LYFORD CONSOLIDATED INDEPENDENT SCHOOL DISTRICTLocal Government

Reference Number: 2025-004 No secondary review of meal claim reimbursements prior to submission Child Nutrition Cluster ALN’s: 10.553, 10.555, and 10.582 Pass through identifying number: NT4XL1YGLGC5 Award Year: 2024-2025 Federal Agency: U.S. Department of Agriculture Passed through State Department of Agriculture Criteria: 2 CFR §200.303 requires non-Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance that the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. Program regulations for the Child Nutrition Cluster require reimbursement claims to be accurate and supported by appropriate documentation prior to submission. Effective internal controls over reporting include supervisory review of reimbursement claims to ensure accuracy and completeness before submission. Condition Found: During testing of reimbursement claims submitted under the Child Nutrition Cluster, we noted the School District did not perform a documented secondary review of monthly meal reimbursement claims prior to submission to the pass-through agency. Claims were prepared and submitted by the same individual without evidence of supervisory review or approval. Cause: Management indicated the control requiring a second review was informal and not consistently performed due to staffing limitations and turnover within the food service department. Additionally, the control was not formally documented in written procedures. Effect: Without a secondary review, there is an increased risk that reimbursement claims may contain errors, including inaccurate meal counts or calculation errors, which could result in over- or underreimbursement and potential noncompliance with Federal reporting requirements. Questioned Cost: $0. The District’s claims tested were mathematically accurate and supported, however, the control was not properly documented. Recommendation: We recommend the District implement and document a formal secondary review control over all Child Nutrition reimbursement claims prior to submission. Views of Responsible Officials: Management agrees with the findings. See corrective action plan

PROGRAM DESCRIPTION Reference Number: 2024-004 Proper review of payroll charges to grant funds ALN 84.425U & 84.425W COVID-19 Education Stabilization Fund Pass through identifying number: 21528001245902 Award Year: 2023-2024 Federal Agency: U.S. Department of Education Passed through State Department of Education Criteria: Non-federal entities are required to establish and maintain effective internal controls over compliance in accordance with 2 CFR 200.303(a) and 2 CFR 200.430(g) which requires that compensation charged to federal awards must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated, of which documentation must be incorporated into the official records of the entity. Condition Found: During our review of payroll charges that were funded through ESSER funds, it was noted that the District did not have adequate controls in place to monitor the payroll transactions charged to the program. Cause: Although the District implemented Skyward in the prior year, the District did not integrate the appropriate approvals into the system in a timely manner. In addition, turnover in the District Chief Financial Officer position caused difficulties in the District obtaining the proper approvals for journal entries. Effect: The District could fail to appropriately support expenditures charged to the program. Questioned Cost: $0 Recommendation: We recommend the District to implement appropriate approvals in the Skyward accounting system to provide for better oversight of transactions. Views of Responsible Officials: Management agrees with the findings. See corrective action plan beginning on page 114.

Reference Number: 2023‐003 Annual Report Card, High School Graduation rate compliance ALN 84.010 Title I Grants for Local Education Agencies Pass through identifying number: 23610101245902 Award Year: 2022‐2023 Federal Agency: U.S. Department of Education Passed through State Department of Education Criteria: Non‐federal entities are required to establish and maintain effective internal controls over compliance in accordance with 2 CFR 200.303(a). ESEA section 8101(25)(B), states: (B) COHORT REMOVAL—To remove a student from a cohort, a school or local educational agency shall require documentation, or obtain documentation from the State educational agency, to confirm that the student has transferred out, emigrated to another country, or transferred to a prison or juvenile facility, or is deceased. To confirm that a student transferred out, the District must have official written documentation that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma. Condition Found: During our review of students that were removed from the adjusted cohort, one student removal was not supported by appropriate written documentation. Cause: The documentation regarding removing the student from the adjusted cohort was not maintained. Turnover in the District PEIMS director position caused difficulties in the District locating the appropriate written documentation. Effect: The District could fail to appropriately support removing students from the adjusted cohort. Questioned Cost: $0 Recommendation: We recommend the District to maintain written documentation each time a student is removed from the adjusted cohort and place within the student file for easy access. Views of Responsible Officials: Management agrees with the findings.

Reference Number: 2021-003 TEA approval of capital outlay expenditures ALN 84.425U COVID-19 Education Stabilization Fund Passed through identifying number: 21528001245902 Award Year: 2020-2021 Federal Agency: U.S. Department of Education Passed through Texas Education agency Criteria: Non-federal entities are required to establish and maintain effective internal controls over compliance in accordance with 2 CFR 200.303. Per the CARES Act, Education Stabilization funds may be used to purchase equipment that meet the overall purpose of preventing, preparing, and responding to the COVID-19 pandemic. However, these purchases are subject to prior approval by TEA. Condition Found: The District purchased 3 HVAC units and did not receive prior approval from TEA. Cause: The District originally coded the HVAC units purchase under contracted services, however, the individual units met the District?s capitalization threshold and should have been considered when approving the use of ESSER III funds. Effect: The noted oversight resulted in reported noncompliance with requirements related to Equipment and Real Property Management. Questioned Cost:$21,390 Recommendation: CRI recommends that the Finance department review equipment purchases for capitalization thresholds to ensure proper coding and to ensure that equipment purchased with federal funds have necessary pre-approval from State and/or Federal agencies, as applicable. Views: Management agrees with the findings. See corrective action plan beginning on page 99.

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