a standard procedure in place to document management’s review and approval for monthly claims for reimbursements. Effect: The Organization’s reporting of monthly claims for reimbursement are not fully documented in accordance with internal control procedures over compliance. Questioned Costs: None Recommendation: Management should implement controls to ensure related documentation of approval for all monthly claims for reimbursement prior to submission.
Show full finding ▾Hide full finding ▴Finding 2024‐004: Reporting – Significant deficiency in internal control over compliance. Child Nutrition Cluster Criteria: Section 200 of the Code of Federal Regulations requires recipients to implement robust internal controls to ensure compliance for all required reporting submissions. Condition: During reporting testing for federal grants, 1 out of 4 monthly claims for reimbursements did not have documented support of review and approval prior to the claim being submitted. Cause: The School did not have a standard procedure in place to document management’s review and approval for monthly claims for reimbursements. Effect: The Organization’s reporting of monthly claims for reimbursement are not fully documented in accordance with internal control procedures over compliance. Questioned Costs: None Recommendation: Management should implement controls to ensure related documentation of approval for all monthly claims for reimbursement prior to submission.
No. 2024-004 Subject: Reporting - Significant deficiency in internal control over compliance Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: Management will implement internal controls related to documentation of approval for all monthly NSLP claims for reimbursement prior to submission. We will establish a formalized procedure to ensure that all monthly claims for reimbursement undergo documented management review and approval before submission. This procedure will clearly define the review process and designate responsible personnel for each step to maintain accountability. All reviewed and approved claims will be accompanied by signed documentation as evidence of compliance. All Food Service personnel involved in the reimbursement submission process will receive training on the new procedure to ensure understanding and adherence to the documentation requirements.
FAC accepted this audit on October 1, 2025 — management decision was due April 1, 2026.
During allowable cost testing for federal grants, for 3 out of 17 payroll transactions tested, the amount charged to the grant did not agree to actual time and effort. Cause: Funding percentages in the accounting system did not match the actual time and effort per the semi‐annual time and effort certification logs. Effect: The School's reporting of grant time and effort was not fully documented, in accordance with internal control over compliance procedures. The cumulative effect of the exceptions noted during tested resulted in the grants being undercharged by the School. Questioned Costs: None Recommendation: Management should ensure amount charged to the grants agree to the approved percentage per the semi‐annual time and effort certification logs before the request for reimbursement is submitted.
Show full finding ▾Hide full finding ▴Finding 2024‐003: Allowable costs – Significant deficiency in internal control over compliance and compliance finding. Title I Grants to Local Educational Agencies ALN 84.010 Criteria: Section 200 of the Code of Federal Regulations requires recipients to implement robust internal controls to ensure compliance with cost principles for all transactions charged to the grant. Condition: During allowable cost testing for federal grants, for 3 out of 17 payroll transactions tested, the amount charged to the grant did not agree to actual time and effort. Cause: Funding percentages in the accounting system did not match the actual time and effort per the semi‐annual time and effort certification logs. Effect: The School's reporting of grant time and effort was not fully documented, in accordance with internal control over compliance procedures. The cumulative effect of the exceptions noted during tested resulted in the grants being undercharged by the School. Questioned Costs: None Recommendation: Management should ensure amount charged to the grants agree to the approved percentage per the semi‐annual time and effort certification logs before the request for reimbursement is submitted.
No. 2024-003 Subject: Allowable costs - Significant deficiency in internal control over compliance and compliance finding. Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: We will review the funding percentage in the accounting system to the approved percentages in the semi-annual time and effort logs to verify accuracy. These improved internal procedures will provide proper compliance over allowable costs. Annual audit of all grant-funded employee positions at the start of each school year, reviewed by grants team, HR, and accounting to verify accuracy of all employee costing allocations to grants.
During allowable cost testing for federal grants, for 3 out of 17 payroll transactions tested, the amount charged to the grant did not agree to actual time and effort. Cause: Funding percentages in the accounting system did not match the actual time and effort per the semi‐annual time and effort certification logs. Effect: The School's reporting of grant time and effort was not fully documented, in accordance with internal control over compliance procedures. The cumulative effect of the exceptions noted during tested resulted in the grants being undercharged by the School. Questioned Costs: None Recommendation: Management should ensure amount charged to the grants agree to the approved percentage per the semi‐annual time and effort certification logs before the request for reimbursement is submitted.
Show full finding ▾Hide full finding ▴Finding 2024‐003: Allowable costs – Significant deficiency in internal control over compliance and compliance finding. Title I Grants to Local Educational Agencies ALN 84.010 Criteria: Section 200 of the Code of Federal Regulations requires recipients to implement robust internal controls to ensure compliance with cost principles for all transactions charged to the grant. Condition: During allowable cost testing for federal grants, for 3 out of 17 payroll transactions tested, the amount charged to the grant did not agree to actual time and effort. Cause: Funding percentages in the accounting system did not match the actual time and effort per the semi‐annual time and effort certification logs. Effect: The School's reporting of grant time and effort was not fully documented, in accordance with internal control over compliance procedures. The cumulative effect of the exceptions noted during tested resulted in the grants being undercharged by the School. Questioned Costs: None Recommendation: Management should ensure amount charged to the grants agree to the approved percentage per the semi‐annual time and effort certification logs before the request for reimbursement is submitted.
No. 2024-003 Subject: Allowable costs - Significant deficiency in internal control over compliance and compliance finding. Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: We will review the funding percentage in the accounting system to the approved percentages in the semi-annual time and effort logs to verify accuracy. These improved internal procedures will provide proper compliance over allowable costs. Annual audit of all grant-funded employee positions at the start of each school year, reviewed by grants team, HR, and accounting to verify accuracy of all employee costing allocations to grants.
During reporting testing for federal grants, 1 out of 4 monthly claims for reimbursements did not have documented support of review and approval prior to the claim being submitted. Cause: The School did not have a standard procedure in place to document management’s review and approval for monthly claims for reimbursements. Effect: The Organization’s reporting of monthly claims for reimbursement are not fully documented in accordance with internal control procedures over compliance. Questioned Costs: None Recommendation: Management should implement controls to ensure related documentation of approval for all monthly claims for reimbursement prior to submission.
Show full finding ▾Hide full finding ▴Finding 2024‐004: Reporting – Significant deficiency in internal control over compliance. Child Nutrition Cluster Criteria: Section 200 of the Code of Federal Regulations requires recipients to implement robust internal controls to ensure compliance for all required reporting submissions. Condition: During reporting testing for federal grants, 1 out of 4 monthly claims for reimbursements did not have documented support of review and approval prior to the claim being submitted. Cause: The School did not have a standard procedure in place to document management’s review and approval for monthly claims for reimbursements. Effect: The Organization’s reporting of monthly claims for reimbursement are not fully documented in accordance with internal control procedures over compliance. Questioned Costs: None Recommendation: Management should implement controls to ensure related documentation of approval for all monthly claims for reimbursement prior to submission.
No. 2024-004 Subject: Reporting - Significant deficiency in internal control over compliance Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: Management will implement internal controls related to documentation of approval for all monthly NSLP claims for reimbursement prior to submission. We will establish a formalized procedure to ensure that all monthly claims for reimbursement undergo documented management review and approval before submission. This procedure will clearly define the review process and designate responsible personnel for each step to maintain accountability. All reviewed and approved claims will be accompanied by signed documentation as evidence of compliance. All Food Service personnel involved in the reimbursement submission process will receive training on the new procedure to ensure understanding and adherence to the documentation requirements.
During reporting testing for federal grants, 1 out of 4 monthly claims for reimbursements did not have documented support of review and approval prior to the claim being submitted. Cause: The School did not have a standard procedure in place to document management’s review and approval for monthly claims for reimbursements. Effect: The Organization’s reporting of monthly claims for reimbursement are not fully documented in accordance with internal control procedures over compliance. Questioned Costs: None Recommendation: Management should implement controls to ensure related documentation of approval for all monthly claims for reimbursement prior to submission.
Show full finding ▾Hide full finding ▴Finding 2024‐004: Reporting – Significant deficiency in internal control over compliance. Child Nutrition Cluster Criteria: Section 200 of the Code of Federal Regulations requires recipients to implement robust internal controls to ensure compliance for all required reporting submissions. Condition: During reporting testing for federal grants, 1 out of 4 monthly claims for reimbursements did not have documented support of review and approval prior to the claim being submitted. Cause: The School did not have a standard procedure in place to document management’s review and approval for monthly claims for reimbursements. Effect: The Organization’s reporting of monthly claims for reimbursement are not fully documented in accordance with internal control procedures over compliance. Questioned Costs: None Recommendation: Management should implement controls to ensure related documentation of approval for all monthly claims for reimbursement prior to submission.
No. 2024-004 Subject: Reporting - Significant deficiency in internal control over compliance Name of Contact Person: Ingmar Berg, CFO Phone Number: (480) 270-5438 x1091 Anticipated Completion Date: June 30, 2025 Corrective Action: Management will implement internal controls related to documentation of approval for all monthly NSLP claims for reimbursement prior to submission. We will establish a formalized procedure to ensure that all monthly claims for reimbursement undergo documented management review and approval before submission. This procedure will clearly define the review process and designate responsible personnel for each step to maintain accountability. All reviewed and approved claims will be accompanied by signed documentation as evidence of compliance. All Food Service personnel involved in the reimbursement submission process will receive training on the new procedure to ensure understanding and adherence to the documentation requirements.
FAC accepted this audit on November 28, 2023 — management decision was due May 28, 2024.
FAC accepted this audit on December 14, 2022 — management decision was due June 14, 2023.
During testing of Assessment System Security management was unable to provide support for required documentation for 2 of the 7 items selected for testing. Cause: The School does not have a procedure in place to timely identify if Assessment System Security required documentation has been completed. Effect: The School?s required documentation is not fully documented in accordance with TEA and the Texas Department of Education. Questioned costs: None. Recommendation: We recommend the School implement a procedure to timely review submitted documentation and a central location to store all required documentation. Management?s response: See corrective action plan.
Show full finding ▾Hide full finding ▴2022-001 Special Tests ? Assessment System Security: Internal Controls over required documentation and approval for state testing ALN# 84.010A Title I Grants to Local Education Agencies. Criteria: Internal controls over the Assessment System Security required documentation and approval for state testing should be designed and implemented to ensure that the teacher oath, testing materials checklist and seating chart approval is properly documented to reflect school compliance with the TEA and the Texas Department of Education. Condition: During testing of Assessment System Security management was unable to provide support for required documentation for 2 of the 7 items selected for testing. Cause: The School does not have a procedure in place to timely identify if Assessment System Security required documentation has been completed. Effect: The School?s required documentation is not fully documented in accordance with TEA and the Texas Department of Education. Questioned costs: None. Recommendation: We recommend the School implement a procedure to timely review submitted documentation and a central location to store all required documentation. Management?s response: See corrective action plan.
Summary Description: During the summer the Campus Testing Coordinator (Instructional Coach) for the campus resigned. Although the testing coordinators received testing security training that included the required storage of documentation, there was not a set of internal controls to ensure that the documentation would be secured for the district. Points of Contact: ? Superintendent, Dr. Mechiel Rozas, mechiel.rozas@legacytraditional.org ? District STAAR Testing Coordinator, Valarie Walker, valarie.walker@legacytraditional.org ? Campus STAAR Campus Coordinator 2002-2023: Kehinde Stevenson, Evonne Murillo, Kim Wood, Molly Stumpo Resources Requirements: ? Campus Testing Coordinators have trained each semester using slides prepared by TEA with an overview of documentations requirements and storage. ? Testing Security training for Campus Testing Coordinators using the Learning Management System (LMS) in the Testing Information Distribution Engine (T.I.D.E.) Planned Milestones: ? Fall Campus Testing Coordinator Training (October 27, 2022) ? Training and signed documentation to verify understanding of the security requirements for the year and the steps to ensure securing protocols are followed if there is an early departure from duties. ? Campus Testing Coordinators meet with the District Testing Coordinator monthly to review expectations and confirm compliance. This information is shared with the district Superintendent on the first Monday in each month. ? Spring Campus Testing Coordinator Training (January 11, 2023) ? Training and signed documentation to verify understanding of the security requirements for the year and the steps to ensure securing protocols are followed if there is an early departure from duties. ? Original copies of documents submitted to the District Testing Coordinator at the end of each testing session and copies filed for the campus and maintained at the campus level (December 16, 2022 EOC; April 3, 2023 TELPAS; May 15, 2023 Spring STAAR and EOC; June 30, 2023 Summer EOC). Scheduled Completion Date: The campus Testing Coordinator will secure the Campus Principal signage page completed with final submission to the District Testing Coordinator along with Principal oaths by May 15, 2023 for elementary campuses and June 30,2023 for the high school campus. Change in Procedure: The District Testing Coordinator has enhanced the training for testing procedures and systems of accountability have been created. Campus Testing Coordinator training now includes testing security responsibilities if there is a departure from the position or the district. The district will continue to train Campus Testing Coordinators twice a year, but the internal controls now include the collection of original documents on specific dates at the end of each testing session, rather than at the end of the school year, along with monthly checks for compliance. The Principal of each campus must review the testing binder and secure storage of materials after completing the signage document in the testing binder and ensure submission of the testing binder to the District Testing Coordinator by the scheduled completion dates.
FAC accepted this audit on February 3, 2022 — management decision was due August 3, 2022.
FAC accepted this audit on March 4, 2021 — management decision was due September 4, 2021.
FAC accepted this audit on February 3, 2020 — management decision was due August 3, 2020.
FAC accepted this audit on February 7, 2019 — management decision was due August 7, 2019.
FAC accepted this audit on February 6, 2018 — management decision was due August 6, 2018.
FAC accepted this audit on February 5, 2017 — management decision was due August 5, 2017.
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